It has come to the attention of the Baby Products Association that there remains some confusion in the industry regarding R129 child restraints that are secured in the vehicle by the vehicle’s seat belt. This confusion also appears to exist within one UK Approval Authority and the Association is currently liaising with it to reach the same understanding.
UN R129 is clear that only one belt route can be used on a child restraint, including both integral and non-integral, regardless of any changes of configuration that might be needed as a child grows through the type-approved height range.
This was established in R129 at the time that integral belted child restraints were added to the Regulation.
At the last session of the Working Party on Passive Safety (GRSP), which is responsible for these Regulations , in May 2023, a proposal for Supplement 10 to the 03 series was adopted that further clarifies the requirement for one belt route: https://unece.org/sites/default/files/2023-05/GRSP-73-14r1e.pdf.
A footnote to the existing text was added that states: “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 shall be used for both configurations. The same applies for an ECRS which combines integral and non-integral configurations or any other combination that is allowed by this paragraph.”
A Supplement is a regulatory tool that clarifies the existing requirements. It is not allowed to set new, more stringent requirements and is further evidence of the intentions of the regulators.
The Baby Products Association urges any manufacturer or supplier of R129 child restraints that are secured in the vehicle by the vehicle’s seat belt to ensure that they meet the requirements of R129 as explained above. Retailers are also urged to be vigilant in stocking only those child restraints that meet the requirements of the Regulation.
For more detailed information, including links to the relevant text in the Regulation and GRSP meeting notes, please contact Julie Milne on 0845 456 9570 or at firstname.lastname@example.org.