Head Restraint IWG Document: HR-1-4

Comparison of Head Restraint Regulations FMVSS 202

(Current standard, Final Rule, and ECE 17)

Head Restraint U.S. – FMVSS 202 US FMVSS 202 ECE 17 Comments

Component (current) Final Rule
A. Application
1. Vehicles
Front outboard seating Front outboard and rear Front outboard and rear -If HR present in rear
positions in passenger outboard (optional) (optional) seating seat, ECE 17 and 202
cars, MPVs and trucks seating positions in positions in vehicles of Final Rule regulates.
with a GVWR  4536 passenger cars, MPVs categories M1 and N, -ECE 17 regulates rear
kg and trucks with a and of vehicles of center head restraints if
GVWR  4536 kg, with categories M2 and M3, available.
added exclusion for not covered by
seating position adjacent Regulation No. 80
to aisle on buses (more
than 10 seats)
2. Requirements
a. Height
1. Front outboard
A. Fixed At least 700 mm above Increased to 800 mm Same height as FR, but Different seat set-up
H-point as measured above H-point and measured from R-point. and measuring
parallel to the torso measured with a SAE Seat back angle is 25 techniques used.
reference line. J826 manikin. Seat degrees or manufacturer
back angle set at 25 specified. Seat cushion
degrees. Seat cushion at at lowest position
highest position.
B. Adjustable Same as 202-fixed Must achieve a height of Same height as FR, but Different seat set-up
800 mm and cannot be measured from R-point and measuring
adjusted below 750 mm. and at manufacturer’s techniques used.
Measured with a SAE suggested angle or 25
J826 manikin. Seat degrees. Seat cushion in
back angle set at 25 highest position.
degrees. Seat cushion in
highest position.

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Head Restraint U.S. – FMVSS 202 US FMVSS 202
Component (current) Final Rule
a. Height (cont.) (202 Final Rule: Rear head restraint means a rear seat back,
2. Rear outboard or any independently adjustable seat component attached to or
adjacent to a seat back, that has a height equal or greater than
700 mm, in any position of backset and height adjustment.)
A. Fixed Not specified If provided, minimum
height of 750 mm above
H-point. Measured with
SAE J826 Manikin.
B. Adjustable Not specified If provided, no
adjustment below 750
mm from H-point.
Measured with SAE
J826 Manikin.
3. Rear Center
Not specified Not specified
b. Backset
1. Front outboard Not specified Backset limited to a
positions maximum 55 mm as
measured with HRMD.
Head restraint in at any
height adjustment
between 750 and 800
mm, inclusive. Seat
back angle set at 25
degrees. Seat cushion at
highest position.
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Head Restraint IWG Document: HR-1-4
ECE 17 Comments
If provided, same height Different seat set-up
as FR, but measured and measuring
from R-Point techniques used.
If provided, same as FR, Different seat set-up
but measured from R- and measuring
Point techniques used.
If provided, minimum
height of 700 mm above
R-point
No backset specified, Different seat set-up
but there is a general and measuring
requirement for the seat techniques used.
back angle to be set at
manufacturer’s
suggested angle or 25
degrees and the seat
cushion to be in the
lowest position.
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 Head Restraint IWG Document: HR-1-4

Head Restraint U.S. – FMVSS 202 US FMVSS 202 Final ECE 17 Comments
Component (current) Rule
c. Width
1. Front outboard Minimum of 171 mm on Minimum of 170 mm on Minimum of 170 mm US requires wider HRs
single seats and 254 mm single seats (outboard for all seat types. on front outboard seats
on bench seats seats with no seat in with a center seat
between) and 254 mm between them.
on bench seats (outboard
seats with seat in
between).
2. Rear outboard Not specified If provided, minimum of If provided, minimum of
170 mm for all seat 170 mm.
types
d. Height of adjustable head restraint front
surface
Not specified Not specified Minimum height of 100
mm
e. Gaps
1. All outboard Not specified In all positions, gap -In lowest position, gap -ECE 17/25 does not
positions between HR and seat is  25, with no specify load placed on
back and within the HR reference to backset the sphere to measure
is  60 mm. A 165 mm adjustment. Measured gap.
sphere is pressed against along straight line -ECE 17/25 measures
the gap with a load no between HR and seat the gap between the
more than 5 N back. HR in the lowest
-In other positions the position and seat back
gap  60 mm as differently from the
measured with 165 mm gaps in the HR.
dia. sphere. -Larger gaps allowed
-Gaps larger than 60 mm by ECE, but must be
are allowed if they pass tested.
the energy absorption
test.

