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Rear Facing Child Seats for Hong Kong

How important are Rear Facing Child sets for your Model S order in Hong Kong?

  • Never wanted them.

    Votes: 8 23.5%
  • Planned to order. Not bothered that they are not available.

    Votes: 2 5.9%
  • Planned to order. Now seriously inconvenienced that they can't offer them.

    Votes: 19 55.9%
  • An absolute requirement, so will now cancel my reservation.

    Votes: 5 14.7%

  • Total voters
    34
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interesting...there is a Audi station wagon (looks over 12 years old car) in my parking with a rear facing seat (saw there were two kids sitting there couple times). Don't understand why TD doesn't approve Tesla rear facing seat

Can you find out make, model and year (first registration date is on the yearly license in front window). In fact, just a picture of that license in the window and one of the rear seats would be fine.

Thanks.
 
While not a personal car, almost all buses have rear facing seats - with, and without seat belts. In any case, rear facing cars might not be preferred, as passengers usually like to face forward, but they are usually safer. As far as I recall, the NCAP test of the Tesla model S showed that the "+2 seats" was actually the safest place to sit in the car, despite being quite close to the rear.

If it wasn't for people wanting to look in the direction of travel, all airplane seats apart from the pilots seats would be facing rearwards - as it's much safer in most impacts (assuming the vehicle is not moving backwards at impact)


Apparently it's nothing to do with size. It's the REAR facing causing the issue. All approved third row seats are FRONT facing.

(From my friend at BMW Canada. It seems linking to some weird British rules.)
 
Can you find out make, model and year (first registration date is on the yearly license in front window). In fact, just a picture of that license in the window and one of the rear seats would be fine.

Thanks.

Checked tonight, it is a 2001 Audi Allroad and the license on the windshield shows "seating capacity: 6” (so it is a 7 seater)


This thread in this forum also has a picture of the rear seat of this car:
http://www.teslamotorsclub.com/showthread.php/2481-Putting-babies-in-the-trunk
 

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Hi fellows: thanks for the great suggestions. Was anybody able to order the car prepared (reinforced
Bumper) per LuckyLuke's suggestion? I couldn't get it yet, but maybe i should try harder. Comments welcome.

You could ask Tesla to prepare the car (reinforced bumper etc) in their factory anyway but not install the seats before delivery. After delivery you could purchase the seats as part(s) and have a mechanic (or Tesla if they are up to it) mount them in the car.
 
Hi fellows: thanks for the great suggestions. Was anybody able to order the car prepared (reinforced
Bumper) per LuckyLuke's suggestion? I couldn't get it yet, but maybe i should try harder. Comments welcome.

The vehicle registration document would still say driver + 4 passengers, and that would make it illegal to put more than 5 people in the car. Kind of like getting a 5 seater car and adding two seats in the trunk - doesn't make it legal to put passengers in those seats. That said, I'm not actually sure what the law says - just guessing that the registration document listed number of passengers is legally enforceable.

The trick is going to be getting the registration document to say driver + 6 passengers. From my understanding, that needs to be done at the time of first registration and is dependent on type approval. The alternative is to bring in a 7 seater car from the UK and go through type approval yourself (fighting the Transport Department to get the third row child seats approved).
 
I recall that at beginning of last year Tesla had mechanics installing rear-facing seats for some customers in US who didn't get them in original delivery - it was mentioned in one of the internet reviews at the time (the guy was talking about taking the car back to have the rear-facing seats installed). So it is definitely possible to have them installed post-production if Tesla wants to do so (presumably there is some logistics cost to such an alternative).

I had mine installed after taking delivery but my VIN was below the 54xx cutoff so my car came with the reinforcement (the estimate said "crossmember not required" and they said that would have cost another $6000). So it's possible to install them after delivery but it might be very expensive. It might be worth contacting Jerome to see if there's some way to just have the hardware installed in anticipation of the regulations changing in the future.
 
hello! i've been following this thread with great interest as I was very excited about the possibility of a 5+2 car which was more or less the size of a sedan. Very disappointed to find out subsequently that they are not offering this in HK.

