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.

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.

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.