GRSP-79-34
Request for clarification regarding identification of CRS through type approval number

This document raises concerns regarding identification of child restraint systems through type approval numbers. Multiple brand names are marketed under single type approval numbers, creating market confusion and hampering consumer choice. Products with identical type approval numbers but variations in plastic parts have been identified and failed frontal impact testing. Proposed measures include limiting brand names per type approval number to five maximum, adding manufacturer names to type approval labels, and establishing a publicly accessible database of type approval information.

UNECE server
Excerpts from session reports
GRSP | Session 79 | 1-5 Jun

26. The expert from CI delivered a presentation (informal document GRSP-79-34) discussing the results of a testing campaign where some child restraint systems had failed to meet more stringent requirements than those specified in UN Regulation No. 129. Furthermore, he highlighted that several of the products that had failed the test corresponded to the same type approval but were being commercialized under different brands. He then argued that even though marketing CRSs with a common type approval under different brands was allowed by the regulation and had been common for years, the low threshold for engaging in this practice for online retailers and the large scale on which this was now taking place was problematic for both consumers and market surveillance authorities. He proposed several measures to mitigate this problem. Answering questions from the expert from the United Kingdom, the expert from CI clarified that he had no indication that the products that failed the test would have also failed the type approval tests or that they might have been counterfeit products. The expert from the Kingdom of the Netherlands clarified that for type approval purposes, it was the manufacturer name which was relevant, not the brand name, and that a single type approval would cover all brands with the same design and manufacturer. He also cautioned that a cost-benefit analysis should be undertaken before increasing the pulse used for testing during type approval, as this could result in more expensive CRSs and could ultimately result in users using less appropriate restraints. He informed that his country, as a consequence of these results and in line with a risk-based approach, would be launching a market surveillance program. Finally, he agreed that the proposal by CI to add the manufacturer name in the product could be a good idea and that the special interest group on UN Regulation No. 129 would look into it. Several experts supported this idea.