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. The proposal also further clarifies the text to explicitly prohibit non-integral belt guides and other seating devices offered separately from the child restraint system.

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.

The Russian Approval Authority had concluded that the product brand “Braxx”, type “Smart Kid Belt” approved according to UN Regulation No. 44, approval No. E20 44R-04 4013 granted by Poland on 11 July 2017, cannot be considered as a child restraint system.

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.

Proposal for transitional provisions to phase out UN R44 starting from 1 September 2021. From 1 September 2023, Contracting Parties will not be obliged to accept type approvals issued in accordance with UN R44. Nonetheless, approvals for vehicle specific “built in” or specific vehicle “built in” child restraint systems issued according to the 04 series of amendments will continue to be accepted.