Proposal to restrict use of the colour green exclusively to the marking belt route indicators.

31. GRSP considered GRSP-72-05-Rev.1 on prevention of green indicators suggesting a belt route outside the remit of the type approval. GRSP requested the secretariat to distribute GRSP-72-05-Rev.1 with an official symbol at its May 2023 session.

30. The expert from Poland requested deferral of discussion on the belt-guide, that was type approved by the authority of her country, to the December 2020 session of GRSP due to the research test results on the belt-guide, which had not yet been made available by the expert of EC. The experts from the Netherlands and ANEC/CI argued that discussion was needed on this subject since they considered this type of CRS as dangerous. The expert from the Netherlands introduced GRSP-67-05 explaining that the belt-guide was not in the scope of the UN Regulation and could not be type approved; as such, the type approval should be withdrawn. Finally, with reference to the procedure of the 1958 Agreement, Revision 3, Articles 4.2., 10.4 and Schedule 6 (paragraphs 2 and 3), he stated that through GRSP-67-05 he sought support from other contracting parties and cooperation from the expert of Poland to avoid starting the arbitration process – according to Schedule 6 of the 1958 Agreement. The expert from ANEC/CI, introduced GRSP-67-10 and GRSP-67-36 showing the high risk of abdominal injuries in both cases due to severe submarining. In anticipation of the above-mentioned test results, the expert from Poland introduced GRSP-67-32, showing some results of tests demonstrating the performance of this belt-guide type under laboratory conditions. She also clarified that the belt-guide was type approved according to Supplement 10 to the 04 series of amendments. However, she added that according to some stakeholder opinions, this belt-guide type should had been tested according to Supplement 11, thus making the device subject to different criteria. However, she stated that in her opinion there was a clear legal basis which demonstrated that the type approval granted under Supplement 10 was the correct one. The expert of the Netherlands responded by stating that, apart from the fact that this device does not comply with several requirements of UN Regulation No. 44, a supplement only clarifies existing requirements or test procedures and does not introduce new requirements. Even when Supplement 10 was in force, it was evident that a belt guide could not be approved as a child restraint.

31. The expert from EC recalled to GRSP, that the group had agreed to his former proposal (ECE/TRANS/WP.29/GRSP/2019/28) to amend the scope of UN Regulation No 44 (Child Restraint Systems) with clarification that a belt-guide cannot be approved under Regulation 44 without being part of a child restraint system (see ECE/TRANS/WP.29/GRSP/66, paragraphs 27 and 28). However, he explained that EC had reconsidered the document submission to WP.29, since the interpretation that a “guide strap” and similar devices cannot be separately approved as a child restraint system, had already been endorsed by WP.29 at its March 2012 session (see ECE/TRANS/WP.29/1095, paragraph 35). Therefore, he introduced GRSP-67-31, that was only on the phase out of UN Regulation No. 44.

32. The Chair of GRSP referred to Schedule 6 of the 1958 Agreement, and stressed full consideration of the different opinions of the Type Approval Authorities of the concerned contracting parties, and of contracting parties applying UN Regulation No. 44. Therefore, the experts from France, Germany, Italy, Russian Federation, Spain, Switzerland and United Kingdom explicitly endorsed the request of the expert from the Netherlands to withdraw the type approval granted by Poland on the belt-guide, while none of the other present delegates indicated abstention or disagreement. The experts also noted that the Chair encouraged the expert of the Netherlands to continue discussions with the Type Approval Authority of Poland to seek cooperation with Poland in the aim to avoid the arbitration process according to Schedule 6 of the 1958 Agreement, which would start in the November 2020 session of WP.29.

33. GRSP also considered GRSP-67-14, tabled by the expert from France to correct a date in transitional provisions. Finally, GRSP adopted GRSP-67-14 and GRSP-67-31, as reproduced in Annex V to the session report. The secretariat was requested to submit the two proposals as draft Supplement 18 to the 04 series of amendment to UN Regulation No. 44, for consideration and vote at the November 2020 sessions of WP.29 and AC.1.