In any case, i wanted to chime in on this thread and add to the discussion esp. re. passenger capacity legislation in HK. I note previous threads regarding the Audi All Road (which I don't think is available any more in HK) and the trick to get registration document to say +6 passengers. From researching on the current legislation (umm.. i am a lawyer but in a totally unrelated field), it states under Road Traffic (Construction and Maintenance of Vehicles) Regulations (Cap. 374A), Regulation 27 [Passenger Seating Capacity] that:

(1) No vehicle shall be provided with seating capacity for passengers in excess of the seating capacity for that class of vehicle specified in the Third Schedule.
(2) The seating capacity for passengers in a bus or special purpose vehicle shall be the seating capacity specified in the registration document issued in respect of that vehicle, and no bus or special purpose vehicle shall be provided with seating capacity in excess of the seating capacity so specified.
(3) No seating capacity for passengers shall be provided in an invalid carriage, trailer, tricycle or pedestrian-controlled vehicle.
(4) Subject to regulation 26, every seat in a vehicle shall be secured to the body of the vehicle and shall, except in the case of a bus or light bus, measure at least 380 millimetres from the backrest to the front edge of the seat and 380 millimetres along the back.
(5) In calculating the seating capacity of a vehicle for the purposes of this regulation-

(a) only those seats that are provided in accordance with paragraph (4) or regulation 73, as the case may be, shall be taken into account; and
(b) no account shall be taken of any space on a seat which is less than 380 millimetres.

(Department of Justice: Bilingual Laws Information System| «ß¬F¥q: Âù»yªk¨Ò¸ê®Æ¨t²Î)

I cannot seem to find the exact dimensions of the rear-facing jump-seats and would be grateful if someone could provide such info! But from the specs on Tesla's website for Model S, the rear cargo volume is 744.7 liters (seats up). Not too sure how this translates to millimetres but if we can show that the two rear seats indeed meet 380mmx380mm, we should have the possibility to get Transport Department to get this approved. If however, the rear jump seats don't meet this dimension, it may be a tough battle to get the law changed.

Looking forward to other people chiming in! also, thank you markwj for the work you have put in so far! I really really hope we can get these rear seats approved in HK as this would fit in so well with my family size/plans. (although will need to figure out how to get an EV to charge if I do buy one but that's another issue to be dealt with!)
 
hello...i've been following this thread closely as i was recently informed by a friend regarding the possibility of a sedan-size car but with 7 seats! Was super excited to know about this until subsequently found out that the 2 rear jump seats option is not offered here in hk.

in any case, further to the comments mentioned above especially regarding the Audi all road (which I believe is not currently available anymore), i went to check up on the legislation regarding passenger seating capacity for vehicles in HK in hopes to further our case for the rear seats (yes, i'm a lawyer but do not specialize in traffic laws=P). According to regulation 27 under Road Traffic (Construction and Maintenance of Vehicles) Regulations (Cap. 374A), it states that: I to locate the toto

(1) No vehicle shall be provided with seating capacity for passengers in excess of the seating capacity for that class of vehicle specified in the Third Schedule.
(2) The seating capacity for passengers in a bus or special purpose vehicle shall be the seating capacity specified in the registration document issued in respect of that vehicle, and no bus or special purpose vehicle shall be provided with seating capacity in excess of the seating capacity so specified.
(3) No seating capacity for passengers shall be provided in an invalid carriage, trailer, tricycle or pedestrian-controlled vehicle.
(4) Subject to regulation 26, every seat in a vehicle shall be secured to the body of the vehicle and shall, except in the case of a bus or light bus, measure at least 380 millimetres from the backrest to the front edge of the seat and 380 millimetres along the back.
(5) In calculating the seating capacity of a vehicle for the purposes of this regulation-
(a) only those seats that are provided in accordance with paragraph (4) or regulation 73, as the case may be, shall be taken into account; and
(b) no account shall be taken of any space on a seat which is less than 380 millimetres.

I have so far not been able to locate the exact dimensions of the 2 rear jump seats and would be grateful if someone could help out here. However, from the specs available on Tesla’s website, it does indicate that the rear volume (seats up) is 744 Liters but I am not sure how that translates into millimetres. If we can show that the seats meet the requirements of being 380mmx380mm, we should have a relatively good chance of getting this option allowed. However, if the seat is unfortunately less than this, it may take quite some lobbying in order to get the law changed.

I for one would really want to see the rear seat options be available in HK. Also, want to thank markmj thus far for all the work you have put in to get this started!
 
hello...i've been following this thread closely as i was recently informed by a friend regarding the possibility of a sedan-size car but with 7 seats! Was super excited to know about this until subsequently found out that the 2 rear jump seats option is not offered here in hk.

in any case, further to the comments mentioned above especially regarding the Audi all road (which I believe is not currently available anymore), i went to check up on the legislation regarding passenger seating capacity for vehicles in HK in hopes to further our case for the rear seats (yes, i'm a lawyer but do not specialize in traffic laws=P).

