UN R16 Base text (09 series) · UNECE Regulation No. 16 (ECE R16) — Uniform Provisions Concerning the Approval of: Safety-Belts and Restraint Systems, for Occupants of Power-Driven Vehicles.
UN R16 — 09 series of amendments
Changes from 08 series of amendments (supplement 4)
- What changed
- New paragraphs 2.48. to 2.54. define the lower tether anchorage (LTA) and related lower tether terms.
- New paragraphs 8.4.6. to 8.4.6.4. give requirements for the safety-belt reminder connection of removable seats.
- From 1 September 2026, Contracting Parties need not accept UN type approvals to preceding series first issued on or after that date.
- Why
- The proposal aims to introduce definitions and requirements for lower tether anchorages (LTA), but it does not mandate the use of LTAs.
- Some vehicles on the market already have LTAs that do not meet the requirements of the UN Regulation or are not approved as such. For this reason, a new series with transitional provisions is needed.
- A transitional provision of the 07 series referred to a removable seat, but no requirements were given for the safety-belt reminder connection of removable seats.
Q1What changed95 changes
Lower tether anchorages and anti-rotation devices (paras. 2.34. and 2.48. to 2.54.)
New paragraphs 2.48. to 2.54. define the lower tether anchorage (LTA) and the lower tether. They also define the lower tether strap, connector, hook and bracket, and the generic lower tether bracket. An LTA is on the seat track or on or close to the floor, and a lower tether bracket can be attached or is integrated. New item (d) of paragraph 2.34. covers the anti-rotation device for a “specific vehicle” (Enhanced) Child Restraint System. This device may comprise a top tether, a support leg, lower tether strap(s) or any other means capable of limiting the rotation. Items (c) and (e) now refer to “i-Size Enhanced” and “(Enhanced)” Child Restraint Systems.
Information on child restraint systems (Annex 17)
Annex 17, paragraph 1.1. lists what the vehicle manufacturer must indicate for each forward-facing passenger seating position and each specified ISOFIX position. New item (c) in this list is: if the seating position is suitable for child restraint systems equipped with lower tether attachments. Paragraph 1.2. now refers to the “universal” category of UN Regulation No. 44, 04 series of amendments, not Supplement 5 to the 03 series. Paragraph 1.2. also adds the universal categories of UN Regulation No. 129. Positions that the vehicle manufacturer indicates as suitable for universal child restraint systems must now comply with Appendix 5 as well as Appendix 1. Annex 17, Appendix 3 adds item 4: information on lower tether anchorages and/or brackets, and on front seat top tether anchorages usable as LTA.
Approval mark: no Unique Identifier, and 09 series examples (paras. 5.3.5. to 5.3.8., Annex 2)
New paragraph 5.3.5. says that the approval mark prescribed in paragraph 5.3.4. may not be replaced by a Unique Identifier (UI). The UI is the one referred to in Schedule 5 of the 1958 Agreement. Former paragraphs 5.3.5. to 5.3.7. become paragraphs 5.3.6. to 5.3.8. The Annex 2 examples of approval marks now refer to the 09 series of amendments, for example approval number 092439 instead of 082439.
At least Ar belts on forward-facing seats facing built-in child restraint systems (para. 8.1.8., Annex 16)
In M2 and M3 vehicles of all classes, forward-facing seats facing Built-in Child Restraint Systems must have at least Ar seat belts (para. 8.1.8.). Annex 16 adds Note b with the same requirement, and the existing note becomes Note a. Former paragraphs 8.1.8. to 8.1.8.4. become paragraphs 8.1.9. to 8.1.9.4. Former paragraph 8.1.9. becomes paragraph 8.1.10.
Safety-belt reminder connection for removable seats (paras. 8.4.6. to 8.4.6.4.)
New paragraphs 8.4.6. to 8.4.6.4. give requirements for the connection of a safety-belt reminder system for removable seats. For removable seats without manual connection, the connection must be automatic when the seat is installed in the vehicle. For removable seats with manual connection, paragraphs 8.4.6.2.1. to 8.4.6.2.5. require visible connectors, a permanent label and a warning for a misconnected or disconnected connector. The presence or absence of the removable seat must not adversely affect the safety-belt reminder system of other seating positions. The safety-belt reminder system of the removable seats must not give any false indication of belt use, whether the seats are installed or not.