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.

30. The expert from Poland requested deferral of discussion on the belt-guide, that was type approved by the authority of her country, to the December 2020 session of GRSP due to the research test results on the belt-guide, which had not yet been made available by the expert of EC. The experts from the Netherlands and ANEC/CI argued that discussion was needed on this subject since they considered this type of CRS as dangerous. The expert from the Netherlands introduced GRSP-67-05 explaining that the belt-guide was not in the scope of the UN Regulation and could not be type approved; as such, the type approval should be withdrawn. Finally, with reference to the procedure of the 1958 Agreement, Revision 3, Articles 4.2., 10.4 and Schedule 6 (paragraphs 2 and 3), he stated that through GRSP-67-05 he sought support from other contracting parties and cooperation from the expert of Poland to avoid starting the arbitration process – according to Schedule 6 of the 1958 Agreement. The expert from ANEC/CI, introduced GRSP-67-10 and GRSP-67-36 showing the high risk of abdominal injuries in both cases due to severe submarining. In anticipation of the above-mentioned test results, the expert from Poland introduced GRSP-67-32, showing some results of tests demonstrating the performance of this belt-guide type under laboratory conditions. She also clarified that the belt-guide was type approved according to Supplement 10 to the 04 series of amendments. However, she added that according to some stakeholder opinions, this belt-guide type should had been tested according to Supplement 11, thus making the device subject to different criteria. However, she stated that in her opinion there was a clear legal basis which demonstrated that the type approval granted under Supplement 10 was the correct one. The expert of the Netherlands responded by stating that, apart from the fact that this device does not comply with several requirements of UN Regulation No. 44, a supplement only clarifies existing requirements or test procedures and does not introduce new requirements. Even when Supplement 10 was in force, it was evident that a belt guide could not be approved as a child restraint.

31. The expert from EC recalled to GRSP, that the group had agreed to his former proposal (ECE/TRANS/WP.29/GRSP/2019/28) to amend the scope of UN Regulation No 44 (Child Restraint Systems) with clarification that a belt-guide cannot be approved under Regulation 44 without being part of a child restraint system (see ECE/TRANS/WP.29/GRSP/66, paragraphs 27 and 28). However, he explained that EC had reconsidered the document submission to WP.29, since the interpretation that a “guide strap” and similar devices cannot be separately approved as a child restraint system, had already been endorsed by WP.29 at its March 2012 session (see ECE/TRANS/WP.29/1095, paragraph 35). Therefore, he introduced GRSP-67-31, that was only on the phase out of UN Regulation No. 44.

32. The Chair of GRSP referred to Schedule 6 of the 1958 Agreement, and stressed full consideration of the different opinions of the Type Approval Authorities of the concerned contracting parties, and of contracting parties applying UN Regulation No. 44. Therefore, the experts from France, Germany, Italy, Russian Federation, Spain, Switzerland and United Kingdom explicitly endorsed the request of the expert from the Netherlands to withdraw the type approval granted by Poland on the belt-guide, while none of the other present delegates indicated abstention or disagreement. The experts also noted that the Chair encouraged the expert of the Netherlands to continue discussions with the Type Approval Authority of Poland to seek cooperation with Poland in the aim to avoid the arbitration process according to Schedule 6 of the 1958 Agreement, which would start in the November 2020 session of WP.29.

33. GRSP also considered GRSP-67-14, tabled by the expert from France to correct a date in transitional provisions. Finally, GRSP adopted GRSP-67-14 and GRSP-67-31, as reproduced in Annex V to the session report. The secretariat was requested to submit the two proposals as draft Supplement 18 to the 04 series of amendment to UN Regulation No. 44, for consideration and vote at the November 2020 sessions of WP.29 and AC.1.

ANEC calls for support for proposal to improve UN Regulation No. 44 on Child Restraint Systems to ensure the highest protection practicable for children travelling by car.

Proposal to cease new approvals of booster-cushion CRS under UN R44 from 1 September 2021 and to amend the transitional provisions accordingly.

