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UN R129 Base text (04 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 — 04 series of amendments

Changes from 03 series of amendments (supplement 9)

Adopted at the WP.29 191st sessionEntry into force 2024-06-15
What changed
  • New paragraphs 2.63. to 2.63.6. define the lower tether anchorage (LTA) and related lower tether terms.
  • New paragraph 6.3.6. gives lower tether strap specifications for Specific vehicle belted Enhanced Child Restraint Systems.
  • From 1 September 2026, Contracting Parties need not accept UN type-approvals to the preceding series first issued after that date, subject to paragraph 16.15.
Why
  • The proposal aims at introducing definitions and requirements for lower tether anchorages, but it does not mandate the use of LTAs.
  • Vehicles are already on the market with LTAs that do not meet the requirements of the Regulation or are not approved as such. For this reason, a new series of amendments with transitional provisions is needed.
  • The aim of Corrigendum 1 to the 04 series is to correct an inconsistency in the 04 series of amendments.

Q1What changed139 changes

Lower tether definitions and the anti-rotation device (paras. 2.12., 2.14. and 2.63. to 2.63.6.)

New paragraphs 2.63. to 2.63.6. define the lower tether anchorage (LTA) and six related terms, for example “lower tether strap” and “generic lower tether bracket”. A lower tether is a type of anti-rotation device intended to restrict the rearward rotation of a rearward-facing ECRS. In paragraph 2.12., the anti-rotation device consists of a top-tether strap or a support-leg “in the case of i-Size ECRS”. For a “specific vehicle” ECRS, the list of anti-rotation devices now also names lower tether strap(s). In paragraph 2.14., the definition of “tension relieving device” adds the words “or in the lower tether strap(s)” after “the ISOFIX top tether strap”.

"Anti-rotation device" ". Means a device intended to limit the rotation of the Enhanced Child Restraint System during a vehicle impact and in the case of i-Size ECRS consisting of:
An "Anti-rotation device" for a "specific vehicle" Enhanced Child Restraint System may comprise a top tether, a support-leg support leg, lower tether strap(s) or, any other means capable of limiting the rotation.
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Lower tether straps (paras. 6.3.6. to 6.3.6.5.)

New paragraph 6.3.6. gives lower tether strap specifications for Specific vehicle belted Enhanced Child Restraint Systems. The lower tether straps must fulfil the requirements specified in paragraphs 6.7.4.2. to 6.7.4.4. The lower tether strap length must be at least 900 mm, including the lower tether connector. The lower tether strap must have a no-slack indicator, and the device must meet the requirements of paragraph 6.7.2. An automatically locking retractor that fulfils paragraph 6.7.3.1. can replace the provision for adjustment and release of the tension and the no-slack indicator. For the engagement dimensions of lower tether connectors (hook type), paragraph 6.3.6.5. refers to Figure 3 (c) in paragraph 6.3.4.2.4.

Specific vehicle belted Enhanced Child Restraint System lower tether strap specifications.
The lower tether straps shall fulfil the requirements specified in paragraphs 6.7.4.2. to 6.7.4.4.
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Top tether connector, ISOFIX top tether straps and strap breaking load (paras. 6.3.4.1. to 6.3.4.2.4. and 6.7.4.3.2.)

The top tether connector must also be used as the lower tether hook, if applicable (paragraph 6.3.4.1.). New paragraph 6.3.4.2.1. says that the ISOFIX top tether straps must fulfil the requirements specified in paragraphs 6.7.4.2. to 6.7.4.4. Former paragraphs 6.3.4.2.1. to 6.3.4.2.3. are renumbered as paragraphs 6.3.4.2.2. to 6.3.4.2.4. In paragraph 6.3.4.2.3., the no-slack indicator device must now also meet the requirements of paragraph 6.7.2. Figure 3(c) now gives the dimensions of the ISOFIX top tether or lower tether connector (hook type). In paragraph 6.7.4.3.2., the breaking load of not less than 3.6 kN now applies to the restraints of ECRS, instead of i-Size ECRS.

The top tether connector shall be an ISOFIX top tether hook as shown in Figure 3(c), or similar devices that fit within the envelope given by Figure 3(c). The same connector shall also be used as the lower tether hook (if applicable; see paragraph 6.3.6.).
The ISOFIX top tether straps shall fulfil the requirements specified in paragraphs 6.7.4.2. to 6.7.4.4.
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Generic lower tether brackets and Annex 24 attachment information (paras. 6.3.7. to 6.3.8.4., Annex 24)

New paragraph 6.3.7. gives generic lower tether bracket and mounting material specifications, for applications where the vehicle manufacturer provides the generic anchorages. Brackets supplied by the child restraint manufacturer must have mounting instructions, including required torque application, and a note that qualified personnel only may fit them. New paragraph 6.3.8. adds two strength tests at 5,000 ± 100 N for each generic lower tether bracket (Figures 3 (j) and 3 (k)). In Annex 24, paragraph 1 now names lower tether anchorages and UN Regulation No. 145. Annex 24 now requires the manufacturer of the child restraint system to describe how it attaches to different vehicles, for assessment by the Technical Service. The child restraint manufacturer must now provide parts for fitting the generic lower tether brackets (if any), instead of parts for fitting the anchorages.

