11. The expert from OICA introduced ECE/TRANS/WP.29/GRSP/2020/12 to clarify the test procedure for the height of head restraints in the case of vehicles having a low roof construction. He added that the current provisions were design restrictive and that the proposal was addressing only integrated head restraints. However, the expert from Japan expressed the following concerns through a presentation (GRSP-68-31-Rev.1) to the proposal:

1. The range of exempted vehicles addressed exemption applicable to bucket-type seats. However, considerations from the expert from Japan shows that this exemption could be applied to any integrated headrest seat. Therefore, not only sport-vehicles but also vehicles with high hoods and low roofs (e.g., low roof sedans, high and/or long hood vehicles and SUVs) would be exempted at manufacturer’s choice.
2. Safety risk to tall occupants. Specifically, in the case of an occupant taller than the average, the safety level of the occupant in the event of a collision would likely decrease.