Proposal to introduce limit values for the chest vertical acceleration (Az) of Q dummies during dynamic testing of Enhanced Child Restraint Systems (ECRS) until such time as upper neck tension Force (Fz) and upper neck flexion moment (My) criteria can be established.

23. GRSP resumed discussion of ECE/TRANS/WP.29/GRSP/2019/19 on limit values on the chest vertical acceleration of Q-dummies during the dynamic testing of ECRS, as agreed at its December 2019 session (see ECE/TRANS/WP.29/GRSP/67, paragraph 41). The expert from CLEPA recalled to GRSP that this decision aimed to allow the collection and analysis of data monitoring. The expert from CLEPA clarified (see GRSP-67-23) that data were subsequently provided by the Type-Approval Authority and the Vehicle Certification Agency (VCA) of the United Kingdom. He added that these were supplemented with a sample from CLEPA, in order to derive the proposed limits for tension force, Fz and flexion moment. He then introduced a proposal (see GRSP-67-24) of amendments to the injury assessment criteria for frontal and rear impact to specify limit values for tension force and flexion moment measured in the upper neck of the Q0, Q1 and Q1.5 dummies. However, he recommended that other contracting parties also provide monitoring data to support this analysis and confirm the proposed limits. GRSP endorsed the request of the expert from CLEPA and agreed to resume discussion at its December 2020 session based on a revised official proposal. Moreover, the experts from the Global NCAP and ANEC on behalf of CI withdrew ECE/TRANS/WP.29/GRSP/2019/19. GRSP agreed to defer consideration of GRSP-66-28 to the December 2020 session, due to the lack of time.

Proposal to prohibit new type approvals under UN R44 from [1 September 2020] via the introduction of new transitional provisions. The purpose is to ensure that further child restraint system approvals are made under the UN R129.

Proposal to introduce chest vertical acceleration (Az) criteria until such time as upper neck tension Force (Fz) and upper neck flexion moment (My) criteria can be established.

35. The expert from GlobalNCAP also introduced GRSP-65-06 proposing limit values for the chest vertical acceleration of Q-dummies during dynamic testing of Enhanced Child Restraint Systems (ECRS). The expert from CLEPA expressed general concern and raised a time reservation. The expert from United Kingdom stated that a permanent solution was needed. He added that this was not the case to implement the chest vertical acceleration but rather to develop the upper neck tension force on the basis of available data. The expert from EC stated that discussion should be deferred until data was available. The expert from CLEPA expressed similar view and suggested collecting support data before the December 2019 session of GRSP. The Chair of GRSP suggested to create a TF led by a representative of a contracting party to coordinate efforts. GRSP agreed, in principle, with the proposal of Chair and agreed to resume discussion at its December 2019 session on the basis of the outcome of above-mentioned TF research. At the same time GRSP requested the secretariat to distribute GRSP-65-06 with an official symbol at its next session.

Proposal to prohibit the granting of new approvals under UN R44 from [1 September 2020] and to amend the transitional provisions accordingly.

20. The expert from IC introduced GRSP-64-32 which explained that for the forthcoming entry into force of “Phase 3” of UN Regulation No. 129 (belted Enhanced Child Restraint Systems (ECRS)), all groups and categories except Group III on forward-facing non-integral CRS would be covered. Accordingly, he explained that belted CRS could be still approved according to UN Regulation No. 44 for an undefined period. He therefore proposed to phase out this category of CRS (ECE/TRANS/WP.29/GRSP/2018/26). The proposal received comments on the transitional provisions and GRSP considered GRSP-64-35-Rev.1. Finally, GRSP adopted ECE/TRANS/WP.29/GRSP/2018/26, as amended by Annex IV to the session report, and requested the secretariat to submit it as Supplement 16 to the 04 series of amendments to UN Regulation No.44, for consideration and vote at the June 2019 sessions of WP.29 and AC.1.