Generic lower tether bracket and mounting material specifications (for applications where the vehicle manufacturer provides the generic anchorages).
The generic lower tether brackets supplied by the manufacturer of the child restraint, shall be accompanied by mounting instructions including required torque application and a note that this shall be done by qualified personnel only.
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Dynamic tests: support legs, head excursion and lower tether installation (paras. 6.3.5., 6.6.4.4.1.2.1., 7.1.3.5.2.3. and Annex 6, Appendix 2)

Paragraph 6.3.5. now also applies to Specific Vehicle ECRS that are tested on the test bench according to paragraph 6.6.4.1.2.1. Paragraph 6.6.4.4.1.2.1. has a new sentence after the text on tests under paragraphs 6.6.4.1.6.1.1., 6.6.4.1.6.1.2. or 6.6.4.1.8.2. It applies a tolerance of +10 per cent to the head excursion value distance between the Cr point and plane DF. The dummy should not pass beyond the plane HI, parallel to plane DE. In paragraph 7.1.3.5.2.3., if present, the top tether or lower tether must be adjusted to achieve a tension load of 50 ± 5N. If present, lower tether bracket(s) must be mounted on the Annex 6, Appendix 2, Figure 5 positions and installed according to the user manual.

i-Size Enhanced Child Restraint System support-leg and support-leg foot requirementsSupport leg and support leg foot requirements for i-Size ECRS and also for Specific Vehicle ECRS that are tested on the test bench according to paragraph 6.6.4.1.2.1
i-Size Enhanced Child Restraint Systems fitted with These support-legs shall comply in all positions of use (e.g. in case of length adjustable attachment, base, etc. the shortest and longest position) with the geometrical provisions defined in this paragraph and its subparagraphs.
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One belt route, one approval number and markings (paras. 3.2.2., 3.5, 4.6.4. and 4.14.)

Items (i) and (j) of paragraph 3.2.2. now have a footnote on the one belt route. 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. New paragraph 3.5: an ECRS must not bear more than one approval number, except for 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, in green and no other colour. In paragraph 4.14., item (c) now also names lower tethers and requires one or more of the following symbols as appropriate, instead of one.

Application for a an i-Size Enhanced Child Restraint SystemSystems; or
Application for a specific vehicle booster seat Enhanced Child Restraint System; or
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Approvals to the preceding series, approval numbers and test report contents (paras. 5.2. and 16.13. to 16.15., Annexes 2 and 27)

From 1 September 2026, Contracting Parties need not accept UN type-approvals to the preceding series first issued after 1 September 2026 (paragraph 16.13.). From 1 September 2027, they need not accept type-approvals issued to the preceding series of amendments (paragraph 16.14.). But Contracting Parties must continue to accept, and grant extensions to, approvals to the preceding series for ECRS not affected by the 04 series changes. The first two digits of the approval number are now 04 (paragraph 5.2.), and the Annex 2 examples now show 042439 and 042450. Annex 27 has new test report rows for paragraphs 6.3.4.2.1. and 6.3.6. to 6.3.8. The Annex 27 introduction no longer says that, for Type Approval Extensions, only the information related to the changes to the ECRS must be provided.

An approval number shall be assigned to each type approved. Its first two digits (at present 03 04 corresponding to the 03 04 series of amendments) shall indicate the series of amendments incorporating the most recent major technical amendments made to this Regulation at the time of issue of the approval. The same Contracting Party shall not assign the same number to another type of Enhanced Child Restraint System covered by this Regulation.
As from 1 September 2026, Contracting Parties applying this Regulation shall not be obliged to accept UN type-approvals to the preceding series of amendments, first issued after 1 September 2026.
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Q2Why it changed

Proposed by
Expert from the Netherlands, and 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

  • Together with proposals for UN Regulations Nos. 16 and 145, the proposal aims at introducing definitions and requirements for lower tether anchorages. It also aims at only facilitating attachment by means of the ISOFIX top tether connector. It aims at not allowing other constructions whereby straps around vehicle seats or seat rails are used. The proposal does not mandate the use of LTAs. But if LTAs are used as an anti-rotation device, the requirements must be unambiguous, and the user must be sufficiently informed.

    Sources (5)
    “This proposal, together with simultaneous proposals updating UN Regulation No. 16 and UN Regulation No. 145 aims at:”
    “Introducing definitions and requirements for lower tether anchorages;”
    “Only facilitating attachment by means of the ISOFIX top tether connector;”
    “not allowing other constructions whereby straps around vehicle seats, straps around seat rails, etc. are used.”
    “This proposal does not mandate the use of LTAs; but if LTAs are used as an anti-rotation device, the requirements shall be unambiguous, and the user shall be sufficiently informed.”
  • The lower tether straps are relevant to stop the rotation in a rear impact. For this reason, plane DF can be passed with an additional 10 per cent. A new plane HI, parallel to plane DE, is defined to make the assessment of the passage of plane DE well defined.

