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UN R129 Supplement 9 (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 9 to the 03 series of amendments

Supplement 8 → 9

Adopted at the WP.29 190th sessionEntry into force 2024-01-05
What changed
  • Forward-facing integral ECRS and non-integral booster seats tested with the Q3 or Q6 dummy now have a DA plane value of 840 mm. For non-integral booster cushions, this value applies with the Q6 dummy.
  • In height, the support leg dimension assessment volume is now limited by a plane 185 mm above the origin for rear-facing ECRS. For forward-facing ECRS, the plane stays at 70 mm above the origin.
  • For forward-facing integral ECRS, the head acceleration criterion is not considered during dummy contact with a rigid test bench part in the rebound phase.
Why
  • The changes to paragraph 6.6.4.4.1.1. are to correct mistakes in the Regulation text and to harmonize the vertical excursion limit for Q3 and Q6 dummies.
  • Increasing the height of the support leg volume would improve the compatibility between the support leg volume and the ISO envelopes.
  • Other proposals aimed to clarify the approach of the production qualification testing phase and to update the references to EN Standards.

Q1What changed31 changes

DA plane value with the Q3 and Q6 dummies (para. 6.6.4.4.1.1.)

For forward-facing integral ECRS, the DA plane value is now 840 mm with the Q3 or Q6 dummy, and 800 mm otherwise. Before, the text gave 800 mm with no exception. For non-integral booster seats, a new provision sets the DA plane value at 840 mm when testing with the Q3 or Q6 dummy. For non-integral booster cushions, a new provision sets the DA plane value at 840 mm when testing with the Q6 dummy.

The value in relation to the DA plane is 800 mm, except when testing with the Q3 or Q6 dummy where the value is 840 mm; and
When testing with the Q3 or Q6 dummy, the following applies:
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Rebound contact with the test bench for integral ECRS (para. 6.6.4.4.1.1.)

For forward-facing integral ECRS, new item (d) covers dummy contact with a rigid part of the test bench in the rebound phase. In that case, the head acceleration criterion during that contact is not considered. Item (c) now ends with “; and”.

In case of dummy contact with a rigid part of the test bench in the rebound phase, the head acceleration criterion during that contact shall not be considered.
However, the head of the dummy may pass beyond the DE plane, if the head pad or the backrest part of the child restraint structure, which is behind the head of the dummy, at the point the head, passes the DE plane.; and

Figure 4 reference and wording (para. 6.6.4.4.1.1.)

The texts for integral ECRS, non-integral booster seats and non-integral booster cushions now refer to Figure 4, not Figure 1. The other changes in this paragraph are to hyphens, punctuation, capital letters and the wording of two sentences.

Forward facing Forward-facing Enhanced Child Restraint Systems
Integral Enhanced Child Restraints: No part of the head of the dummy shall pass beyond the planes BA, DA and DE as defined in Figure 1 4 below:
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Paragraph references in paras. 6.6.4.4.1.1.1. and 7.1.3.6.4.

Paragraph 6.6.4.4.1.1.1. now lists tests conducted in accordance with paragraph 6.6.4.1.6.1.1., 6.6.4.1.6.1.2. or 6.6.4.1.8.2. For these tests, a tolerance of +10 per cent applies to the head excursion value distance between the Cr point and plane AB. Before, the list was paragraph 6.6.4.1.6.2. or paragraph 6.6.4.1.8.2. Paragraph 7.1.3.6.4. now refers to the test in paragraph 6.6.4.1.6.1.1., not paragraph 6.6.4.1.6.2.

Where a test is conducted in accordance with paragraph 6.6.4.1.6.26.6.4.1.6.1.1. or paragraph 6.6.4.1.6.1.2. or paragraph 6.6.4.1.8.2. above, a tolerance of +10 per cent shall be applicable to the head excursion value distance between the Cr point and plane AB.
The test specified in paragraph 6.6.4.1.6.26.6.4.1.6.1.1. above is a requirement only for the largest dummy for which the child restraint is designed.

Support leg dimension assessment volume (para. 6.3.5.1., Annex 19)

Item (c) limits the volume in height by a plane parallel to the X'-Y' plane. This plane is now 70 mm above the origin for forward-facing ECRS or 185 mm above the origin for rear-facing ECRS. In each case, the distance is measured perpendicular to the X'-Y' plane. Before, the text gave one distance: 70 mm above the origin. The limit of 285 mm below the origin for rigid, non-adjustable parts of the support leg does not change. Figures 1 and 2 of Annex 19 now show a forward-facing ECRS and a rearward-facing ECRS.

