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UN R100 Base text (05 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 — 05 series of amendments

Changes from 04 series of amendments (supplement 1)

Adopted at the WP.29 195th sessionEntry into force 2025-09-26
What changed
  • Thermal propagation safety is shown by physical testing to new Annex 9K or by risk management analysis. Risk management analysis is used when physical testing is deemed not possible without compromising the REESS safety design. A REESS designed to be charged only by an on-vehicle energy source, up to 2 kWh (Ah × nominal voltage), needs only risk management analysis.
  • The thermal propagation requirements of paragraph 6.15. now apply to a REESS containing flammable electrolyte or alkali metal anodes. They do not apply to REESS solely installed on category O vehicles, nor to batteries on category O vehicles used for recuperation only.
  • From 1 September 2029, Contracting Parties applying this Regulation are not obliged to accept approvals to any preceding series, except under paragraphs 13.4.5. and 13.4.6.
Why
  • Thermal runaway in a single cell may propagate to the surrounding cells, and the smoke, fire and explosion threaten the safety of occupants.
  • Because of considerable divergence in how different Technical Services applied the existing documentation requirement, among other reasons, a test procedure needs to be provided.
  • The requirements also apply to REESS containing alkali metal anodes, taking into account relevant field data.

Q1What changed396 changes

Alkali metal anodes, common space and the scope of thermal propagation (paragraphs 2.56., 2.57., 6.4.2.3., 6.5., 6.12.3. and 6.15.)

New paragraph 2.57. defines “alkali metal anodes” as negative electrodes of the battery cells which are based on lithium, sodium, or potassium. The thermal propagation requirements of paragraph 6.15. now apply to a REESS containing flammable electrolyte or alkali metal anodes. Paragraph 6.15. does not apply to REESS solely installed on category O vehicles, nor to batteries on category O vehicles used for recuperation only. For REESS other than open-type traction battery, paragraph 6.12.3. adds paragraph 6.15. on thermal propagation to its list of tests. New paragraph 2.56. defines “common space” as an area on which two or more information functions may be displayed but not simultaneously. In paragraph 6.4.2.3., item (c1) now refers to paragraph 6.4.2.1.1., and item (c2) to paragraph 6.4.2.1.2. or paragraph 6.4.2.2.

"Common space" means an area on which two or more information functions (e.g. symbol) may be displayed but not simultaneously.
"Alkali metal anodes" means negative electrodes of the battery cells which are based on lithium, sodium, or potassium, e.g. alkali metal foils (stand alone or supported on a current collector) and alkali metals encapsulated in host structure(s).
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Warning signal in the event of thermal propagation (paragraphs 6.15.1. to 6.15.2.)

Paragraph 6.15.1. covers a thermal propagation triggered by an internal short circuit leading to a single cell thermal runaway. In this event, the REESS or vehicle system must give a signal to activate the warning of paragraph 5.2.3., to allow egress. This requirement is deemed to be met if one of the conditions in items (a), (b) and (c) is satisfied. Under item (a), no hazardous situation, as defined by the pass/fail criteria in paragraph 6.15.3.4., occurs within 5 minutes following the warning signal. In case of conditions (b) or (c), the warning indication is not mandatory. Paragraph 6.15.2. now says “in the cell, REESS or vehicle” instead of “in the cell or REESS”.

The REESS or vehicle system shall have functions or characteristics provide a signal to activate the warning specified in paragraph 5.2.3. in the cell or REESS intended to protect vehicle occupants (as described in paragraph 6.15.) in conditions caused by event of a thermal propagation which is triggered by an internal short circuit leading to a single cell thermal runaway. REESS or vehicle manufacturers shall make available, at the request in order to allow egress. This requirement is deemed to be met if one of the Technical Service with its necessity, the following documentation explaining safety performance of the system level or sub-system level of the vehiclebelow conditions is satisfied:
A system diagram of all relevant physical systems and components. Relevant systems and components are those which contribute to protection of vehicle occupants from hazardous effects caused by thermal propagation triggered by a single cell thermal runaway.the presence of a hazardous situation as defined by pass/fail criteria in paragraph 6.15.3.4. does not occur within 5 minutes following the warning signal; or
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Verification process of thermal propagation safety compliance (paragraphs 6.15.3. to 6.15.3.4.2.)

Conformance is shown by physical testing, or by risk management analysis when physical testing is deemed not possible without compromising the REESS safety design. The Type Approval Authority and the Technical Service determine this with the help of documentation provided by the manufacturer. A REESS designed to be charged only by an on-vehicle energy source, up to 2 kWh (Ah × nominal voltage), needs only risk management analysis. For the trigger method, the Technical Service considers localized fast external heating first. Physical test pass criteria: for 5 minutes after the warning signal, thermal propagation must not cause fire, explosion or smoke release into the passenger compartment. If no thermal propagation is observed during the 2 hours after thermal runaway was triggered in the initiation cell, the pass criteria are deemed met.

