Child car seats and restraint systems

• UN Regulation No 129 (i-Size)
• UN Regulation No 44 — legacy, withdrawn from sale
• Regulation (EU) 2018/858 — vehicle type approval framework
• Regulation (EU) 2023/988 — GPSR

Who has to appoint one

Manufacturers and sellers placing child restraint systems on the EU market. Unlike most consumer goods this category is not self-declared: the seat must hold a type approval granted by an approval authority after testing by a technical service.

Thresholds and exemptions

None. Every model and every variant must be approved, and unapproved seats may not be sold at all, whatever documentation the seller holds.

What must appear on the label

The orange approval label showing the UN R129 approval number, the approval authority country code, the size range in centimetres, the maximum occupant mass and the category of use. Manufacturer name and address, model, batch and date of manufacture. Instructions permanently attached or stored with the seat.

Marketplace fields

Marketplaces require the approval number and remove seats carrying only foreign approvals such as FMVSS 213 from the United States, which have no validity in the Union.

Documentation you must hold

The type approval certificate, the conformity of production arrangements agreed with the approval authority, technical documentation, dynamic test reports and the instructions for use.

Standards and testing

Dynamic frontal, rear and side impact testing with the specified dummies under UN R129, plus flammability, buckle release force, and material toxicity requirements. Testing is carried out by a designated technical service, not by the manufacturer alone.

Language requirements

Instructions and warnings in the language of each member state where the seat is sold, and this is enforced strictly given the safety consequences of incorrect installation.

When it applies

Approval before placing on the market. Seats approved only under the older UN R44 may no longer be sold in the Union, though families may continue using ones already purchased.

How long records are kept

Approval and production conformity records for the life of the approval and afterwards per national law.

What happens if you do not comply

Prohibition of sale, recall, and criminal exposure where an unapproved seat is implicated in an injury. This is one of the categories where marketplaces act fastest, because the reputational risk is severe.

Who enforces it

National type approval authorities, technical services, market surveillance authorities and customs.

Where the boundary lies

An Article 16 responsible person or an Article 4 economic operator does not substitute for type approval: without the approval the product cannot be placed on the market at all. Accessories sold separately — seat protectors, harness pads, head supports — can interfere with the approved configuration and are treated as unapproved modifications.

Questions we are asked

Our seat is FMVSS certified in the US — can we sell it in the EU?

No. US certification has no effect in the Union. The seat needs a UN R129 approval obtained through an EU approval authority.

Can we sell R44 seats we still have in stock?

No. R44 approvals are no longer valid for placing seats on the market, and marketplaces block them.