Call for support for the draft Supplement 18 to UN R44 intended to clarify that certain belt-guides and straps can be eligible for type-approval only as a part of a Child Restraint System and not as a free-standing Child Restraint System.

Proposal to amend the transitional provisions: Extensions can be granted to CRS of group 2/3 and group 2 until 1 September 2023 according to paragraph 17.19. However, according to paragraph 17.21, no extensions shall be granted to CRS other than Group 3. In order to align these paragraphs and avoid misinterpretation, the document proposes that the date in paragraph 17.21 should be amended to 1 September 2023.

At the December 2019 GRSP session, the Commission proposed to amend the scope of UN R44 to clarify that a belt guide cannot be approved without being part of a child restraint system (paragraph 1.2). The amendment was agreed by the GRSP and sent to WP.29 together with the proposal from IC/ANEC on the phase out of the R44 (ECE/TRANS/WP.29/GRSP/2019/28) for consideration at its June 2020 session.

Upon further examination, the Commission identified that its proposed amendment was not in line with the General Guidelines for UN regulatory procedures and transitional provisions in UN Regulations. In reconsidering the drafting, the Commission concluded that de jure, a ‘guide strap’ and similar devices cannot be separately approved as a child restraint system under the current wording of UN R44.

For that reason, the Commission proposes to withdraw its initial draft amendment. The Commission underlines that the withdrawal of its draft amendment does not change its understanding of paragraph 2.8.8. of Regulation 44 that approvals granted to guide straps that are not part of a child restraints systems are not valid.