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UN R122 Supplement 7 (00 series) · UNECE Regulation No. 122 (ECE R122) — Uniform provisions concerning the approval of vehicles of categories M, N and O with regard to their heating systems.

UN R122 — Supplement 7 to the 00 series of amendments

Supplement 6 → 7

Adopted at the WP.29 191st sessionEntry into force 2024-06-15
What changed
  • The manufacturer can exceed the Annex 5 temperature limits if it demonstrates during the type approval process that its safety concept covers for higher temperatures. The risk for occupants to get burns must not increase compared to the risk caused by the limit temperatures. In vehicles of categories M2 and M3, this possibility applies only to the driver and to passengers seated in the row adjacent to the driver.
  • The definitions of “Heating system” and “Electric heater” now also refer to the perceived temperature of occupants.
  • A new item in Annex 1 asks if the surface temperature exceeds the limit values in paragraphs 2.1. to 2.3. of Annex 5.
Why
  • Electric vehicles need separate energy to warm the interior, and the heating systems mainly used make the All Electric Range (AER) reduce sharply.
  • Radiation warmers were expected to increase the energy efficiency of electric vehicles. For the best efficiency, they cannot meet the Annex 5 limit temperature for non-metallic materials.
  • The expert from OICA explained that industry needed flexibility, since objective pass/fail criteria did not exist for such technology.

Q1What changed8 changes

Higher surface temperatures with a safety concept (Annex 5, para. 2)

Paragraph 2 now requires measuring heating system parts likely to come into contact with any occupant, instead of any driver, during normal road use. No such part may exceed the temperature limits in paragraphs 2.1. to 2.3., with one exception. The manufacturer can exceed these limits if it demonstrates during the type approval process that its safety concept covers for higher temperatures. The higher temperatures must not increase the risk for occupants to get burns, compared to the risk caused by the limit temperatures. Any such demonstration and documentation must be appended to the test report. In vehicles of categories M2 and M3, this possibility applies only to the driver and to passengers seated in the row adjacent to the driver.

The surface temperature of any part of the heating system likely to come into contact with any driver occupant of the vehicle during normal road use shall be measured with a contact thermometer. No such part or parts shall exceed a temperature limits defined in paragraphs below unless the manufacturer can demonstrate during the type approval process that their safety concept covers for higher temperatures without increasing the risk for occupants to get burns compared to the risk caused by the temperatures below. Any such demonstration and documentation shall be appended to the test report. The possibility to exceed these temperatures, does not apply to vehicles of 70 °C categories M2 and M3 other than for uncoated metal or 80 °C the driver and for other materialspassengers seated in the row adjacent to the driver.
Surface temperature

Limits for the driver and for passengers (Annex 5, paras. 2.1. to 2.3.)

Paragraph 2.1. now covers parts of the heating system likely to come into contact with the driver of the vehicle during normal road use. It limits their surface temperature to 70°C for uncoated metal or 80°C for other materials. Before this supplement, these limits applied to parts likely to come into contact with any driver. Paragraph 2.1. no longer has the 110 °C limit for parts behind the driver’s seat in the case of overheating. Paragraphs 2.2. and 2.3. now say that the part “is limited to” the value, instead of “no part … shall exceed” it. Their vehicle categories, conditions and values do not change.

In the case of part or parts of the heating system behind the driver’s seat, and in the case of overheating, the temperature shall not exceed 110 °C.The surface temperature of any part of the heating system likely to come into contact with the driver of the vehicle during normal road use is limited to 70°C for uncoated metal or 80°C for other materials.
In the case of vehicles of categories M1 and N, no any part of the system likely to come into contact with seated passengers during normal road use of the vehicle, with the exception of the outlet grille, shall exceed a temperature of is limited to 110 °C.
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Definitions of heating system and electric heater (paras. 6.1.1. and 6.1.5.)

The definitions of “Heating system” (para. 6.1.1.) and “Electric heater” (para. 6.1.5.) add the words “and/or the perceived temperature of occupants”. Before this supplement, the definitions did not refer to the perceived temperature of occupants. Paragraph 6.1.5. also writes “on-board” instead of “onboard”. The rest of the definition of “Electric heater”, including its exclusions, does not change.

