UN R100 Supplement 4 (03 series) · UNECE Regulation No. 100 (ECE R100) — Uniform provisions concerning the approval of vehicles with regard to specific requirements for the electric power train.
UN R100 — Supplement 4 to the 03 series of amendments
Supplement 3 → 4
- What changed
- In paragraphs 1.1. and 1.2., “categories M and N” becomes “categories M, N and O”.
- Parts I and II apply to category O vehicles with batteries charged by an e-axle, including the requirements for the REESS.
- A category O propulsion system must only activate if the trailer is coupled to a towing vehicle and it receives a signal, command or action.
- Why
- The aim is to allow type approval of a driven axle in a trailer or semi-trailer, for example with a propulsion or recuperation system.
- Vehicles of categories O3 and O4 are to be compared in size and use with vehicles of categories N2 and N3.
- Low battery content in a trailer leads to an automatic stop of any support functions, so a warning is not necessary.
Q1What changed30 changes
Vehicles of category O and e-axle batteries in Parts I and II (paras. 1.1., 1.2. and 2.55.)
In paragraphs 1.1. and 1.2., “categories M and N” becomes “categories M, N and O”. Parts I and II apply to category O vehicles with batteries charged by an e-axle, including the requirements for the REESS. Such batteries are considered as REESS even though they may not provide propulsion. New paragraph 2.55. defines an “e-axle” as an axle mounted to a vehicle of category O, generating electrical energy and/or providing electrical propulsion. A new item (c) states that Part I does not cover the high voltage electricity connection between the towing vehicle and the trailer(s).
Trailer load compartment (paras. 2.54., 5.1.1.1. and 5.1.1.2.)
New paragraph 2.54. defines the “trailer load compartment” as the compartment of the trailer described by the bodywork. It is contained by the floor of the loading area and the inner surface of the bodywork. It also includes the inside of the storage equipment, for example a pallet box, if any. High voltage live parts inside the trailer load compartment now need protection degree IPXXD, as inside the passenger compartment or luggage compartment. In areas other than these three compartments, protection degree IPXXB applies.
Vehicles of categories O3 and O4 in protection against direct contact (paras. 5.1.1., 5.1.1.3. and 5.1.1.4.2.)
Paragraphs 5.1.1., 5.1.1.3. and 5.1.1.4.2. now name vehicles of categories O3 and O4 together with N2, N3, M2 and M3. For the 3 m minimum wrap around distance to roof mounted charging devices, the text still names categories M2 and M3, not O3 and O4.
Warnings for vehicles of category O (paras. 5.2.3. and 5.2.4.)
In the event specified in paragraphs 6.13. to 6.15., the trailer of category O must warn the towing vehicle's driver optically and/or audibly. For O3 and O4 vehicles, the trailer may give the towing vehicle a signal for an optical and/or audible warning in the same event. An example is transmission through CAN-Bus according to ISO 11992-2. The warning in the event of low energy content of REESS is not required for vehicles of category O.
Preventing accidental or unintended movement of category O vehicles (paras. 2.1., 5.3.1., 5.3.2. and 5.3.3.)
For category O vehicles, “active driving possible mode” is also the vehicle mode when coupled with a towing vehicle in active driving possible mode. The momentary indication of paragraph 5.3.1. and the signal of paragraph 5.3.2. are now optional for vehicles of category O. A category O propulsion system must only activate if the trailer is coupled to a towing vehicle and it receives a signal, command or action. For category O vehicles, a trailer parking brake must activate automatically while the trailer connector is physically connected to the trailer inlet.
Mechanical shock test pulses for category O vehicles (Annex 9C, para. 3.2.)
Table 1 now applies to M1, N1, O1 and O2 vehicles, and Table 3 now applies to M3, N3, O3 and O4 vehicles. A new footnote covers O1 and O2 vehicles with a maximum design speed limited to 100 km/h. For these vehicles, the Table 2 pulses may be used at the request of the manufacturer. The observation period at the end of the test is now written as “1 hour” instead of “1 h”.
Earth ground connection device for “vehicles” instead of “motor vehicles” (para. 5.1.2.3.)
Paragraph 5.1.2.3. now starts “In the case of vehicles” instead of “In the case of motor vehicles”. The paragraph is about the device for the galvanical connection of the electrical chassis to the earth ground.
Q2Why it changed
- Proposed by
- Expert from the International Association of the Body and Trailer Building Industry (CLCCR)
- Working party
- GRSP, 75th session (May 2024)
Reasons
The aim is to allow type approval of a driven axle in a trailer or semi-trailer, for example with a propulsion or recuperation system. Vehicles with a propulsion that supports the movement of the towing vehicle are intended to use high voltage components, including traction batteries (REESS). For this reason, the scope should include vehicles of category O.