The verification process of thermal propagation safety compliance
Recognizing that there are different REESS and vehicle designs on the market, and to ensure the technical neutrality of this requirement, the verification of thermal propagation safety compliance follows a multistep approach described in paragraphs 6.15.3.1. to 6.15.3.4.
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Documentation for approval and the risk management analysis method (paragraphs 3.4., 3.5. and 6.15.4.)

If applicable or required under paragraph 6.15.3., the manufacturer must perform and document a risk assessment. It considers occupant protection in normal operating conditions as defined in paragraph 2.31. The manufacturer must make available a high-level report in four parts, for paragraphs 6.15.4.1. to 6.15.4.4., to the Type Approval Authority and Technical Service. Footnote 4 is now on paragraph 6.15.4.4. and says that the manufacturer will be accountable for the verity and integrity of the documentation. Where information is shown to be covered by intellectual property rights or to be specific know-how, paragraph 3.4. requires sufficient information for the correct verifications. Under paragraph 3.5., the formal documentation package and material available for inspection must remain available for at least 10 years after production is definitively discontinued.

In cases where information is shown to be covered by intellectual property rights or to constitute specific know-how of the manufacturer or of their suppliers, the manufacturer or their suppliers shall make available sufficient information to enable the correct verifications referred to in this Regulation. Such information shall be treated on a confidential basis.
Documentation shall be made available in two parts:
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New Annex 9K: thermal propagation test and four thermal runaway trigger methods (Appendices 1 to 4)

New Annex 9K gives the thermal propagation test. Its purpose is occupant safety in a vehicle when a forced thermal runaway of a cell in the REESS is triggered. The manufacturer chooses, in agreement with the Technical Service, a test with a complete vehicle, the complete REESS or REESS subsystem(s). Appendices 1 to 4 describe four trigger methods: a localized rapid external heater, an internal heater, nail penetration and a laser-based trigger. The trigger method must not affect the adjacent cell(s). Each appendix gives a test procedure for the vehicle-based test and for the component-based test.

Thermal propagation test
Thermal runaway trigger method with a localized rapid external heater
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Part III: installation of an approved REESS for a vehicle approval, and new paragraph numbers (paragraphs 1.3., 4.2., 5.2.1., 5.2.2., 6.16., 7. to 12. and Annex 1)

New Part III (paragraph 7.) gives the requirements for the installation of an approved REESS for the purpose of a vehicle approval. New paragraph 5.2.2.2. says that smoke caused by thermal propagation must not be released into the passenger compartment. A design review of the intended venting strategy of the REESS and its installation verifies this requirement. New paragraph 6.16. requires that the REESS and vehicle are compatible with regard to their communication. Former paragraphs 7. to 11. are now paragraphs 8. to 12. Two RegVault Notes explain references that the 05 series did not amend after it renumbered or deleted paragraphs; the official text is reproduced as printed.

Part III: Requirements with respect to the installation of an approved Rechargeable Electrical Energy Storage System (REESS) to the road vehicles of categories M, N and O equipped with electric power train, excluding vehicles permanently connected to the grid.
Notice of approval or of refusal or of extension or withdrawal of approval or production definitively discontinued of a vehicle type pursuant to this Regulation shall be communicated to the Parties to the Agreement applying this Regulation, by means of a form conforming to the model in Annex 1, Part 1 (for approval of type of vehicle according to Part I or Part III of this Regulation) or Part 2 (for approval of type of REESS according to Part II of this Regulation) as appropriate to this Regulation.
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Transitional provisions and approval marks (paragraph 13. and Annex 2)

From 1 September 2027, Contracting Parties applying this Regulation are not obliged to accept type approvals to any preceding series first issued after that date. Until 1 September 2029, they must accept type approvals to any preceding series first issued before 1 September 2027, if their transitional provisions foresee this. As from 1 September 2029, they are not obliged to accept type approvals to any preceding series, except under paragraphs 13.4.5. and 13.4.6. Until 1 September 2030, they must accept 03 (subject to 13.3.5.) or 04 series approvals applying paragraph 6.15.1.(a), first issued before 1 September 2027. They must also continue to accept 03 (subject to 13.3.5.) or 04 series approvals for vehicles/vehicle systems not affected by the 05 series changes. In the Annex 2 examples, the first two digits of the approval number are now 05, for the 05 series of amendments.

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Q2Why it changed

Proposed by
Special Interest Group on Thermal Propagation
Working party
GRSP, 76th session (December 2024)

Reasons

  • The proposal aims to introduce improved requirements on thermal propagation and on the approval of electric powered vehicles. It also introduces provisions on the treatment of the intellectual properties of manufacturers.

