UN R129 Supplement 2 (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 — Supplement 2 to the 04 series of amendments
Supplement 1 → 2
- What changed
- The manufacturer's written declaration on the flammability of materials now refers to section 5.4 of EN 71-2:2020 instead of EN 71-2:2021.
- New paragraph 16.13. covers UN type-approvals to the 04 series. From the official date of entry into force of the 04 series, no Contracting Party applying this Regulation may refuse to grant or accept them.
- Annex 27: for Type Approval Extensions, only the information related to the changes to the ECRS must be provided.
- Why
- The proposal says that the date of EN 71-2 was written as 2021 instead of 2020 by mistake.
- The proposal says that the 04 series does not specify from which date Contracting Parties are obliged to grant or accept 04 series type-approvals.
- The Supplement 8 change to Annex 27 of the 03 series, on type-approval extensions, was missing from the 04 series.
Q1What changed15 changes
Flammability declaration refers to EN 71-2:2020 (para. 6.3.1.2.)
The manufacturer's written declaration on the flammability of materials used to manufacture the Enhanced Child Restraint System now refers to EN 71-2:2020. Before, it referred to EN 71-2:2021. The method of section 5.4 and the maximum rate of spread of flame of 30 mm/s do not change.
New paragraph 16.13. on 04 series approvals; paragraphs 16.14. to 16.16. renumbered
New paragraph 16.13. covers UN type-approvals under this Regulation as amended by the 04 series of amendments. From the official date of entry into force of the 04 series, no Contracting Party applying this Regulation may refuse to grant or accept them. Former paragraphs 16.13. to 16.15. are now paragraphs 16.14. to 16.16.
Annex 27: new title and test reports for Type Approval Extensions
Annex 27 has the new title “List of minimum contents for the test reports included in the type-approval application”. Before, the title was “Type approval test report template”. The annex now lists the minimum content and information for the test reports that are included for a new Type Approval Application. For Type Approval Extensions, only the information related to the changes to the ECRS must be provided.
Annex 27: paragraph numbers and labels in the tables
In one row, paragraph 6.2.1.4. becomes 6.2.1.8., and “Buckle position” becomes “Lap strap position” (when smallest & largest dummies are installed). In the General Requirements table, paragraph 6.3.1.1. is now Toxicity and paragraph 6.3.1.2. is now Flammability. Before, the two labels were the other way round. The Buckle Tests row now shows the paragraph number 6.7.1.7. The row for the lower tether retractor now refers to paragraph 6.7.3.2. instead of paragraph 6.7.3.1. The heading “Dimensions bracket” is now “Dimensions and material specifications bracket”.
Annex 27: Integral and Non-integral ECRS values, and the strap check of paragraph 6.7.4.4.
The rows for paragraphs 6.1.2.5./6.1.3.4. and 6.1.2.6./6.1.3.5. now have separate lines for Integral ECRS and Non-integral ECRS. Under paragraph 6.7.4.4., the strap table now adds “It shall not be possible to pull the complete strap through any adjusters, buckles or anchoring points”. The table also adds the line “Verification photos of the physical check shall be provided”.
Annex 27: top tether connector also used as the lower tether hook (6.3.4.1. and 6.3.4.2.4.)
The top tether connector row now says that the same connector must also be used as the lower tether hook, if applicable. The dimensions row now says that Figure 3(c) shows the engagement dimensions for ISOFIX top tether hooks / lower tether hooks. Before, it named only ISOFIX top tether hooks.
Q2Why it changed
- Proposed by
- Expert from the European Association of Automotive Suppliers
- Working party
- GRSP, 75th session (May 2024)
Reasons
Supplement 9 to the 03 series of amendments updated the reference to EN 71-2. A mistake was made with the date of the standard: it was written as EN 71-2:2021 instead of EN 71-2:2020. The proposal corrects the mistake.
Sources (2)
“Supplement 9 to the 03 series of amendments to UN Regulation No. 129 (ECE/TRANS/WP.29/2023/51) updated the reference to European Standard (EN) 71-2”
“Unfortunately, a mistake was made with the date of the EN standard, which was written as EN 71-2: 2021 instead of EN 71-2:2020. This proposal corrects the mistake.”
The 04 series of amendments does not specify the date from which Contracting Parties are obliged to grant or accept type-approvals to the 04 series. The official date of entry into force may imply this obligation. The proposal states it explicitly, in accordance with the example in the UN Guidelines.
Sources (3)
“However, the 04 series of amendments do not specify the date from which Contracting Parties are obliged to grant or accept type-approvals to the 04 series.”
“Although the official date of entry into force for a new series may imply that Contract Parties are obliged to grant or accept type-approvals, this proposal states this explicitly”
“and in accordance with the example set out in the UN Guidelines.”
Supplement 8 to the 03 series of amendments amended Annex 27 on the minimum content of type-approval test reports. Its purpose was to clarify that, for a type-approval extension, only information related to the changes to the ECRS is required in the report. This change was missing from the 04 series, which appears to have been written from an earlier version of the 03 series. The proposal updates Annex 27 to be consistent with the latest version of the 03 series.
Sources (3)
“amended Annex 27 (minimum content of type-approval test reports) to clarify that only information related to the changes to the Enhanced Child Restraint Systems (ECRS) is required in the report for a type-approval extension”
“However, this change was missing from the 04 series of amendments, which appears to have been written from an earlier version of the 03 series of amendments”
“This proposal updates Annex 27 to be consistent with the latest version of the 03 series of amendments.”
The proposal also corrects some editing mistakes and omissions in Annex 27.
Source
“It also corrects some editing mistakes and omissions in Annex 27.”
Document trail
- 2024-03ProposalECE/TRANS/WP.29/GRSP/2024/11Proposal by the expert from the European Association of Automotive Suppliers
- —Working party adoptsECE/TRANS/WP.29/GRSP/75Session report, para. 24
- 2024-09Sent to WP.29ECE/TRANS/WP.29/2024/138Text that GRSP sent to WP.29 and AC.1
- 2024-11WP.29 adoptsECE/TRANS/WP.29/1181Adopted at the 194th session (session report, para. 158)
- 2025-06-12In forceC.N.331.2025.TREATIES-XI.B.16.129UN depositary notification
Q3Who is affected
Vehicle manufacturer
- No direct action for this role.
Component supplier
- Make sure that your written flammability declaration refers to the method of section 5.4 of EN 71-2:2020.
Technical service / Approval authority
- If you carry out tests to confirm the flammability declaration, use the method of section 5.4 of EN 71-2:2020.
- Update your test report layouts for the changed Annex 27 rows, for example separate Integral ECRS and Non-integral ECRS values.
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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 1
- 04 series — Base text
- 03 series — Supplement 12
- 03 series — Supplement 11
- 03 series — Supplement 10
- 03 series — Supplement 9
- 03 series — Supplement 8
- 03 series — Supplement 7
- 03 series — Supplement 6
- 03 series — Supplement 5