Sources (2)
“to allow the type approval of a driven axle in a trailer or semi-trailer (e.g. with either a propulsion or a recuperation system)”
“Vehicles of category equipped with a propulsion to support the movement of the towing vehicle are intended to use high voltage components including traction batteries (REESS). Therefore the scope should be amended by vehicles of category O.”
The requirements for protection against direct contact have to be considered for vehicles of category O. Vehicles of categories O3 and O4 are to be compared in size and use with vehicles of categories N2 and N3. For this reason, O3 and O4 should comply with the requirements for N2 and N3.
Sources (2)
“The requirements for the Protection against direct contact have to be considered by vehicles of category O.”
“Nevertheless vehicles of category O3 and O4 are to be compared in size and use with vehicles in category N2, N3. Therefore O3 and O4 should comply with the requirements for N2, N3.”
A failure in the REESS of a trailer has different consequences from a failure in the REESS of a motor vehicle. Low battery content in a trailer leads to an automatic stop of any support functions. The trailer then operates as a normal trailer without propulsion. For this reason, a low battery warning is not necessary.
Sources (2)
“In case of a event of failure in REESS of the trailer the consequences are different from the consequences of a failure of REESS in the motor vehicle.”
“Low battery content in the trailers leads to an automatic stop of any support functionalities. This means the trailer operates then a normal trailer without propulsion. Therefore a warning is not necessary.”
Trailers are normally not in the scope of crash test regulations, because they carry no passengers. For this reason, it is recommended to define basic performance pulses for trailers in relation to the trailer category.
Source
“Trailers are normally not in the scope of crash test regulations due to the absence of passengers. Therefore it is recommended to define basic performance pulses for trailers in relation to the category of the trailer.”
Proposer's reason (informal document GRSP-75-01-Rev.3)
The REESS of O1 and O2 vehicles may be tested with the M1 and N1 pulse (Table 1). M1 and N1 vehicles are the most common towing vehicles. With few exceptions, speed limits for a towing vehicle and trailer are lower than for M1 and N1 vehicles alone. For this reason, manufacturers of O1 and O2 vehicles should have the option of the M2 and N2 pulse (Table 2). This option applies if their design speed is limited to 100 km/h.
Submitted by Experts from the International Association of the Body and Trailer Building Industry (CLCCR). Working party adoption: ECE/TRANS/WP.29/GRSP/75, para. 18.
Sources (3)
“REESS on O1/O2 may be tested with the pulse as defined for M1/N1 (Table 1), because they are the most common towing vehicles.”
“Nevertheless, with few exceptions, the speed limits worldwide are lower for the combination of towing vehicle and trailer than those for the M1/N1 vehicles alone.”
“Therefore, an option should be given to the manufacturers of O1/O2 to test their REESS according to the specifications provided for M2/N2 (Table 2), if their design speed is limited to 100 km/h.”
Document trail
- 2022-09ProposalECE/TRANS/WP.29/GRSP/2022/14Earlier proposal by CLCCR
- —RevisedGRSP-75-01-Rev.3Revised proposal by CLCCR that superseded the earlier proposal
- —Working party adoptsECE/TRANS/WP.29/GRSP/75Session report, para. 18
- 2024-08Sent to WP.29ECE/TRANS/WP.29/2024/121Text that GRSP sent to WP.29 and AC.1
- 2024-11WP.29 adoptsECE/TRANS/WP.29/1181Adopted at the 194th session (session report, para. 158)
- 2025-06-12In forceC.N.310.2025.TREATIES-XI.B.16.100UN depositary notification
Q3Who is affected
Vehicle manufacturer
- For category O vehicles with batteries charged by an e-axle, apply Parts I and II, including the REESS requirements.
- Make category O vehicles warn the towing vehicle's driver, optically and/or audibly, in the events of paragraphs 6.13. to 6.15.
- Make the trailer parking brake of category O vehicles activate automatically while the trailer connector is physically connected.
Component supplier
- Make sure trailer propulsion activates only when coupled to a towing vehicle and given a signal, command or action.
- For O3 and O4 vehicles, decide whether to give the towing vehicle a signal for the optical and/or audible warning.
- Give high voltage live parts inside the trailer load compartment the protection degree IPXXD.
Technical service / Approval authority
- Be ready to test vehicles of category O, including batteries charged by an e-axle, under Parts I and II.
- Use the Table 1 pulses for O1 and O2 vehicles and the Table 3 pulses for O3 and O4 vehicles.
- On manufacturer request, use Table 2 pulses for O1 and O2 vehicles with maximum design speed limited to 100 km/h.
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ⓘ This report gives advice only. It is not legal or type-approval advice.