UN R100 Supplement 1 (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 — Supplement 1 to the 05 series of amendments
Base text → Supplement 1
- What changed
- New section 0. says that the Regulation is amended to account for vehicles of categories X and Y.
- Whilst an ADSF-2 is active, the warnings of paragraphs 5.1.3.3., 5.1.4.4., 5.2.3. and 5.2.4. must be transmitted as a logic signal to the ADS.
- For vehicles of category O, paragraph 5.1.4.4. now requires the trailer to give an optical and/or audible warning to the driver of the towing vehicle.
- Why
- The TF-AVRS proposal was prepared to enable the application of the Regulation to vehicles equipped with an Automated Driving System (ADS).
- The proposal from France was prepared to correct inconsistencies that followed the extension of the Regulation to vehicles of category O.
- Paragraph 5.2.1.1. was replaced by paragraph 7.1. in the 05 series of amendments.
Q1What changed39 changes
Introduction for vehicles of categories X and Y (section 0.)
New section 0. says that the Regulation is amended to account for vehicles of categories X and Y. Without a driver or manual driving controls in the vehicle, related provisions must not be taken into account, unless this amendment already covers them. For vehicles with an ADS other than categories X and Y, no special provisions or exemptions apply in the manual driving mode. In a mode where an ADS feature is active, the relevant ADS requirements apply. For vehicles of category Y, the mechanical integrity of the REESS is validated at component level, with the component-based alternative.
ADS features of type 1 and type 2, and active driving possible mode (paragraphs 2.1., 2.58. and 2.59.)
New paragraphs 2.58. and 2.59. define an ADS feature of type 1 (ADSF-1) and an ADS feature of type 2 (ADSF-2). An ADSF-1 includes an ADS fallback response requiring a fallback user. An ADSF-2 does not include an ADS fallback response requiring a fallback user. Paragraph 2.1. adds a meaning of “active driving possible mode” for the time whilst the ADS is active. It is the vehicle mode when the signals sent by the ADS will cause the electric power train to move the vehicle.
Warnings transmitted to the ADS whilst an ADSF-2 is active (paragraphs 5.1.3.3., 5.1.4.4., 5.2.3. and 5.2.4.)
Paragraphs 5.1.3.3., 5.1.4.4., 5.2.3. and 5.2.4. add the same sentence for the time whilst an ADSF-2 is active. Then the warning must be transmitted as a logic signal to the ADS. The sentence also refers to the technical requirements of UN Regulation No. 185, in its original version or later series of amendments. These are the isolation resistance warnings and the warnings of failure in REESS and of low energy content of REESS. The adopted text has the placeholder “UN Regulation No. [XXX]”. A RegVault Note explains that RegVault shows No. 185, the UN Regulation on Automated Driving Systems.
Driver provisions that do not apply whilst an ADSF-2 is active, Annex 8 discharge and Annex 9E occupants (paragraphs 5.3.1., 5.3.2. and 5.3.4.)
Paragraphs 5.3.1., 5.3.2. and 5.3.4. now say that their provisions do not apply whilst an ADSF-2 is active. Paragraph 5.3.1. covers the indication to the driver when manual activation of the propulsion system first places the vehicle in active driving possible mode. Paragraph 5.3.2. requires a signal to the driver when leaving the vehicle if it is still in the active driving possible mode. Paragraph 5.3.4. requires that the state of the drive direction control unit is identified to the driver. In Annex 8, paragraphs 5.1.1.1. and 5.1.2., the REESS discharge now also stops when an indication to stop the vehicle is given by the ADS. In Annex 9E, paragraph 1., the situation should now leave the occupants, not the driver and passengers, with enough time to evacuate.
Warnings from trailers of vehicles of category O (paragraphs 5.1.4.4. and 5.2.3.)
For vehicles of category O, paragraph 5.1.4.4. now requires the trailer to give an optical and/or audible warning to the driver of the towing vehicle. Paragraph 5.1.4.4. applies when an isolation resistance monitoring system is provided and detects isolation resistance less than the requirements of paragraph 5.1.3. In addition, for category O3 and O4, the trailer may give the towing vehicle a signal to address an optical and/or audible warning. In paragraph 5.2.3., the sentence on vehicles of category O3 and O4 now begins with “In addition,”. Paragraph 5.2.3. adds that its requirements related to paragraph 6.15. do not apply to REESS solely installed on vehicles of category O. They also do not apply to batteries on vehicles of category O used for recuperation.
Thermal propagation: batteries used for recuperation and vehicles of category Y (paragraph 6.15.)
In paragraph 6.15., the exception for batteries on vehicles of category O now says “used for recuperation” instead of “used for recuperation only”. A new sentence in paragraph 6.15. says that the paragraph does not apply to vehicles of category Y.
References to paragraph 7.1., to Annexes 5A and 5B, and to R.E.3 (paragraphs 5.4.1. and 6.4.1.3., footnotes)
In the second sentence of paragraph 5.4.1., the reference “5.2.1.1.” is now “7.1.”. The RegVault Note that explained the old reference to paragraph 5.2.1.1. is removed. Paragraph 6.4.1.3. changes the isolation resistance measurement for a high voltage REESS. It now uses Annex 5A after the vehicle based test and Annex 5B after the component based test. Footnote 1 of sections 0. and 1. and the footnote of paragraph 4.3.1. now refer to R.E.3, document ECE/TRANS/WP.29/78/Rev.8. The Annex VI amendments adopted with the AC.1 vote also changed the text of footnote 1.