    Sources (2)
    “It aims to introduce the improved requirements on thermal propagation and the approval of electric powered vehicles.”
    “In addition, the provisions concerning the treatment of intellectual properties of manufacturers have been introduced into the UN Regulation.”
  • Thermal runaway is a known failure mode of the lithium-ion battery and of other contemporary traction battery cells. The thermal runaway in a single cell may propagate to the surrounding cells. The smoke, fire and explosion threaten the safety of occupants of electric vehicles. Internal short circuits in contemporary traction batteries have already been reported in field failures.

    Sources (4)
    “Thermal runaway is a known failure mode of the lithium-ion battery, but also of other contemporary traction battery cells”
    “By heat transfer, the thermal runaway in a single cell may propagate to the surrounding cells”
    “The smoke, fire and explosion threaten the safety of occupants of electric vehicles.”
    “The internal short circuit in contemporary traction batteries has already been reported in field failures.”
  • Under the existing requirement, the manufacturer submits engineering documentation to demonstrate the vehicle's ability to minimize the risk of single cell thermal runaway. Different Technical Services applied this documentation requirement with considerable divergence. The requirement is also impractical, particularly in the context of the verification of compliance. For these reasons, and to improve regulatory certainty for economic operators, a test procedure needs to be provided.

    Sources (3)
    “the requirement exists whereby the manufacturer is required to submit engineering documentation to demonstrate the vehicle's ability to minimize the risk associated with single cell thermal runaway”
    “Given a considerable divergence in the application of the existing documentation requirement by different Technical Services under the type approval system, the impracticality of such a requirement, particularly in the context of the verification of compliance”
    “with a view to improve regulatory certainty for economic operators, a test procedure needs to be provided to demonstrate that potential risks to vehicle occupants associated with thermal propagation are appropriately minimized”
  • Four different test methods were selected to initiate the thermal runaway of a single cell, in terms of practicability and repeatability. Localized fast external heating is the trigger method that the Technical Service considers first.

    Sources (2)
    “Four different test methods were selected to initiate the thermal runaway of a single cell in terms of practicability and repeatability.”
    “Localized fast external heating is the trigger method for physical testing of thermal propagation safety performance, which is considered first by the Technical Service.”
  • Before the 05 series, the thermal propagation requirements applied to REESS containing flammable electrolyte. Taking into account relevant field data, the requirements also apply to REESS containing alkali metal anodes.

    Source
    “While the current requirements concerning thermal propagation apply to REESS containing flammable electrolyte, the proposed requirements also apply to REESS containing alkali metal anodes taking into account relevant field data.”

Document trail

  1. —ProposalGRSP-75-16Earlier informal proposal for the 05 series
  2. 2024-09RevisedECE/TRANS/WP.29/GRSP/2024/18Official proposal by the Special Interest Group on Thermal Propagation
  3. —Amended in sessionGRSP-76-08-Rev.1Amendments adopted with the proposal at the 76th GRSP session
  4. —Working party adoptsECE/TRANS/WP.29/GRSP/76Session report, para. 21
  5. 2024-12Sent to WP.29ECE/TRANS/WP.29/2025/41Text that GRSP sent to WP.29 and AC.1
  6. 2025-03WP.29 adoptsECE/TRANS/WP.29/1184Adopted at the 195th session (session report, para. 109)
  7. 2025-09-26In forceC.N.520.2025.TREATIES-XI.B.16.100UN depositary notification

Q3Who is affected

Vehicle manufacturer

  • Give the technical documentation of paragraph 6.15.3.1., including recommendations on the feasibility of physical testing.
  • Where paragraph 6.15.3. requires risk management analysis, make available the four-part high-level report of paragraph 6.15.4.
  • Make sure that smoke caused by thermal propagation is not released into the passenger compartment (paragraph 5.2.2.2.).
  • Keep material available for inspection for at least 10 years after production is definitively discontinued (paragraph 3.5.).
  • Check your 03 and 04 series approvals against the dates in paragraphs 13.4.2. to 13.4.6.

Component supplier

  • If information is shown to be specific know-how or covered by intellectual property rights, make sufficient information available for verifications.
  • Make sure that the REESS and the vehicle are compatible with regard to their communication (paragraph 6.16.).

Technical service / Approval authority

  • Determine whether physical testing is possible without compromising the safety functionality and design of the vehicle and/or REESS.
  • Consider localized fast external heating first when you select the trigger method for physical testing (paragraph 6.15.3.2.).
  • Document and justify your trigger method decision in the test report.
  • Assess risk management analysis for occupant safety in thermal propagation from an internal short circuit causing single cell thermal runaway.
  • Keep the formal documentation package available for at least 10 years after production is definitively discontinued (paragraph 3.5.).
  • Be ready for a design review of the intended REESS venting strategy and its installation (paragraph 5.2.2.2.).

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

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