Q&A concerning the new regulation on enhanced child restraint systems.
Q&A concerning the new regulation on enhanced child restraint systems.
List of questions & answers are available on the website of UNECE. [document CRS-37-02 above]
Presentation from Erik SALTERS (DOREL) of the CLEPA analysis – Future iSize approval possibilities for IG consideration [document CRS-37-04 above]. Option “2”
could be an interim phase 1. You must not be able to see the R44 approval sticker on the baby shell when used on the base as part of an iSize approved system.
Remarks from Peter BROERTJES about Directive 2003/20/EC of the European Parliament and of the Council of 8 April 2003, amending Council Directive 91/671/EEC on the approximation of the laws of the Members States relating to compulsory use of safety belts in vehicles of less than 3,5 tonnes and the direct reference to regulation 44. According to EC lawyers, the iSize ECRS regulation can be considered as an improvement of regulation 44. This directive is then according to lawyers compatible with the use of iSize product. The EC will, if necessary communicate this in June 2013 if there are barriers from member states with the use of the new iSize regulation.
The iSize regulation will be in force on the July 9th.
Use of iSize fixtures: The CRS must fit into the iSize box for the declared height range stated on the CRS. The check of the gabarit has to be done with the CRS with the largest size of the declared range in at least one seating position. The lateral dynamic test will be performed in this configuration. For frontal impact the test shall be perform in extreme size position adjustment (worst case). The CRS can be outside the iSize box for comfort adjustability, outside the stated range, i.e. width adjustment, headrest adjustment, recline positions.
5.1. Status of I-Size implementation
EC provided a detailed overview of the state-of-play concerning the acceptance of R129 approved seats for use in the EU. It was explained that the legal experts of the EC were in the process of reviewing the issue if R129 can indeed be viewed as an adaptation to R44, or not, and that this process was not yet finalised. In parallel efforts were being made to update the Seatbelt Wearing Directive to be absolutely clear about the status of R129 and its permitted use in motor vehicles. It was stressed that the process was very much ongoing at the time of the meeting.
The position of the Member states represented in the meeting was asked.
For Hans AMERLAAN (RDW), it is not inacceptable to have the following embarrassing situation:
Countries (contracting party of 1958 agreements) allow the sale of the new enhanced Child Restraints Systems (iSize). But the National law is in contradiction and doesn’t allow the use of such products
France has also authorized the use.
Information from Rudoph GERLACH (TUV) for German market: During the meeting planned for the 15th of November between transport ministry, laboratory and CRS manufacturers in Germany, the following statement will be given: it will be allow to sells & use products homologated according to the R129.
Information from Tommy PETTERSSON (VTI), it’s legal to use product homologated according to the R129 in Sweden
According to Sergi FERRIS (SafeDesign / IDIADA) , situation in Spain is no so clear. It is not allowed but it is also not forbidden to sell and use product homologate according to the R129.
To promote R129, the group suggests adding in the new regulation a sentence clarifying that R129 is an evolution of R44.
The chairman suggests including this kind of sentence in the formal amendment ECE/TRANS/WP.29/GRSP/2013/23. ANEC volunteer to include this proposal into the document.
Peter BROERTJES (EC) highlights also that it is needed to clarify the possibility to use iSize product in Isofix seating position since a lot of contradicting information are given on this subject.
Isize Product are super Isofix then for the informal group it is clear that they can be used in a ISOFIX seating position defined by a car seat fitting list.
Final statement of the group: R129 Isofix CRS products can be installed in Isofix seating positions declared by CRS manufacturer in a car seat fitting list.
5.2. Status on I-Size logo / name
Peter BROERTJES (EC) inform the group that the European Commission succeeds to challenge the deposit of the I-size brand name by a Spanish company. The Brand name I-size is free and can be used without any restriction.