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 Head Restraint IWG Document: HR-1-4

Head Restraint U.S. – FMVSS 202 US FMVSS 202 ECE 17 Comments

Component (current) Final Rule
f. HR Adjustment Retention Devices (locks)
1. Height Not specified Must maintain height in If adjustable, requires ECE has no downward
highest position and at automatic locking testing requirement.
800 mm and 750 mm system (ECE 17, 5.1.1).
for front and rear seats No downward test
(if HR provided), required.
respectively, while a
downward force is
applied. Seat back is
rigidly constrained.
2. Backset Not specified Under applied rearward Not specified.
moment, while adjusted
to 800mm for front and
750mm for rear (if
provided), HR must
maintain any position of
backset adjustment.
Seat back is rigidly
constrained.
g. Removability
1. Front Not specified Can be removed with Same as 202 FR
deliberate action distinct
from any act necessary
for adjustment.
2. Rear Not specified Can be removed with Same as 202 FR
deliberate action distinct
from any act necessary
for adjustment.

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 Head Restraint IWG Document: HR-1-4

Head Restraint U.S. – FMVSS 202 US FMVSS 202 Final ECE 17 Comments
Component (current) Rule
h. Clearance
Not specified 25 mm clear space If HR provided, 25 mm -In ECE the 25 mm
allowed where rear HRs, clear space allowed gap is measured from
when seat is occupied, where interference with any vehicle structure,
interfere with roofline or vehicle structure. Seat not just roofline or rear
rear window. does not need to be window as in FR.
occupied. Minimum -ECE requires a
height of 700mm must minimum seat height if
be maintained. HR is present. FR
defines a rear HR as
having a height greater
than 700 mm
i. Non-use positions
1. Front Not specified Not allowed Allowed, provided HR
automatically returns to
proper position when
seat is occupied.
2. Rear Not specified Allowed, provided HR Allowed as long as non- US rule defines
automatically returns to use position is “clearly “clearly recognizable”
proper position when recognizable to the as being rotated
seat is occupied or the occupant”. forward or rearward
HR is rotated a 60.
minimum of 60
forward or rearward.
j. Radius of Curvature
Not specified In NPRM, requirement Parts of front and rear of Deleted in FR because
was same as ECE 17. HR shall not exhibit a enforcement outweighs
Requirement was radius of curvature less benefits.
deleted in final rule. than 5 mm. No commenter had
info to support reg.

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Head Restraint U.S. – FMVSS 202 US FMVSS 202 Final ECE 17 Comments
Component (current) Rule
k. Energy Absorption
Not specified Front of HR impacted Similar to FR: Uses Tests in ECE and FR
with head form at pendulum impactor with are functionally
v=24.1 km/h. 3ms same weight and equivalent. Except FR
deceleration of head velocity as linear does not test rear of
form must not exceed impactor. Front and rear HR.
80gs . Impactor is linear of HR tested.
head form with mass of
6.8 kg.
l. Displacement Test Procedures
Load is applied to back Test procedure modified Same load and FR provides a detailed
pan of seat, load is from 202. Seat back and displacement test procedure,
applied to head restraint HR loaded together. requirements as FR. including load hold
after seat load is Moments and times.
removed. 102 mm of displacements same.
displacement allowed Maximum load the
with 373 Nm moment. same, seat back cannot
Load is increased until fail. Use spherical form
890N or seat back fails. to apply load
Use spherical or
cylindrical form to apply
load.
m. Dynamic sled test (optional)
Seat accelerated so the New corridor based on Not specified
pulse falls in a corridor scaled version 208 sled
defined by 2-½ sine test. Target pulse the
waves with amplitudes of same as 202. 50th male
78 m/s2 and 86 m/s2. dummy used in any seat,
Corridor cannot be met. HR adjusted midway
95th male dummy used, between lowest and
max rotation 45. highest position and any
backset position. 12

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max rotation.

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