    Sources (2)
    “Since the lower tether straps are relevant to stop the rotation in a rear impact, the relevant plane DF can be passed with an additional 10 per cent”
    “For the passage of plane DE, a new plane HI parallel to plane DE is defined, to make the assessment well defined.”
  • Vehicles are already on the market with LTAs that do not meet the requirements of the Regulation or are not approved as such. For this reason, transitional provisions and therefore a new series of amendments are needed.

    Source
    “Since there are vehicles on the market already equipped with LTAs not meeting the requirements of the Regulation or approved as such, there is a need to introduce transitional provisions and therefore a new series of Amendments.”
  • The experts from the Kingdom of the Netherlands and Sweden tabled GRSP-75-22-Rev.1 to correct an inconsistency in the 04 series of amendments.

    Source
    “GRSP considered GRSP-75-22-Rev.1 tabled by the experts from the Kingdom of the Netherlands and Sweden to correct an inconsistency in the 04 Series of Amendments to UN Regulation No. 129.”
  • Proposer's reason (informal document GRSP-75-22-Rev.1)

    All anchorages should fulfil the requirement for two adjacent CRS positions. This is because there is no way to see whether a generic anchorage is approved as a single or as a dual anchorage. The proposal is made as a corrigendum. The aim is that, from the application of the 04 series, all generic lower tether brackets are approved to meet the dual anchorage requirements. The corrigendum is only relevant for the generic bracket and does not affect UN Regulation No. 145.

    Submitted by Experts from Sweden and the Netherlands. Working party adoption: ECE/TRANS/WP.29/GRSP/75, para. 25.

    Sources (3)
    “All anchorages should fulfil the requirement for two adjacent CRS positions – since there is no way to see whether the generic anchorage is approved for application as single anchorage or as dual anchorage.”
    “The proposal is made as a Corrigendum, to make sure that all generic lower tether brackets will be approved from the application of the 04 series of Amendments, to meet the requirements as a dual anchorage.”
    “This Corrigendum is only relevant for the generic bracket and therefore does not affect UN Regulation No. 145.”

Document trail

  1. 2023-03ProposalECE/TRANS/WP.29/GRSP/2023/11Proposal by the expert from the Netherlands to clarify the single belt route principle
  2. 2023-03ProposalECE/TRANS/WP.29/GRSP/2023/13Proposal by the expert from the Netherlands for the 04 series, on lower tether anchorages
  3. 2023-03ProposalECE/TRANS/WP.29/GRSP/2023/14Proposal by the expert from ANEC on behalf of Consumers International, on green belt route indicators
  4. —Working party adoptsECE/TRANS/WP.29/GRSP/73Session report, paras. 33 to 35
  5. 2023-08Sent to WP.29ECE/TRANS/WP.29/2023/109Text that GRSP sent to WP.29 and AC.1
  6. —ProposalGRSP-75-22-Rev.1Proposal by the experts from Sweden and the Netherlands for a corrigendum to paragraph 6.3.8.1.
  7. —Working party adoptsECE/TRANS/WP.29/GRSP/75Session report, para. 25: GRSP adopted GRSP-75-22-Rev.1
  8. 2024-08Sent to WP.29ECE/TRANS/WP.29/2024/151Corrigendum 1 to the 04 series on paragraph 6.3.8.1., sent by GRSP to WP.29 and AC.1
  9. 2023-11WP.29 adoptsECE/TRANS/WP.29/1175Adopted at the 191st session (session report, para. 180)
  10. 2024-06-15In forceC.N.257.2024.TREATIES-XI.B.16.129UN depositary notification

Q3Who is affected

Vehicle manufacturer

  • For Specific vehicle belted ECRS, make sure lower tether straps are at least 900 mm long, including the connector.
  • Use the same connector as the top tether connector for the lower tether hook, if applicable.
  • Show only type-approved belt routings on the ECRS, in green and no other colour.
  • Apply for not more than one approval number per ECRS, except for approving a module as part of different ECRSs.
  • For Specific vehicle Belted ECRS, consult the vehicle manufacturer's information before you include a vehicle type in the vehicle list.
  • Check your approvals to the preceding series of amendments against paragraphs 16.13. to 16.15.

Component supplier

  • For Specific vehicle belted ECRS, make sure lower tether straps fulfil paragraphs 6.7.4.2. to 6.7.4.4.
  • Make sure that ISOFIX top tether straps fulfil paragraphs 6.7.4.2. to 6.7.4.4.
  • After special conditioning, make sure the breaking load is at least 3.6 kN for ECRS restraints, not only i-Size ones.

Technical service / Approval authority

  • When you test ECRS with lower tether(s), place the floor in its lowest position.
  • Use LTA 4 when the top tether anchorage from the seat in front is used; otherwise LTA 2 and 3.
  • Use the generic lower tether brackets in the dynamic test when the CRS manufacturer provides them.
  • Mount lower tether brackets, if present, on the Annex 6, Appendix 2, Figure 5 positions, following the user manual.
  • Perform the two strength tests of paragraph 6.3.8.2. on each generic lower tether bracket.

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ⓘ This report gives advice only. It is not legal or type-approval advice.

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