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UN R100 Base text (04 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 — 04 series of amendments

Changes from 03 series of amendments (supplement 3)

Adopted at the WP.29 193rd sessionEntry into force 2025-01-10
What changed
  • New paragraph 5.5.1. requires labels, as specified in Annex 10, on M2/N2 and M3/N3 vehicles equipped with a high voltage electric powertrain. This requirement is considered satisfied if the requirement of paragraph 7.1.7. of UN Regulation No. 134 is satisfied (para. 5.5.1.1.).
  • New Annex 10 gives provisions for the label. The label must be weather resistant, at least 110 mm wide and 80 mm high, with layout and symbols to ISO 17840-4:2018.
  • From 1 September 2026, Contracting Parties applying this Regulation need not accept preceding-series type approvals first issued on or after that date (para. 12.6.). From 1 September 2027, they need not accept type approvals issued to the preceding series (para. 12.8.). Paragraph 12.9. makes an exception for 03 series approvals of vehicles/vehicle systems not affected by the 04 series changes.
Why
  • The proposal says that the label will help emergency services to determine how to approach these vehicles in case of a fire.
  • UN Regulations Nos. 67, 110 and 134 already have identification provisions for LPG, CNG/LNG and compressed hydrogen fuelled M2/N2 and M3/N3 vehicles. The proposal seeks consistency with them for the installation of labels.
  • CTIF recommends symbols in line with ISO 17840-4, and the proposal seeks consistency with this standard for the label appearance.

Q1What changed34 changes

Identification labels on electric power trained vehicles (paras. 5.5. to 5.5.2.)

New paragraph 5.5. is about the identification of electric power trained vehicles. On M2/N2 and M3/N3 vehicles equipped with a high voltage electric powertrain, labels must be installed as specified in Annex 10 (para. 5.5.1.). This requirement is considered satisfied if the requirement of paragraph 7.1.7. of UN Regulation No. 134 is satisfied (para. 5.5.1.1.). For hybrid electric vehicles running on diesel or gasoline, the high voltage powertrain is considered the first energy source, independent of REESS capacity (para. 5.5.2.).

Identification of electric power trained vehicles.
On vehicles of the categories M2/N2 and M3/N3, equipped with a high voltage electric powertrain, labels shall be installed as specified in Annex 10.
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Where the labels must be placed (para. 5.5.3.)

The labels must be placed on the front of the vehicle and on its left side as well as its right side. On the sides, they must be placed in the vicinity of a front door, if one is available. If there is no front door available, the label has to be placed on the first third of the vehicle length. In addition, for vehicles of category M2 and M3, a label must be fixed to the rear of the vehicle.

These labels shall be placed on the front of the vehicle and on the left side as well as on the right side of the vehicle; for the side if available in vicinity of a front door. If there is no front door available, the label has to be placed on the first third of the vehicle length.
In addition, for vehicles of category M2 and M3, a label shall be fixed to the rear of the vehicle.

Provisions for the label in new Annex 10

New Annex 10 gives provisions for a label for vehicles of categories M2/N2 and M3/N3 equipped with an electric power train. The label must be weather resistant. The centre zone indicates the first energy source, and the upper zone indicates the second energy source. Layout and symbols must be in accordance with ISO 17840-4:2018. The background must be orange (RGB code 255, 165, 0), with white reflecting border and letters. The label must be at least 110 mm wide and at least 80 mm high.

Provisions for a label for vehicles of categories M2/N2 and M3/N3 equipped with an electric power train.
(Paragraph 5.5.1 to 5.5.3. of this Regulation)
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Acceptance of type approvals to the 04 series and to the preceding series (paras. 12.5. to 12.11.)

From the entry into force of the 04 series, no Contracting Party applying this Regulation may refuse to grant or accept 04 series type approvals. From 1 September 2026, Contracting Parties applying this Regulation need not accept type approvals to the preceding series first issued on or after that date. Until 1 September 2027, they must accept type approvals to the preceding series first issued before 1 September 2026. From 1 September 2027, they need not accept type approvals issued to the preceding series. Notwithstanding paragraph 12.8., they must continue to accept 03 series type approvals for vehicles/vehicle systems not affected by the 04 series changes. Former paragraphs 12.5. and 12.6. are now paragraphs 12.10. and 12.11.