Proposal to require rigid barrier frontal crash testing for commercial use quadricycles (i.e., four-wheeled vehicles with unladen mass not more than 400 kg (550 kg for goods-carrying vehicles), not including the mass of batteries in the case of electric vehicles and whose maximum continuous rated power does not exceed 15 kW).

40. The experts from Global NCAP and from ANEC on behalf of Consumers International introduced GRSP-63-14 which proposes to include L7 (quadricycles) categories of vehicles in the scope of UN Regulation No. 137, in line with the recommendation of the WP.29 (GRSP-63-15 and ECE/TRANS/WP.29/1141, para. 41) aimed at offering a minimum protection to L7 vehicle occupants in case of a crash. They also mentioned GRSP-63-16, for information, concerning the “Public Interest Litigation Regarding Motor Vehicle Safety in India”. They added that quadricycles are not subject to the same legislation as conventional passenger cars and their crashworthiness should be addressed by GRSP as recommended by WP.29. They stressed the risk that consumers buy this type of vehicle to cater to an individual’s need for a car but without being informed about the lack of safety requirements in those vehicles which might expose them to serious injuries in case of a crash. They indicated that NCAP tests showed cases of safety-belts that snapped off and even ineffective airbags and revealing that these types of restraint systems and performance of this type of vehicles were far below similarly-sized passenger car. Moreover, they informed GRSP that L7 vehicles are becoming more popular, also because they are considered as new environmentally friendly mobility solutions and are expected to become more numerous in the future. They clarified that the proposal of Global NCAP and Consumer International to extend the scope of UN Regulation No. 137 to L7 vehicle would be in line with the test speed scenarios and biomechanical injury criteria that provide for the safety of occupants, as in other types of passenger vehicles.

41. The expert from the Republic of Korea was full in support of GRSP-63-14 since his country had recently experienced a surge of this type of vehicles on its roads. The expert from Italy argued that the mass and powertrain of L7 differ from those of M1 and that these factors should be analysed in crash test. The expert from EC reminded GRSP about a European Union study (see ECE/TRANS/WP.29/GRSP/61 para. 31) on an initial assessment of the additional functional safety of this category of vehicles. He explained that the study showed that the low frequency of crashes in Europe of these types of vehicle did not justify an urgent action plan. Moreover, he requested justification on why the L6 category was not included in the proposal. He reminded GRSP about the existence of many UN Regulations covering safety provisions of L7 categories. The expert from Japan agreed with him, however, he requested further investigations. The expert from the Russian Federation agreed with the expert from EC and expressed concern that more severe requirements would eliminate this category of vehicles. The expert from India agreed with a more in-depth investigation on actual safety issues for this category of vehicles and confirmed that these vehicles were becoming relevant in the market of his country. The expert from the Netherlands supported further in-depth study and finding a balanced solution. GRSP decided to resume discussion on this subject at its December 2018 session and to keep GRSP-63-14 as a reference document.

December 2015 notes prepared by Global NCAP in safety awareness following “Safer Cars in India” program.

40. The experts from Global NCAP and from ANEC on behalf of Consumers International introduced GRSP-63-14 which proposes to include L7 (quadricycles) categories of vehicles in the scope of UN Regulation No. 137, in line with the recommendation of the WP.29 (GRSP-63-15 and ECE/TRANS/WP.29/1141, para. 41) aimed at offering a minimum protection to L7 vehicle occupants in case of a crash. They also mentioned GRSP-63-16, for information, concerning the “Public Interest Litigation Regarding Motor Vehicle Safety in India”. They added that quadricycles are not subject to the same legislation as conventional passenger cars and their crashworthiness should be addressed by GRSP as recommended by WP.29. They stressed the risk that consumers buy this type of vehicle to cater to an individual’s need for a car but without being informed about the lack of safety requirements in those vehicles which might expose them to serious injuries in case of a crash. They indicated that NCAP tests showed cases of safety-belts that snapped off and even ineffective airbags and revealing that these types of restraint systems and performance of this type of vehicles were far below similarly-sized passenger car. Moreover, they informed GRSP that L7 vehicles are becoming more popular, also because they are considered as new environmentally friendly mobility solutions and are expected to become more numerous in the future. They clarified that the proposal of Global NCAP and Consumer International to extend the scope of UN Regulation No. 137 to L7 vehicle would be in line with the test speed scenarios and biomechanical injury criteria that provide for the safety of occupants, as in other types of passenger vehicles.