In height by a plane parallel to the X'-Y' plane, positioned at a distance of 70 mm above the origin for forward-facing ECRS or 185 mm above the origin for rear-facing ECRS and in each case measured perpendicular to the X'-Y' plane. Rigid, non-adjustable parts of the support leg shall not extend beyond a plane parallel to the X'-Y' plane, positioned at a distance of 285 mm below the origin and perpendicular to the X'-Y' plane.
The support leg, including its attachment to the Enhanced child restraint systems and the support-leg foot shall lie completely within the support leg dimension assessment volume (see also Figures figures 1 and 2 of annex 19 of this Regulation), which is defined as follows:
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EN standards for toxicity and flammability (paras. 6.3.1.1. and 6.3.1.2.)

Paragraph 6.3.1.1. now refers to EN 71-3:2019+A1:2021 instead of EN 71-3:2019 for the toxicity declaration. In paragraph 6.3.1.2., the flammability declaration now refers to section 5.4 of EN 71-2:2021 instead of EN 71-2:2011+A1:2014. The maximum rate of spread of flame of 30 mm/s does not change.

The Enhanced Child Restraint System manufacturer shall declare in writing that the toxicity of materials used in the manufacture of restraint systems and accessible to the restrained child is in conformity with the test requirements of EN 71-3:201971-3:2019+A1:2021, for a Category III material as defined in paragraph 4.2. Table 2 and following the test method of paragraph 7.2., specifically paragraph 7.2.2., Table 3, Category III sampling method. Tests confirming the validity of the declaration may be carried out at the discretion of the Technical Service. This paragraph does not apply to non-integral ECRS with a stature range of 100 cm or above.
The Enhanced Child Restraint System manufacturer shall declare in writing that the flammability of materials used to manufacture the Enhanced Child Restraint System is in conformity with the method of section 5.4 of EN 71-2:2011+A1:2014 71-2:2021 with a maximum rate of spread of flame of 30 mm/s. Tests confirming the validity of the declaration may be carried out at the discretion of the Technical Service. Where fabrics are assembled together, these shall be tested as a composite.

Production qualification with ECRS modules (para. 9.2.)

Paragraph 9.2. now says that, where the type approval consists of different modules, product qualification tests will be conducted with each module of the ECRS. The text still says that additional qualifications of production may be prescribed following paragraph 11.4. The title of paragraph 9.2. now ends with a full stop.

The production of each new approved type of Enhanced Child Restraint System shall be subjected to production qualification tests. Additional qualifications Where the type approval consists of production may different modules, product qualification tests will be prescribed following paragraph 11.4conducted with each module of the ECRS.
Additional qualifications of production may be prescribed following paragraph 11.4.
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Q2Why it changed

Proposed by
Expert from the European Association of Automotive Suppliers; expert from Spain, on behalf of the Technical Service Group
Working party
GRSP, 72nd session (December 2022)

Reasons

  • The vertical excursion of 840 mm is already well established for the Q10 in the forward-facing direction and Q3 and Q6 in the rearward-facing direction. Accepting 840 mm for forward-facing Q3 and Q6 dummies would harmonize the vertical excursion requirements for the Q3, Q6 and Q10 dummies. The amendment is not seen to have any negative consequences for the safety level of children. In a sample of vehicles, the minimum vertical distance available from the Cr point was more than 840 mm in all cases.

    Sources (5)
    “Since the vertical excursion of 840 mm is already well established for the Q10 in the forward-facing direction and Q3 and Q6 in the rearward-facing direction”
    “to also accept the vertical excursion of 840 mm for the Q3 and Q6 dummies in the forward-facing direction”
    “This would harmonize the vertical excursion requirements to be consistent in all circumstances for the Q3, Q6 and Q10 dummies.”
    “This amendment is not seen to have any negative consequences for the safety level of children”
    “the minimum vertical distance available from the Cr point in the vehicles was in most vehicles between 880 mm and 960 mm and in all cases more than 840 mm.”
  • The changes are also to correct mistakes in the Regulation text. An instruction line was missing from ECE/TRANS/WP.29/2020/58. Without it, that legal text could be seen as replacing all of paragraph 6.6.4.4.1.1., which would delete the head excursion requirements for integral ECRS. Also, a reference was missing in paragraph 6.6.4.4.1.1.1., and paragraph 7.1.3.6.4. referred to paragraph 6.6.4.1.6.2., which does not exist.

