Are seat rows forward of an emergency exit required to be locked upright and fixed, or is there a distance requirement forward of the overwing exit that permits those seats to recline?
More often than not, when you check seats forward of an emergency exit, they are locked upright. No matter how hard or many times the button is pressed, the recline feature will not work. This restriction is related to the applicable regulation, 14 CFR 25.813 Emergency Exit Access. Please review the regulation relating to seat recline:
The final rule of 14 CFR 25.813 Emergency Exit Access provides clarity to the intent and illustrations to help understand what measurements are made and within what parameters.
It’s not explicitly written that the seats forward of an overwing exit must be prevented from recline, however, it’s required that a specific minimum amount of space be made available. Lockout of a seat then satisfies this requirement.
The language used also seems to be intentional, so should seats forward of an exit row be outside the recline range limit of a seat, the minimum distance would be maintained. For example, I’ve seen aircraft with only business class/first class seats forward of the overwing exit. The seats, if fully reclined, were still more than 20 inches away from the most forward edge of the type III overwing exit. If the language called for the seat forward of the exit be restricted from recline, even though far away, it would have to be locked out. The specific measurements permit for operator discretion and FAA or CAA validation that the exit space clearance is met.
This YouTube video of a 747 door being opened shows what happens when a seat is too close to the emergency exit and reclined.