Proposal to cease new approvals of non-integral group 2 and group 2/3 child restraint systems under UN Regulation No. 44 as of [1 September 2019]. This proposal supersedes the previous document GRSP/2017/20.

21. The expert from CI introduced ECE/TRANS/WP.29/GRSP/2017/20 to definitively phase out approvals granted to non-integral group 2 or group 2/3 of child restraint systems (CRS). The expert from CLEPA supported a unique set of provisions in the future (UN Regulation No. 129) to which the CRS manufacturers could refer. However, he introduced the rationales in GRSP-62-18 for an adequate time period to implement this transition sensibly. In response to the presentation of CLEPA the expert from CI stated that the timeline of the withdrawal of group 0, 0+ and 1 integral harness from UN Regulation No. 44 should not precedent the withdrawal of group 2/3 CRS. He explained that a short lead time could apply, as demonstrated by CRS manufacturers in the past and could allow consumers to benefit from a higher standard as soon as possible. However, the expert from France noted that the transitional provisions proposed by ECE/TRANS/WP.29/GRSP/2017/20 cannot be applied from the administrative point of view and proposed a one year delay to cease new type approvals. The expert from the United Kingdom encouraged a compromise to allow the industry to phase out any such provisions from UN Regulation No. 44. Finally, GRSP agreed on the transitional provisions set out GRSP-62-29 and adopted ECE/TRANS/WP.29/GRSP/2017/20 as amended by Annex VI to this report. The secretariat was requested to submit it to the June 2018 sessions of WP.29 and AC.1 as draft Supplement 14 to the 04 series of amendments to UN Regulation No. 44.

Proposal to cease new approvals of non-integral group 2 and group 2/3 child restraint systems under UN Regulation No. 44 as of [1 September 2018].

21. The expert from CI introduced ECE/TRANS/WP.29/GRSP/2017/20 to definitively phase out approvals granted to non-integral group 2 or group 2/3 of child restraint systems (CRS). The expert from CLEPA supported a unique set of provisions in the future (UN Regulation No. 129) to which the CRS manufacturers could refer. However, he introduced the rationales in GRSP-62-18 for an adequate time period to implement this transition sensibly. In response to the presentation of CLEPA the expert from CI stated that the timeline of the withdrawal of group 0, 0+ and 1 integral harness from UN Regulation No. 44 should not precedent the withdrawal of group 2/3 CRS. He explained that a short lead time could apply, as demonstrated by CRS manufacturers in the past and could allow consumers to benefit from a higher standard as soon as possible. However, the expert from France noted that the transitional provisions proposed by ECE/TRANS/WP.29/GRSP/2017/20 cannot be applied from the administrative point of view and proposed a one year delay to cease new type approvals. The expert from the United Kingdom encouraged a compromise to allow the industry to phase out any such provisions from UN Regulation No. 44. Finally, GRSP agreed on the transitional provisions set out GRSP-62-29 and adopted ECE/TRANS/WP.29/GRSP/2017/20 as amended by Annex VI to this report. The secretariat was requested to submit it to the June 2018 sessions of WP.29 and AC.1 as draft Supplement 14 to the 04 series of amendments to UN Regulation No. 44.

Consumers International proposes that no new UN Regulation No. 44 approvals be granted to non-integral group 2 or group 2/3 CRS as of [1 September 2018].

Input concerning use and misuse of traditional CRS, including manufacturer and consumer adaptations and responses that should be avoided through the development of UN R129.

Presentation on child restraint systems that can be integral or non-integral and related labeling/installation issues.

Proposal to strip ISOFIX CRS provisions from UN R44 and to cease all new type approvals for CRS under UN R44 from November 2016 in deference to UN R129 on Enhanced CRS.

