UN R44 Supplement 15 (04 series) · UNECE Regulation No. 44 (ECE R44) — Uniform provisions concerning the approval of restraining devices for child occupants of power-driven vehicles ("Child Restraint Systems").
UN R44 — Supplement 15 to the 04 series of amendments
Supplement 14 → 15
- What changed
- The label of rearward facing restraints must have overall dimensions of at least 120 x 60 mm or the equivalent area.
- Other information on the label must be outside a clearly marked rectangle of at least the required size, except a permitted identification mark.
- Any customised appearance of the prescribed pictogram images is prohibited. The exceptions are the hand with pointing index finger and the open face booklet with letter 'i' on its right page, if clearly recognisable.
- Why
- It has become evident that some vehicle manufacturers add random information to the airbag warning label, to the detriment of child safety.
- It seems that there are diverging interpretations of the pictogram wording and that altered versions are being authorised.
- Clarifications on what is and what is not permitted are deemed necessary to give all those involved the same harmonized basis.
Q1What changed13 changes
Label location and overall dimensions (para. 4.4.)
Paragraph 4.4. now says that the visible inner surface includes the inside surface of a side wing beside the child's head. Before, it said “the side wing beside the child's head”. Rearward facing restraints must have the “shown” label permanently attached, instead of the “following” label. The paragraph no longer says that the information shown is a minimum. The overall dimensions of the label must be at least 120 x 60 mm or the equivalent area. Before, the text gave a label minimum size of 60 x 120 mm.
Information on the label and shape of the pictograms (para. 4.4.)
The layout of the label may differ from the example shown, but the content must meet the precise prescriptions. No other type of information may be on the label unless it is outside a clearly marked rectangle with at least the required overall dimensions. A part number, bar code or similar identification mark not exceeding 8 mm x 35 mm or the equivalent area may be on the label. No deviations in the shape and orientation of the provided pictograms are permitted, and any customised appearance of the prescribed pictogram images is prohibited. The hand with pointing index finger and the open face booklet with letter 'i' on its right page are exceptions, if clearly recognisable as such. Small irregularities concerning line thickness, label imprinting and other relevant production tolerances must be accepted.
Figure A and the pictograms in Figures B and C (para. 4.4.)
New headings name Figure A “Warning label”, and Figures B and C. Figure B is the pictogram according to ISO 2575:2004 - Z.01 that must be used. It must have an outer diameter of at least 38 mm. Figure C is the pictogram depicting airbag deployment danger that must be used. It must measure 40 mm in width and 28 mm in height or proportionally larger.
Q2Why it changed
- Proposed by
- Expert from the European Commission
- Working party
- GRSP, 63rd session (May 2018)
Reasons
It has become evident that some vehicle manufacturers add random information to the airbag warning label, to the detriment of child safety. This dilutes the compulsory information aimed to protect children transported in cars.
Sources (2)
“It has become evident that some vehicle manufacturers are adding random information to the airbag warning label to the detriment of child safety.”
“This dilutes the compulsory information aimed to protect children transported in cars.”
It seems that the wording on pictogram images (‘grouped, exact or larger’) has diverging interpretations. Pictogram images do not appear exactly as prescribed, and it seems that altered versions are being authorised despite the clear rules.
Sources (2)
“Moreover, it seems that there are diverging interpretations on the wording: ‘pictogram images shall be grouped, exact or larger’.”
“Notably, pictogram images do not appear exactly as prescribed by the relevant regulations. It seems that altered versions are being authorised despite the clear rules”
Clarifications on what is and what is not permitted are deemed necessary. Their purpose is to provide the same harmonized basis for all those involved in the development, production and approval process of the warning labels.
Source
“To provide the same harmonized basis for all those involved in the development, production and approval process of the warning labels, clarifications on what is and what is not permitted are deemed necessary.”
Document trail
- 2017-09ProposalECE/TRANS/WP.29/GRSP/2017/27Collective proposal by the expert from the European Commission
- —Amended in sessionGRSP-63-01-Rev.1Changes by the expert from the European Commission to ECE/TRANS/WP.29/GRSP/2017/27
- —Working party adoptsECE/TRANS/WP.29/GRSP/63GRSP session report, para. 42 and Annex X
- 2018-08Sent to WP.29ECE/TRANS/WP.29/2018/131Text that GRSP adopted and sent to WP.29 and AC.1
- 2018-11WP.29 adoptsECE/TRANS/WP.29/1142Adopted at the 176th session (session report, para. 172)
- 2019-05-28In forceC.N.264.2019.TREATIES-XI.B.16.44UN depositary notification
Q3Who is affected
Vehicle manufacturer
- No direct action for this role.
Component supplier
- Keep other information outside the clearly marked rectangle on the label, except a permitted identification mark (para. 4.4.).
- Make sure that pictograms keep the provided shape and orientation, apart from the clearly recognisable hand and booklet exceptions.
- Make sure that the Figure B pictogram has an outer diameter of at least 38 mm.
- Make sure that the Figure C pictogram is 40 mm wide and 28 mm high, or proportionally larger.
Technical service / Approval authority
- Check that other information on the label is outside the clearly marked rectangle, except a permitted identification mark.
- Be ready to accept small irregularities concerning line thickness, label imprinting and other relevant production tolerances.
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ⓘ This report gives advice only. It is not legal or type-approval advice.