Many thanks. That is very helpful.

That refers explicitly both to what can be considered an acceptable passenger seat (380mm x 380mm) and to the seating capacity listed on the registration document.

It seems to me that so long as the Tesla 3rd row child seats conform to the safety specifications for passenger seats, and meet those dimensional requirements, then they should be considered as passenger seats according to Hong Kong law.

It also seems to me that if the seats are not 380mm x 380mm, then they would be illegal for use in Hong Kong.

I have just posted this:

Size of 3rd row child seats

Hopefully someone in US / Europe can help out.

- - - Updated - - -

(1) No vehicle shall be provided with seating capacity for passengers in excess of the seating capacity for that class of vehicle specified in the Third Schedule.
(2) The seating capacity for passengers in a bus or special purpose vehicle shall be the seating capacity specified in the registration document issued in respect of that vehicle, and no bus or special purpose vehicle shall be provided with seating capacity in excess of the seating capacity so specified.
(3) No seating capacity for passengers shall be provided in an invalid carriage, trailer, tricycle or pedestrian-controlled vehicle.
(4) Subject to regulation 26, every seat in a vehicle shall be secured to the body of the vehicle and shall, except in the case of a bus or light bus, measure at least 380 millimetres from the backrest to the front edge of the seat and 380 millimetres along the back.
(5) In calculating the seating capacity of a vehicle for the purposes of this regulation-
(a) only those seats that are provided in accordance with paragraph (4) or regulation 73, as the case may be, shall be taken into account; and
(b) no account shall be taken of any space on a seat which is less than 380 millimetres.

OK. I've re-read that (and the legislation) a few times. I'm a little confused.

Paragraph (1): The reference to the seating capacity not exceeding the third schedule means a passenger car can have at most 7 passengers (driver + 7). That is what is said in the third schedule.

Paragraph (2): The registration document seating capacity is specified as only applying to buses or special purpose vehicles.

Paragraph (3): Irrelevant to this discussion.

Paragraph (5a): Refers to regulation 73 (which doesn't seem to me to concern private cars) and reinforces paragraph 4.

Paragraph (5b): Merely reinforced paragraph 4.

So, it comes down to Paragraph (4).

My question is: for a private car, where does the passenger capacity listed in the registration document apply? From what I can see, it doesn't. It does seem to be reflected into the insurance schedules (which is a concern).
 
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"To the front edge of the seat" - I wonder how "front" is understood, if the seats are facing backwards. Would that be the front of the car, or the front of the seat?

I am not as much thinking of what the intention of the wording is, but the legal interpretation (or mis-interpretation) of it.
 
just a quick reply to the above.

Paragraph (1) as you pointed out is the key to the seating capacity for private cars (which as you mentioned, referring to the Third Schedule) is 7.

The rest of the regulation refers to what would be considered a proper "seat" in accordance with HK laws which is 380mmx380mm. Any seat which is less than those dimensions would not be considered a seat. The passenger capacity of that particular vehicle will thus only consider seats which meet the regulation up to a maximum of 7 seats.

As to passenger capacity in the registration document, you will need to refer to Reg 21 under Road Traffic (Registration and Licensing of Vehicles) Regulations (Cap 374E) regarding licensing of motor vehicles as well as Schedule 3 under Cap374E which indicates the particulars that need to be included in the registration document (ie. seating capacity).

Hope this helps? Not positive if I am answering your query correctly and forgive me if i mis-interpreted.

Regarding "front edge of the seat", I would think this means front of the actual seat as opposed to front of the car. Especially when taken in context of the specific dimensions provided.
 
Jess_hk, many thanks and very helpful.

All the information is with Tesla now, and it really is up to them and Transport Department. The 380x380mm specification should really help in particular, as that clearly defines the legislative interpretation of what constitutes an acceptable passenger seat. I think the poll here showing 85% of owners would like to order the option helps as well.
 
Sorry guys, but the bottom (pun intended) line is that this isn't gonna happen for Hong Kong any time soon.

The law says:

Every seat in a vehicle shall be secured to the body of the vehicle and shall, except in the case of a bus or light bus, measure at least 380 millimetres from the backrest to the front edge of the seat and 380 millimetres along the back.

and as MikeC helpfully illustrates, the Tesla Model S third row child seats have a depth of about 28cm:

View attachment 43864

To be clear: this isn't Tesla's fault, but a restriction in the transport legislation for Hong Kong. If we want the seats, the law needs to be changed (and that is a long slow process).

Regards, Mark.