Smart Kid S.A. comment on the changes to the ECE:44 Regulations
Fig 1. Comparison of test results
Smart Kid Belt, child safety seats and all other restraint systems are governed by the ECE R44-04 regulations, which are developed by the World Forum for Harmonisation of Vehicle Regulations (WP.29) at the United Nations Economic Commission for Europe (UNECE). All changes to the regulations are prepared in the working group called Global Road Safety Partnership (GRSP), whose members are the states parties to the 1958 agreement. Besides the signatories, also representatives of CLEPA (the European Association of Automotive Suppliers) partake in the proceedings of the GRSP working group; one of their goals is to support the EU and the United Nations in shaping legislation that has a bearing on the automotive business.
Fig 2. Objectives of CLEPA – European Association of Automotive Suppliers
Are the child safety seat giants “independent experts”, and should the GRSP working group find their voice credible? Are the amendments proposed by the representatives of particular countries adopted in order to defend their own domestic manufacturers? Can the big business act together against the new, innovative Smart Kid Belt device? Yes! All of these things are happening; yet should it be so from the ethical and professional point of view? Definitely not!
The first attempt at blocking Smart Kid Belt was made in June 2016, when Russia (a UNECE member) proposed amendment 11 to the regulations.
Fig 3. Russia's proposal for amendment 11 to the ECE R44 regulations.
Without any analyses, one sentence was added in order to block the approval of devices such as Smart Kid Belt. However, we had received the approval much earlier, under amendment 10.
Unfortunately, the above amendment, enacted as a result of the activity of child safety seat manufacturers’ lobby, has made it impossible for other innovative solutions – not being a child safety seat – to be launched into the market in the future.
Another attempt was made in December 2019.
"1.2. This Regulation explicitly forbids child restraint systems in the form of belt guides and other sitting devices that are dangerous and can harm children in the event of a vehicle collision, irrespective of any test results obtained in accordance with paragraph 8.”
The competitors proposed and passed amendment 18, which allowed for ignoring test results. (with regard to tests where child safety seats are not even on a par with Smart Kid Belt – whereas tests are the only opportunity to compare the seats with other restraint systems).
After a few months, the European Commission withdrew from introducing the amendment in its entirety.
Why the change of mind? The competitors slyly manipulate amendments related to completely different devices, which have nothing to do with Smart Kid Belt; however, we are still thrown into the same category. A counter-presentation was given to the working group in which all reliable dynamic test results from several different institutes were included; yet it did not elicit any comment. The presentation resulted in the amendment being abandoned by the Commission.
After two unsuccessful attempts at blocking the ECE R44 approval for Smart Kid Belt at the levels of the EU and the UNECE, the competitors went a step further, inventing and creating their own testing world for our device. A Dutch consumer organisation named Consumentenbond used a mysterious test by the ANEC organisation, which is not based on any procedures established for the ECE R44 or iSize (R129) regulations.
Can the results of this test be considered reliable? Definitely not, as they abound in errors and manipulations. 2 different dummies were used in the comparative test – a smaller Q3 dummy (15 kg) for child safety seats and a larger Q6 dummy (22 kg) for Smart Kid Belt.
Fig 4. The Q3 dummy (15 kg) used for child safety seats only.
Fig 5. The Q6 dummy (22kg) used for Smart Kid Belt only.
Why? It was supposed to show greater penetration in the lower part of the dummy; as we know, the bigger and heavier the dummy, the greater the pressure exerted on the belt. All world tests comparing different restraint systems follow one basic principle – the same dummy is used. Modern Q-type dummies make it possible to read a parameter reflecting the pressure in the left and right sides of the abdomen, but this was not the case here. However, we have objective results of tests that comply with the ECE R129 regulations (we have shared them many times), in which pressure exceeding the permissible limit was registered for a classic child safety seat, whereas Smart Kid Belt's excellent result oscillated well below the permissible limit.
Fig 6. Test results according to the ECE R129 regulations showing pressure in the abdominal section.
Another manipulation in the ANEC test was incorrect installation of Smart Kid Belt.
Fig 7. Incorrect installation of Smart Kid Belt on a test dummy.
Fig 8. Correct installation of Smart Kid Belt on a test dummy.
Furthermore, emphasis was placed on demonstrating that the upper part of the belt slides onto the neck when the dummy is fastened with Smart Kid Belt. Again, two different dummies were used – the Q3 dummy for the child safety seat and the Q6 dummy for Smart Kid Belt. The video and photos show that in the case of Smart Kid Belt, the seat belt fits much better, despite the use of a larger dummy. As regards the child safety seat, the belt gets as far as under the armpit of the dummy on the opposite side (not marked with a red circle), thus pressing on the neck very high; this arrangement of the belt gives no chance of walking away unharmed from an accident. The presented child safety seat is very dangerous. We can only guess why the parameters of this test and its results have not been demonstrated.
Again, the results have not been shown; yet Smart Kid Belt is in possession of test reports demonstrating the impact of forces on the chest (as in the case of the abdomen).
Fig 9. The Q3 dummy in a child safety seat.
Fig 10. The Q6 dummy fastened with Smart Kid Belt.
The ANEC organisation fails to show the basic data which would enable a comparative analysis, e.g. the acceleration and deceleration of the test trolley. Without these data, it is impossible to assess what g-forces affect the dummy. And here it is worth asking the following question: Is it the reason why the competitors so much avoid showing test results and create their own testing reality? All child safety seats have EE test reports, but Reg. No. 129 reports are available only for the most expensive ones.
Our mission, besides ensuring safe travel for all children, is to call for a transparent presentation and comparison of the results of dynamic tests of all restraint systems, which large manufacturers of classic child safety seats avoid. Our results hold up and speak for themselves, and the massive attacks by our global competitors show how hard it is for them to come to terms with these results, and how difficult they find it to give up a part of the huge sales market in favour of the single, economical and safe Smart Kid Belt device.
It should be emphasised here that such activities on the part of our competitors as well as the regulatory body – which changes the regulations at the UNECE level in the manner described above – are intended to block not only our device but any potential innovation not being a child safety seat yet fulfilling the same function.
We addressed an enquiry in the form of an official legal letter to ANEC Secretary-General Steven Russell. We wanted to receive an explanation of the origin of the test comparing Smart Kid Belt to a child safety seat. As can be seen in his response in black and white, ANEC distances itself from the test results, explaining that the tests were commissioned by a Dutch consumer organisation. They just duplicate content for which they do not want to take responsibility in any way.
Correspondence with the ANEC Secretary-General clearly shows the gaps and errors, and it makes us realise how powerful the child seat lobby is.
Let us not forget that the legally required ECE R44-04 tests must be performed at authorised institutions, not consumer organisations.