35. The expert from CI introduced a presentation (GRSP-58-10) on a proposal (GRSP-58-09) to withdraw ISOFIX CRS from the UN Regulation. He added that the introduction of UN Regulation No. 129 should lead to the discontinuation in production of ISOFIX CRS according to UN Regulation No. 44 because of a lower level of protection offered (i.e. absence of side impact protection). The expert from Germany argued that deleting ISOFIX provisions from the UN Regulation was useless and that this could be simply dealt with in transitional provisions, beyond which date, type approval would no longer be granted to ISOFIX CRS. He added that, at the same time extensions of existing type approvals would be guaranteed in the future. GRSP agreed to resume consideration of a revised proposal at its May 2016 session.

35. The expert from CI introduced a presentation (GRSP-58-10) on a proposal (GRSP-58-09) to withdraw ISOFIX CRS from the UN Regulation. He added that the introduction of UN Regulation No. 129 should lead to the discontinuation in production of ISOFIX CRS according to UN Regulation No. 44 because of a lower level of protection offered (i.e. absence of side impact protection). The expert from Germany argued that deleting ISOFIX provisions from the UN Regulation was useless and that this could be simply dealt with in transitional provisions, beyond which date, type approval would no longer be granted to ISOFIX CRS. He added that, at the same time extensions of existing type approvals would be guaranteed in the future. GRSP agreed to resume consideration of a revised proposal at its May 2016 session.

ANEC considers it undesirable that CRS manufacturers still can develop new products according to R44 for an undefined period. Therefore ANEC propose that no new R44 approvals be granted to Isofix integral CRS as of [9 July 2016], and that transitional provisions be amended accordingly.

Outlook .msg format email from ANEC via the Dutch Consumentenbond. The main issue deals with the implicit exclusion of lateral facing ECRS, although these are mentioned as possibility to transport children up to 15 months. The draft paragraph 6.1.2.3 states that children up to 15 months can be transported in lateral and rearward facing seats, but this is contradicted under a) where is written that ECRS for children up to 15 months shall be rearward facing.

Question and answer brochure on the i-size child restraint systems regulation.

36. The experts from CLEPA and CI introduced respectively GRSP-56-24 and GRSP-56-27, as a draft brochure for a coordinated information campaign on UN Regulation No. 129. The expert from Germany announced that a similar initiative would be published soon in his country. GRSP agreed to resume discussion on this subject on the basis of a possible common text agreed by interested parties.

32. GRSP considered (GRSP-57-04-Rev.2) a draft brochure as part of a coordinated information campaign for UN Regulation No. 129. GRSP noted that the brochure would address different target groups (i.e.: consumers, policy makers, retailers). The expert from CI suggested that the part of the brochure addressing target group such as parents and customers should be shorter and based on the information provided by GRSP-56-27. GRSP noted that the final graphical layout and organization of the contents of the brochure would be finally decided by UNECE secretariat. GRSP in principle endorsed the technical contents of the draft brochure (GRSP-57-04-Rev.2), pending final last comments and information by its experts to be provided to the secretariat by first of June 2015 (close of business).

Summary of assessments for the installation of the Römer Kidfix child restraint system as part of the Euro NCAP Child Occupant Rating for passenger cars.

ANEC/Consumers International (CI) views in response to the CLEPA proposal to allow the use of R44 approved belted infant carriers in combination with an i-size base.

Consumers International statement welcoming the adoption of the new UN Regulation on child restraint systems.

The European Commission received the informal documents WP.29-158-22 and 27 too late to arrange for internal legal approval to enable vote at this session. In any case, France explains that document 22 would benefit from further review, so this document is sent back to GRSP for refinement.

Japan also explains that its proposal to permit acceleration sled testing has been passed by GRSP and so an amendment proposal is pending.

In sum, the new regulation will be voted as it exists in documents WP.29/2012/53 and its corrigendum while the corrigendum in document 22 will pass to the March session. The Japan acceleration sled amendment and a refined version of document 27 will also likely make the March agenda.

Proposal unanimously adopted.