As from the official date of entry into force of the 04 series of amendments, no Contracting Party applying this UN Regulation shall refuse to grant or refuse to accept UN type approvals under this UN Regulation as amended by the 04 series of amendments.
As from 1 September 2026, Contracting Parties applying this UN Regulation shall not be obliged to accept UN type approvals to the preceding series of amendments that were first issued on or after 1 September 2026.
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Arrangements of the approval marks for the 04 series (Annex 2)

In the approval marks of Figures 1 and 2, the approval number is now 042492 instead of 032492. The first two digits now show approval to Regulation No. 100 as amended by the 04 series of amendments, not the 03 series. The approval mark for a vehicle approved to Regulations Nos. 100 and 42 now refers to the 04 series of amendments of Regulation No. 100. The drawings of the approval marks also changed.

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Q2Why it changed

Proposed by
Expert from the Netherlands
Working party
GRSP, 74th session (December 2023)

Reasons

  • The aim is to identify buses and trucks with an electric drivetrain. This identification is to be consistent with the existing regulated identification of LPG, CNG, LNG and compressed hydrogen fuelled trucks and buses. For the installation of labels, the proposal seeks consistency with UN Regulations Nos. 67, 110 and 134.

    Sources (2)
    “identification of buses and trucks equipped with an electric drivetrain which is consistent with already existing regulated identification for Liquified Petroleum Gas (LPG), Compressed Natural Gas (CNG), Liquid Natural Gas (LNG) and Compressed Hydrogen (H2) fuelled trucks and busses.”
    “For the installation of labels, this proposal seeks consistency with UN Regulation Nos. 67, 110 and 134.”
  • The proposal says that the label will help emergency services to determine how to approach these vehicles in case of a fire. This is especially so for the vehicle's REESS, or in case the REESS is damaged, for example due to an accident.

    Source
    “The label will help emergency services to determine how to approach these vehicles in case of a fire, especially the vehicle’s REESS or in case the REESS is damaged due to an accident for example.”
  • CTIF recommends the use of symbols in line with the international standard ISO 17840-4, Part 4 Propulsion energy identification. For the appearance of the label, the proposal seeks consistency with this ISO standard.

    Sources (2)
    “CTIF recommends the use of symbols which are in line with the international standard ISO 17840-4, Part 4 Propulsion energy identification.”
    “For the appearance of the label, this proposal seeks consistency with the above mentioned ISO standard.”
  • The label that paragraph 7.1.7. of UN Regulation No. 134 requires already includes information about electric safety. For this reason, vehicles that satisfy that requirement do not need the additional label.

    Source
    “The label required in paragraph 7.1.7. of UN Regulation 134 already includes information about electric safety, so vehicles which satisfy above requirement do not need an additional label as required by this proposal.”

Document trail

  1. 2023-09ProposalECE/TRANS/WP.29/GRSP/2023/35Proposal by the expert from the Netherlands
  2. —RevisedGRSP-74-38Amendment by the expert from the Netherlands
  3. —Working party adoptsECE/TRANS/WP.29/GRSP/74GRSP session report, para. 23 and Annex V
  4. 2024-03Sent to WP.29ECE/TRANS/WP.29/2024/41Text that GRSP sent to WP.29 and AC.1
  5. 2024-06WP.29 adoptsECE/TRANS/WP.29/1179Adopted at the 193rd session (session report, para. 162)
  6. 2025-01-10In forceC.N.53.2025.TREATIES-XI.B.16.100UN depositary notification

Q3Who is affected

Vehicle manufacturer

  • Install Annex 10 labels on M2/N2 and M3/N3 vehicles with a high voltage electric powertrain, unless paragraph 5.5.1.1. applies.
  • Place labels on the front and on the left and right sides, near a front door if available (para. 5.5.3.).
  • If there is no front door, place the label on the first third of the vehicle length (para. 5.5.3.).
  • For vehicles of category M2 and M3, also fix a label to the rear of the vehicle.
  • Treat the high voltage powertrain of diesel or gasoline hybrid electric vehicles as first energy source, independent of REESS capacity.
  • Check which 03 series approvals cover vehicles/vehicle systems not affected by the 04 series changes (para. 12.9.).

Component supplier

  • If you supply these labels, make sure that they are weather resistant and follow ISO 17840-4:2018 for layout and symbols.
  • Make sure that the labels are at least 110 mm wide and at least 80 mm high (Annex 10).
  • Give the labels an orange background, RGB code 255, 165, 0, with white reflecting border and letters (Annex 10).

Technical service / Approval authority

  • Check labels on M2/N2 and M3/N3 vehicles with a high voltage electric powertrain against Annex 10 (para. 5.5.1.).
  • Check label positions against paragraph 5.5.3., including the rear label on vehicles of category M2 and M3.
  • Where a vehicle satisfies paragraph 7.1.7. of UN Regulation No. 134, treat paragraph 5.5.1. as satisfied (para. 5.5.1.1.).

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ⓘ This report gives advice only. It is not legal or type-approval advice.

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