Japan’s Stance for the R129 Phase 2 43 rd GRSP Informal Group on Child Restraint System 25 th Mar JASIC

 Phase 2 amendment should be implemented after Q10 dummy’s injury criteria are agreed. OR  Until Q10 dummy’s injury criteria are agreed, the scope of Phase 2 should be limited to the CRS size ranges up to 125 cm. Japan’s Stance for R129 Phase2 The following footnote in paragraph to be deleted: For lateral impact, Q6 dummy could be used for a size range up to 135 cm Correction of formal document

Table 6 in paragraph of R129 specifies the dummy used in each dynamic test per CRS size range. Justification Safety evaluation for children whose size exceeds 125 cm cannot be conducted with Q6 dummy. In CRS evaluations for sizes 135 cm or above, safety differences would occur between evaluations that use Q6 dummy (as proposed by the draft amendment) and future evaluations that use Q10 dummy. In the frontal impact test, the target size ranges for evaluation using Q6 dummy are up to 125 cm.

*All booster seats in size range 135 cm or below are high back boosters. CRS size range Frontal Impact High back Q3Q6 Q10 Cushion (over140) Side Impact High back Q3Q6 Q10 Cushion (over140) --- (Reference) CRS Size Ranges for Booster seat and Dummies Used in the Dynamic Tests For boosters with high back in size ranges 130 cm and 135 cm, the degree of difficulty of testing using Q10 dummy is almost the same for both frontal and side impact tests. If Q10 is not used in side impact test for CRS in these ranges, it will be necessary to amend R129

Paragraph 5.3. to be amended (addition of the part in red): 5.3.Notice of approval or of extension or refusal of approval of an Enhanced Child Restraint System pursuant to this Regulation shall be communicated to the Parties to the Agreement which apply this Regulation by means of a form conforming to the model in Annex 1 to this Regulation. If part of the enhanced child restraint system could be used as an infant carrier module and installed as defined in Annex 22, approvals according to this Regulation can only be granted if the infant carrier module complies with the requirements of this annex. Correction of formal document

The provision in red about carrycots in Annex 22 can be deleted when all the CRS types, including the seat belt-secured type in Phase 3, are included in the scope of R129. Currently, amendment is still in Phase 2, and the red part is still necessary. Justification