UN R129 Supplement 10 (03 series) · UNECE Regulation No. 129 (ECE R129) — Uniform provisions concerning the approval of Enhanced Child Restraint Systems used on board of motor vehicles (ECRS).
UN R129 — Supplement 10 to the 03 series of amendments
Supplement 9 → 10
- What changed
- A new footnote is added to the words “only one belt route” in items (i) and (j) of paragraph 3.2.2. One belt route applies over the entire stature range, regardless of the different configurations of use for which the ECRS will be approved.
- New paragraph 3.5. says an ECRS must not bear more than one approval number, except when approving a module as part of different ECRSs.
- New paragraph 4.6.4. says that only type-approved belt routings must be indicated on the ECRS, and that they must be green and no other colour.
- Why
- The footnote is added to further clarify the definition of the use of a one belt route.
- Products have been put on the market which do not comply with the principle of the one belt route.
- Paragraph 4.6.4. was proposed for the prevention of green indicators that suggest a belt route outside the remit of the type approval.
Q1What changed8 changes
New footnote on one belt route in items (i) and (j) (para. 3.2.2.)
A new footnote is added to the words “only one belt route” in items (i) and (j) of paragraph 3.2.2. One belt route applies over the entire stature range, regardless of the different configurations of use for which the ECRS will be approved. For an ECRS which allows forward and rearward facing orientation, only the one belt route must be used for both configurations. The same applies for an ECRS which combines integral and non-integral configurations or any other combination that is allowed by this paragraph.
Wording of items (a), (d) and (e) (para. 3.2.2.)
Item (a) of paragraph 3.2.2. now says “an i-Size” where it said “a i-Size”. Items (a) and (e) now say “Enhanced Child Restraint Systems” where they said “Enhanced Child Restraint System”. Item (d) now ends with the word “or”.
One approval number for an ECRS (para. 3.5.)
New paragraph 3.5. says that an ECRS must not bear more than one approval number. This provision does not apply for the purpose of approving a module as part of different ECRSs.
Belt routings indicated on the ECRS (para. 4.6.4.)
New paragraph 4.6.4. says that only type-approved belt routings must be indicated on the ECRS. The type-approved belt routings must be green and no other colour. Belt routings other than the type-approved ones must not be indicated.
Q2Why it changed
- Proposed by
- Expert from the Netherlands; expert from the European Association for the Coordination of Consumer Representation in Standardisation on behalf of Consumers International
- Working party
- GRSP, 73rd session (May 2023)
Reasons
The proposal for paragraph 3.2.2. does not intend to change the requirements nor the level of stringency. The footnote is added to further clarify the definition of the use of a one belt route.
Sources (2)
“The proposed amendment does not intend to change the requirements nor the level of stringency.”
“The footnote to paragraph 3.2.2. is added to further clarify the definition of the use of a one belt route.”
Before this supplement, the text had apparently been interpreted as allowing a single belt route for each application that an ECRS would offer. That way, one belt route for a rearward facing ECRS (integral) and a second for a forward facing (non-integral) ECRS have been introduced.
Sources (2)
“In its current state, the text apparently has been interpreted as to allow the use of a single belt route for each application that an Enhanced Child Restraint System (ECRS) would offer.”
“That way, one belt route for a rearward facing ECRS (integral) and a second belt route for a forward facing (non-integral) ECRS has been introduced”
The single belt route principle was introduced to limit incorrect use of the belt as much as possible. However, products have been put on the market which do not comply with the principle of the one belt route. According to the proposal, the clarification creates a clear and level playing field and prevents the incorrect and possibly unsafe installation of the child restraint.
Sources (3)
“The single belt route principle was introduced to limit incorrect use of the belt as much as possible.”
“Despite all these efforts, products have been put on the market which do not comply with the principle of the one belt route.”
“the clarification herein creates a clear and level playing field, and at the same time, prevents the incorrect and possibly unsafe installation of the child restraint (i.e., misuse).”
GRSP's report says that ECE/TRANS/WP.29/GRSP/2023/11 and GRSP-73-14-Rev.1, which amended it, were introduced to clarify the single belt route principle in paragraph 3.2.2.
Source
“introduced ECE/TRANS/WP.29/GRSP/2023/11 and GRSP-73-14-Rev.1 amending it, to clarify the single belt route principle in paragraph 3.2.2. of the UN Regulation.”
The proposal says that the clause in paragraph 4.6.4. prevents green indicators from suggesting a belt route outside the remit of the type approval. An example is an integral ECRS type approved for statures up to 105 cm that encourages (unauthorised) non-integral use by its green belt route indicators.
Sources (2)
“This additional clause prevents that green indicators suggest a belt route outside the remit of the type approval.”
“For example, an integral ECRS is type approved for statures up to 105cm and encourages the (unauthorised) non-integral use by its green belt route indicators.”
Document trail
- 2023-03ProposalECE/TRANS/WP.29/GRSP/2023/11Proposal by the expert from the Netherlands for paragraph 3.2.2.
- 2023-03ProposalECE/TRANS/WP.29/GRSP/2023/14Proposal for new paragraph 4.6.4.
- —Amended in sessionGRSP-73-14-Rev.1Document amending ECE/TRANS/WP.29/GRSP/2023/11
- —Working party adoptsECE/TRANS/WP.29/GRSP/73Session report, paras. 34 and 35
- 2023-08Sent to WP.29ECE/TRANS/WP.29/2023/120Text that GRSP sent to WP.29 and AC.1
- 2023-10Sent to WP.29ECE/TRANS/WP.29/2023/120/Corr.1Corrigendum to the corner notation
- 2023-11WP.29 adoptsECE/TRANS/WP.29/1175Adopted at the 191st session (session report, para. 180)
- 2024-06-15In forceC.N.258.2024.TREATIES-XI.B.16.129UN depositary notification
Q3Who is affected
Vehicle manufacturer
- No direct action for this role.
Component supplier
- Make sure an ECRS bears at most one approval number, except for a module approved as part of different ECRSs.
- Make sure your ECRS indicates only type-approved belt routings, and that they are green and no other colour.
Technical service / Approval authority
- Check that the ECRS indicates only type-approved belt routings, and that they are green and no other colour.
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ⓘ This report gives advice only. It is not legal or type-approval advice.
More UN R129 change reports
- 05 series — Supplement 1
- 05 series — Base text
- 04 series — Supplement 6
- 04 series — Supplement 5
- 04 series — Supplement 4
- 04 series — Supplement 3
- 04 series — Supplement 2
- 04 series — Supplement 1
- 04 series — Base text
- 03 series — Supplement 12
- 03 series — Supplement 11
- 03 series — Supplement 9
- 03 series — Supplement 8
- 03 series — Supplement 7
- 03 series — Supplement 6
- 03 series — Supplement 5