"Heating system" means any type of device which is designed to increase the temperature of the interior of a vehicle, including any load area and/or the perceived temperature of occupants.
"Electric heater" means a device using electric energy from an onboard on-board or external source to increase the temperature of the interior of the vehicle and/or the perceived temperature of occupants. Electrical devices which are installed in addition to the main heating system and whose main function is not to heat the interior of the vehicle are not considered as electric heaters according to this Regulation. For example, electric devices installed in components for the sole purpose of heating that component are not considered as electric heaters according to this Regulation.

New item 11 on surface temperature (Annex 1, Part 2, Appendix 1, Section II)

Section II has a new item 11: “The surface temperature exceeds the limit values mentioned in paragraphs 2.1. to 2.3. of Annex 5: Yes/No”.

The surface temperature exceeds the limit values mentioned in paragraphs 2.1. to 2.3. of Annex 5: Yes/No
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Q2Why it changed

Proposed by
Expert from the Republic of Korea
Working party
GRSG, 125th session (March 2023)

Reasons

  • Unlike internal combustion engine vehicles, electric vehicles have no heating source. They need separate energy to warm the interior of the vehicle. As a result of the heating systems mainly used, the All Electric Range (AER) reduces sharply.

    Sources (3)
    “electric vehicles, unlike internal combustion engine vehicles, have a structural problem that requires separate energy consumption to warm the interior of the vehicle since they have no heating source”
    “are mainly used as heating systems for electric vehicles. As a result, AER reduces sharply.”
    “is also able to prevent the sharp reduction of All Electric Range (AER)”
  • Some automobile manufacturers and research institutes are researching radiation warmers as a way to increase heating energy efficiency. The expert from the Republic of Korea said that this technology was expected to increase the energy efficiency of electric vehicles. It was also expected to prevent the sharp reduction of the AER.

    Sources (2)
    “some automobile manufacturers and research institutes around the world are actively researching the application of radiation warmer as the way to increase heating energy efficiency”
    “He added that the technology of radiation warmers was expected to increase the energy efficiency of EV and to prevent the sharp reduction of the All Electric Range (AER).”
  • For the best efficiency, the surface temperature of a radiant warmer must be raised above a certain level. In this way, it is not possible to meet the non-metallic material limit temperature in Annex 5.

    Sources (2)
    “to achieve the best efficiency, the surface temperature of the device must be raised above a certain level.”
    “Therefore, in this way it is not possible to meet the non-metallic material limit temperature mentioned in annex 5 of this UN Regulation.”
  • The expert from OICA explained that industry needed flexibility and no design restrictions, since objective pass/fail criteria did not exist for such technology.

    Source
    “He also explained that industry needed flexibility and no design restrictions, since objective pass/fail criteria did not exist for such technology.”

Document trail

  1. 2023-01ProposalECE/TRANS/WP.29/GRSG/2023/8Proposal by the Republic of Korea
  2. —Working party adoptsECE/TRANS/WP.29/GRSG/104Session report, para. 24 and Annex IV
  3. 2023-08Sent to WP.29ECE/TRANS/WP.29/2023/100Text that GRSG sent to WP.29 and AC.1
  4. 2023-11WP.29 adoptsECE/TRANS/WP.29/1175Adopted at the 191st session (session report, para. 180)
  5. 2024-06-15In forceC.N.256.2024.TREATIES-XI.B.16.122UN depositary notification

Q3Who is affected

Vehicle manufacturer

  • To exceed the Annex 5 limits, demonstrate during the type approval process that your safety concept covers higher temperatures. Show that the burn risk for occupants does not increase compared to the risk caused by the limit temperatures. In M2 and M3 vehicles, use this only for the driver and passengers in the row adjacent to the driver.

Component supplier

  • If you supply devices that increase the perceived temperature of occupants, check them against paragraphs 6.1.1. and 6.1.5.

Technical service / Approval authority

  • Make sure that any demonstration and documentation for higher temperatures is appended to the test report.
  • Be ready for the new item 11 on surface temperature. It asks if the surface temperature exceeds the limit values in paragraphs 2.1. to 2.3. of Annex 5.

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

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