Q2Why it changed
- Proposed by
- Expert from Germany on behalf of the GRSP Task Force on Automated Vehicles Regulation Screening (TF-AVRS); expert from France
- Working party
- GRSP, 78th session (December 2025)
Reasons
The TF-AVRS proposal was prepared to enable the application of the Regulation to vehicles equipped with an Automated Driving System (ADS). The Regulation was first written for vehicles with a driver and manual driving controls. The amendment intends to keep the spirit of the Regulation. It also intends to extend its application to vehicles without a driver and without manual driving controls inside the vehicle.
Sources (4)
“to enable the application of the regulation to vehicles equipped with an Automated Driving System (ADS)”
“See paragraph 0. in the proposal”
“The Regulation was originally drafted for vehicles with driver and manual driving controls”
“It is the intention of this amendment to keep the spirit of the regulation and to extend its application to vehicles without driver and without manual driving controls inside the vehicle”
During the 194th session of WP.29 (November 2024), the scope of UN Regulation No. 100 was extended to vehicles of category O. The proposal from France was prepared to correct inconsistencies that followed this extension.
Sources (2)
“During the 194th session of WP.29 (November 2024), the scope of UN Regulation No. 100 was extended to vehicles of category O.”
“The text reproduced below was prepared by the experts from France to correct inconsistencies following the amendment of regulation 100 by vehicles of category O.”
The signal that trailers of category O3 and O4 may give to the towing vehicle is not mandatory. It applies only in addition to the warning that the trailer must give for vehicles of category O. The change clarifies the provisions for vehicles of category O to avoid any misunderstanding. The warning requirements of paragraph 5.1.4.4. should be aligned with the requirements of paragraph 5.2.3.
Sources (3)
“Those specific indications are non-mandatory and only apply in addition to the following prescriptions for vehicles of category O”
“clarifies the prescriptions for vehicles of category O and avoid any misunderstanding”
“The warning requirements of this paragraph should be aligned with the requirements of paragraph 5.2.3.”
Paragraph 5.2.1.1. was replaced by paragraph 7.1. in the 05 series of amendments. Paragraph 6.4.1.3. is amended for clarification.
Sources (2)
“Paragraph 5.2.1.1. has been replaced by paragraph 7.1. in the 05 series of amendments.”
“Paragraph 6.4.1.3. has been amended for clarification purposes.”
At the GRSP session, the expert from the Russian Federation asked why the text needed a distinction between REESS and batteries used for recuperation only. The expert from the Kingdom of the Netherlands explained that, by definition, the term REESS does not include batteries used for recuperation only. The experts from France and the Russian Federation worked together on a revision of the proposal that would avoid misinterpretations.
Sources (3)
“The expert from the Russian Federation asked why a distinction between Rechargeable Electrical Energy Storage Systems (REESS) and batteries used for recuperation only was needed in the regulatory text.”
“by definition a REESS provides electric energy for electrical propulsion and therefore the term does not include batteries used for recuperation only”
“The experts from France and the Russian Federation worked together to produce a revision of the proposal that would avoid misinterpretations.”
Document trail
- —ProposalGRSP-77-42Proposal by France for the 77th GRSP session
- 2025-09ProposalECE/TRANS/WP.29/GRSP/2025/33Proposal by the expert from Germany on behalf of TF-AVRS
- 2025-09RevisedECE/TRANS/WP.29/GRSP/2025/37Proposal by the expert from France, based on GRSP-77-42
- —Amended in sessionGRSP-78-35-Rev.1TF-AVRS changes to ECE/TRANS/WP.29/GRSP/2025/33
- —Amended in sessionGRSP-78-36-Rev.2Changes by the expert from France to ECE/TRANS/WP.29/GRSP/2025/37
- —Working party adoptsECE/TRANS/WP.29/GRSP/78GRSP session report, paras. 26 and 43 and Annex V
- 2026-03Sent to WP.29ECE/TRANS/WP.29/2026/50Text that GRSP sent to WP.29 and AC.1
- —Amended in sessionWP.29-199-10Amendments for the AC.1 vote, reproduced in Annex VI of ECE/TRANS/WP.29/1192
- 2026-06-24WP.29 adoptsECE/TRANS/WP.29/1192Adopted at the 199th session (session report, para. 103)
- PendingIn forceDate not yet known
Q3Who is affected
Vehicle manufacturer
- With an ADSF-2 active, send fuel cell DC high voltage bus isolation warnings to the ADS as a logic signal.
- With an ADSF-2 active, send the paragraph 5.1.4.4. isolation resistance warning to the ADS as a logic signal.
- Whilst an ADSF-2 is active, send the warning of failure in REESS to the ADS as a logic signal.
- For pure electric vehicles, send the low REESS state of charge warning to the ADS whilst an ADSF-2 is active.
- For category O trailers with isolation monitoring, give the paragraph 5.1.4.4. warning optically and/or audibly to the towing vehicle's driver.
Component supplier
- No direct action for this role.
Technical service / Approval authority
- Whilst an ADSF-2 is active, check the ADS logic signal for isolation resistance, REESS failure and low energy warnings.
- For category O trailers with isolation monitoring, check the paragraph 5.1.4.4. optical and/or audible warning to the towing vehicle's driver.
- In the Annex 8 test, also stop the REESS discharge when the ADS gives an indication to stop the vehicle.
- For vehicles of category Y, be ready for REESS mechanical integrity validation at component level, with the component-based alternative.
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ⓘ This report gives advice only. It is not legal or type-approval advice.