Safety-belt reminder warnings and tests (paras. 8.4.2.1.1., 8.4.4.3., 8.4.4.5., Annex 18)
The figure at the end of paragraph 8.4.2.1.1. is deleted. Paragraph 8.4.4.3. adds “by a deliberate action” to the driver’s option to cancel the first level warning of positions covered by paragraph 8.4.1.2. Paragraph 8.4.4.5. lets the manufacturer choose to activate the second level warning when the safety-belt “is or becomes” unfastened in normal operation. The other conditions of paragraph 8.4.4.5. do not change. In the Annex 18 first level warning test, the agreed alternative method now simulates occupants representing a 5th percentile adult female. Two test items in Annex 18 now refer to the driving conditions in new paragraphs 2.1.2.1. to 2.1.2.3., not 2.1.1.1. to 2.1.1.3.
Transitional provisions of the 09 series (paras. 15.5.7. and 15.6. to 15.6.4.) and R.E.3 references
Paragraph 15.5.7. is deleted. From the official entry into force of the 09 series, no Contracting Party applying this Regulation may refuse to grant or accept 09 series approvals. From 1 September 2026, Contracting Parties need not accept UN type approvals to the preceding series first issued on or after 1 September 2026. Paragraph 15.6.2. covers type-approvals of vehicles, safety-belts and restraint systems to any preceding series first issued before 1 September 2026. Contracting Parties must continue to accept these approvals if the transitional provisions in those previous series foresee this possibility. Contracting Parties may grant type-approvals to any preceding series and must continue to grant extensions of existing approvals to any preceding series.
Q2Why it changed
- Proposed by
- Experts from the Netherlands, Spain, the European Association of Automotive Suppliers (CLEPA) and France
- Working party
- GRSP, 73rd session (May 2023)
Reasons
Together with proposals for UN Regulations Nos. 129 and 145, the Netherlands proposal aims to introduce definitions and requirements for lower tether anchorages (LTA). It 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 informed sufficiently.
Sources (3)
“This proposal, together with simultaneous proposals updating UN Regulation No. 129 and UN Regulation No. 145 aims at:”
“Introducing definitions and requirements for lower tether anchorages;”
“This proposal does not mandate the use of LTAs; but if LTAs are used as anti-rotation device, the requirements shall be unambiguous, and the user shall be informed sufficiently.”
Vehicles are already on the market with LTAs that do not meet the requirements of the UN Regulation or are not approved as such. For this reason, the proposal needs transitional provisions and a new series of amendments. At GRSP, the expert from OICA introduced a document to provide consistency on transitional provisions with other proposals of amendments to the UN Regulation.
Sources (2)
“Since there are vehicles on the market already equipped with LTAs not meeting the requirements of the UN Regulation or approved as such, there is a need to introduce transitional provisions and therefore a new series of amendments.”
“to provide consistency on transitional provisions with other proposals of amendments to the UN Regulation”
For safety-belts, the approval mark carries important information for users, technical inspection, bodybuilders and customs. They must get the correct information in an easy and accessible way. Under Revision 3 of the 1958 Agreement, a Unique Identifier (UI) may replace the approval mark. But a UN Regulation may specify that a UI may not replace the approval number.
Sources (4)
“In the case of the UN Regulation for safety-belts, the approval mark carries important information for users but also for technical inspection, bodybuilders and customs.”
“They must get the correct information in an easy and accessible way that is stipulated in the marking.”
“According to Revision 3 of the 1958 Agreement, the approval mark may be replaced by a Unique Identifier (UI)”
“it is also acknowledged that for UN Regulations it may be specified that the approval number may not be replaced by a Unique Identifier.”
The proposal covers M2 and M3 vehicles of all classes. In these vehicles, an impact between an adult and a child must be prevented when the adult’s forward-facing seat faces a built-in child restraint system. To prevent this impact, a 3-point belt is requested on the adult seating position.
Sources (2)
“For M2 and M3 vehicle of all classes, when an adult seating in a forward-facing seat which faces a built-in Child Restraint system, an impact between the adult and the child shall be prevented.”
“In order to prevent the impact between the occupants a 3-point belt is requested on the adult seating position.”
