UN R100 Supplement 5 (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 5 to the 03 series of amendments
Supplement 4 → 5
- What changed
- New paragraphs 3.4. and 3.5. cover confidential information and put the documentation in two parts.
- If the manufacturer applies condition (a) “to allow egress” of paragraph 6.15.1., the approval communication must contain the remarks.
- New paragraph 2.56. defines “common space”.
- Why
- The measures to protect the intellectual properties of the manufacturer were not yet clearly specified in this Regulation.
- It is necessary to identify the approvals that apply the condition “allow egress”.
- There were different interpretations of “common space” in paragraph 5.2.3.
Q1What changed15 changes
Confidential information and documentation in two parts (paras. 3.4. and 3.5.)
New paragraph 3.4. applies to information shown to be covered by intellectual property rights or to be specific know-how of the manufacturer or their suppliers. They must make available sufficient information for the checks of this Regulation, and this information must be treated on a confidential basis. New paragraph 3.5. puts the documentation in two parts. Part (a) is the formal documentation package, given to the Approval Authority or its Technical Service with the type approval application. Part (b) is additional material that the manufacturer may keep, but must make open for inspection at the time of type approval. Both parts must remain available for at least 10 years after production of the vehicle/REESS type is definitively discontinued.
Advance warning before a thermal propagation hazard (para. 6.15.1. and Annex 1, item 18)
The REESS or vehicle system must give a signal for the advance warning before a hazardous situation in the passenger compartment. The hazard is caused by thermal propagation triggered by an internal short circuit leading to a single cell thermal runaway. The text now gives two conditions for this signal: (a) to allow egress, or (b) 5 minutes. Before, the same two options were in one sentence, without the letters (a) and (b). If the manufacturer applies condition (a), it must give the justification for the egress duration, and the approval communication must contain the remarks. A new item 18 “Remarks:” is in the communication forms of Annex 1, Parts 1 and 2.
Definition of “common space” (para. 2.56.)
New paragraph 2.56. defines “common space”. It is an area on which two or more information functions may be displayed, but not simultaneously. An example of an information function is a symbol.
Test references for electrolyte leakage criteria (c1) and (c2) (para. 6.4.2.3.)
Criterion (c1) for electrolyte leakage now refers to the test of paragraph 6.4.2.1.1., instead of paragraph 6.4.1.1. Criterion (c2) now refers to paragraph 6.4.2.1.2. or paragraph 6.4.2.2., instead of only paragraph 6.4.2.2.
Fire resistance test when the lowest surface of the REESS casing is higher than 1.5 m (para. 6.5.)
The test is not required when the lowest surface of the casing of the REESS is more than 1.5 m above the ground. The test may still be performed in that case at the request of the manufacturer. Before, the text said “at the option of the manufacturer” and used different words for the lowest surface of the REESS.
Q2Why it changed
- Proposed by
- Special Interest Group on Thermal Propagation
- Working party
- GRSP, 76th session (December 2024)
Reasons
UN GTR No. 20 requires the manufacturer to provide technical documentation on aspects such as REESS warnings, low-temperature protection and thermal propagation. This documentation will include the manufacturer's confidential and proprietary information. The measures to protect these intellectual properties were not yet clearly specified in this Regulation. Other regulations, such as UN Regulations Nos. 155 and 156, have provisions to protect the intellectual properties of the manufacturer. For this reason, it is appropriate to include similar provisions in this Regulation.
Sources (4)
“such documentation will include the manufacturer's confidential and proprietary information, where it is indispensable to protect the intellectual properties therein”
“However, the measures to protect such intellectual properties have yet to be clearly specified in this Regulation.”
“this UN GTR includes specific requirements for manufacturer to provide technical documentations that address specific aspects, such as REESS warnings”
“where specific provisions are provided to protect the intellectual properties of the manufacturer. It is considered as appropriate to include similar provisions to this Regulation.”
During the 05 series work, it was agreed to remove the ambiguity in the duration for securing the occupant during thermal propagation. It is then necessary to identify the approvals that apply the condition “allow egress”.
Sources (2)
“it was agreed to eliminate the ambiguity in the duration for securing the occupant in the event of thermal propagation”
“It then becomes necessary to identify the approvals applying such a provision.”
There were different interpretations of “common space” in paragraph 5.2.3. To resolve this issue, a new definition of “common space” is added, based on the definition in UN Regulation No. 121.
Source
“In order to resolve the issue of different interpretations of "common space" in paragraph 5.2.3., a new definition of "common space" is added on the basis of the definition in UN Regulation No. 121.”
The paragraph numbers in paragraph 6.4.2.3. are corrected. Criterion (c1) applies to the vehicle-based dynamic test (6.4.2.1.1.). Criterion (c2) applies to the vehicle-specific component test (6.4.2.1.2.) and the component-based test (6.4.2.2.).
Source
“The paragraph numbers referred to in paragraph 6.4.2.3. (mechanical integrity) are corrected where the criterion (c1) applies to the vehicle-based dynamic test (6.4.2.1.1.), while the criterion (c2) applies to the vehicle-specific component test (6.4.2.1.2.) and the component-based test (6.4.2.2.).”
Proposer's reason (informal document GRSP-76-09)
The editorial change in paragraph 6.5. is to make the description more consistent.
Submitted by Expert from Contracting Parties participating in the SIG Thermal Propagation. Working party adoption: ECE/TRANS/WP.29/GRSP/76, para. 22.
Source
“An editorial change in Paragraph 6.5. aims to improve the consistency of the description.”
Document trail
- 2024-09ProposalECE/TRANS/WP.29/GRSP/2024/22Proposal by the Special Interest Group on Thermal Propagation
- —Amended in sessionGRSP-76-09Amendments to the proposal, adopted with it by GRSP
- —Working party adoptsECE/TRANS/WP.29/GRSP/76Session report, para. 22
- 2024-12Sent to WP.29ECE/TRANS/WP.29/2025/42Text that GRSP sent to WP.29 and AC.1
- 2025-03WP.29 adoptsECE/TRANS/WP.29/1184Adopted at the 195th session (session report, para. 109)
- 2025-09-26In forceC.N.521.2025.TREATIES-XI.B.16.100UN depositary notification
Q3Who is affected
Vehicle manufacturer
- If you apply condition (a) of paragraph 6.15.1., give the justification for the duration required for the egress.
- Give the formal documentation package to the Approval Authority or its Technical Service with the type approval application.
- Keep the material made open for inspection available for at least 10 years after production is definitively discontinued.
Component supplier
- If information is shown to be covered by your intellectual property rights or know-how, give sufficient information for the checks.
Technical service / Approval authority
- Treat information shown to be covered by intellectual property rights or to be specific know-how on a confidential basis.
- Keep the formal documentation package available for at least 10 years after production is definitively discontinued.
- Make sure the communication for the type approval contains the remarks when condition (a) of paragraph 6.15.1. is applied.
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ⓘ This report gives advice only. It is not legal or type-approval advice.