    Sources (5)
    “then submitted to WP.29 as document ECE/TRANS/WP.29/2020/58, Supplement 04 to the 03 Series to UN Regulation No. 129, there was an instruction line and some "….." missing from that document.”
    “the legal text in ECE/TRANS/WP.29/2020/58 could be seen as a replacement of text for the entire of paragraph 6.6.4.4.1.1.”
    “This would lead to the deletion of requirements for head excursion, for integral Enhanced Child Restraints Systems (ECRS).”
    “In paragraph 6.6.4.4.1.1.1., a reference is missing.”
    “Paragraph 6.6.4.1.6.2. does not exist.”
  • The proposal amends the support leg volume to improve its compatibility with the Child Restraint Fixtures used to assess the external dimensions of an ECRS. Increasing the height of the volume would improve the compatibility with the ISO envelopes. This would be particularly useful for large rearward facing CRS designs with support legs.

    Sources (3)
    “to amend the existing support leg volume to improve the compatibility between the support leg volume and the Child Restraint Fixtures used for assessing the external dimensions of an Enhanced Child Restraint System (ECRS).”
    “Increasing the height of the support leg volume would improve the compatibility between the support leg volume and the ISO envelopes.”
    “This would be particularly useful for large rearward facing CRS designs with support legs.”
  • The expert from Spain introduced GRSP-72-01 on behalf of the Technical Service Group, aiming to clarify the approach of the production qualification testing phase. The expert from CLEPA introduced GRSP-72-16 to update the references to EN Standards for toxicity and flammability.

    Sources (2)
    “The expert from Spain introduced GRSP-72-01, on behalf of the Technical Service Group, aiming to clarify the approach of the production qualification testing phase.”
    “the expert from CLEPA introduced GRSP-72-16 to update the references to EN Standards for toxicity and flammability.”
  • Proposer's reason (informal document GRSP-72-16)

    UN Regulation No. 129 requires a declaration of compliance with a dated version of each EN standard for toxicity and flammability. Both versions have recently been revised by CEN, and the versions that UN Regulation No. 129 referred to have been withdrawn. The proposal updates the references to the latest published versions, to avoid administrative burdens during the type-approval process of ECRS.

    Submitted by Expert from the European Association of Automotive Suppliers. Working party adoption: ECE/TRANS/WP.29/GRSP/72, para. 27.

    Sources (3)
    “In each case, a declaration of compliance with a specific (i.e. dated) version of each standard is required.”
    “both versions have recently been revised by CEN and the versions referenced by UN Regulation No. 129 have been withdrawn.”
    “This proposal updates the references to reflect the latest published version of each standard in order to avoid administrative burdens during the type-approval process of ECRS.”

Document trail

  1. 2021-09ProposalECE/TRANS/WP.29/GRSP/2021/26CLEPA proposal for the support leg volume
  2. 2022-09ProposalECE/TRANS/WP.29/GRSP/2022/25CLEPA proposal to correct editing mistakes and harmonize the vertical excursion limit for Q3 and Q6 dummies
  3. —ProposalGRSP-72-01Proposal by the expert from Spain for the production qualification testing phase
  4. —ProposalGRSP-72-16CLEPA proposal to update the references to EN Standards
  5. —Working party adoptsECE/TRANS/WP.29/GRSP/72Session report, paras. 27 to 29
  6. 2023-03Sent to WP.29ECE/TRANS/WP.29/2023/51Text that GRSP sent to WP.29 and AC.1
  7. —Amended in sessionECE/TRANS/WP.29/1173WP.29 session report, para. 98: item (c) of paragraph 6.3.5.1. amended before the AC.1 vote
  8. 2023-06WP.29 adoptsECE/TRANS/WP.29/1173Adopted at the 190th session (session report, para. 165)
  9. 2024-01-05In forceC.N.31.2024.TREATIES-XI.B.16.129UN depositary notification

Q3Who is affected

Vehicle manufacturer

  • No direct action for this role.

Component supplier

  • Update toxicity declarations under paragraph 6.3.1.1. to EN 71-3:2019+A1:2021.
  • Update Method 1 flammability declarations to section 5.4 of EN 71-2:2021.

Technical service / Approval authority

  • Apply the 840 mm DA plane value to forward-facing integral ECRS tested with the Q3 or Q6 dummy.
  • Apply the 840 mm DA plane value to non-integral booster seats tested with the Q3 or Q6 dummy.
  • Apply the 840 mm DA plane value to non-integral booster cushions tested with the Q6 dummy.
  • For forward-facing integral ECRS, ignore the head acceleration criterion during rebound-phase dummy contact with a rigid test bench part.
  • Apply the +10 per cent head excursion tolerance to tests under paragraphs 6.6.4.1.6.1.1., 6.6.4.1.6.1.2. and 6.6.4.1.8.2.
  • Check support legs of rear-facing ECRS against the plane 185 mm above the origin in item (c).

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