A transitional provision of the 07 series referred to a removable seat, but no requirements were given for the safety-belt reminder connection of removable seats. The symbol shown in paragraph 8.4.2.1. is the same as the symbol in UN Regulation No. 121, so the information is redundant. For the rear seat rows of M1 and N1 vehicles, it was not clear whether the driver must cancel the first level warning consciously. In the Annex 18 first level warning test, the fourth alternative was a simulation method agreed by the technical service and the approval authority. This alternative was not really clear and could lead to misinterpretation.
Sources (5)
“A reference to a removable seat was introduced in the transitional provision of UN Regulation No. 16, 07 series of amendments, but requirements for the connection of a safety-belt reminder system for removable seats were not provided.”
“The symbol in UN Regulation No. 121 is the same as the symbol shown in paragraph 8.4.2.1. of UN Regulation No. 16. Therefore, the information is redundant.”
“The first level warning of seating positions of the rear seat row(s) of M1 and N1 category vehicles may be cancelled by the driver. However, it is not clear whether that the cancellation must be done consciously or not.”
“The state in which occupants are onboard the vehicle is simulated by an alternative method specified by the vehicle manufacturer as agreed by the technical service and the approval authority.”
“The fourth alternative is not really clear and could lead to misinterpretation.”
Document trail
- 2023-02ProposalECE/TRANS/WP.29/GRSP/2023/3Proposal by Spain on belts for seats facing built-in child restraint systems
- 2023-03ProposalECE/TRANS/WP.29/GRSP/2023/9Proposal by the Netherlands for the 09 series on lower tether anchorages
- 2023-03ProposalECE/TRANS/WP.29/GRSP/2023/15Proposal by CLEPA on the approval mark and the Unique Identifier
- 2023-05ProposalECE/TRANS/WP.29/GRSP/2023/17Proposal by France on safety-belt reminders
- —RevisedGRSP-73-16-Rev.2Netherlands document that supersedes ECE/TRANS/WP.29/GRSP/2023/9
- —Working party adoptsECE/TRANS/WP.29/GRSP/73GRSP session report, paras. 16 to 19 and Annex III
- 2023-08Sent to WP.29ECE/TRANS/WP.29/2023/105Text that GRSP sent to WP.29 and AC.1
- 2023-11WP.29 adoptsECE/TRANS/WP.29/1175Adopted at the 191st session (session report, para. 180)
- 2024-06-15In forceC.N.232.2024.TREATIES-XI.B.16.16UN depositary notification
Q3Who is affected
Vehicle manufacturer
- Fit at least Ar belts to forward-facing seats facing built-in child restraints in M2 and M3 vehicles (para. 8.1.8.).
- For removable seats, check the safety-belt reminder connection against paragraphs 8.4.6. to 8.4.6.4.
- If the driver can cancel the first level warning of paragraph 8.4.1.2. positions, require a deliberate action (para. 8.4.4.3.).
- Review the Annex 17 handbook information: new item (c) covers child restraint systems with lower tether attachments.
- Compare any lower tether anchorages (LTA) of your vehicles with the definitions in paragraphs 2.48. to 2.54.
- Plan new approvals to the 09 series, because of the 1 September 2026 date in paragraph 15.6.1.
Component supplier
- Make sure that the approval mark on your safety-belts is not replaced by a Unique Identifier (UI) (para. 5.3.5.).
- Compare the approval marks for 09 series approvals with the updated examples in Annex 2.
- Compare the lower tether straps, connectors, hooks and brackets that you supply with the definitions in paragraphs 2.50. to 2.54.
- Make sure that the safety-belt reminder of removable seats never falsely shows belt use (para. 8.4.6.4.).
Technical service / Approval authority
- Be ready to grant and accept type approvals to the 09 series from its official entry into force (para. 15.6.).
- Check the first issue date of approvals to preceding series: paragraphs 15.6.1. and 15.6.2. depend on 1 September 2026.
- In Annex 18 tests that refer to paragraphs 2.1.2.1. to 2.1.2.3., use the manufacturer’s choice of these driving conditions.
- Check that removable seats with manual connection have visible connectors, the label and the warnings of paragraphs 8.4.6.2.1. to 8.4.6.2.5.
- For the first level warning test, check that an agreed simulation method represents a 5th percentile adult female.
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ⓘ This report gives advice only. It is not legal or type-approval advice.
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