Download - GCSFP Study EV Regulations
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GCSFP Study - Regulations on a electric vehicle infrastructure for road traffic
A Study on: _____________________
Analysis of European/German and Chinese
Regulations regarding electric vehicle
infrastructure for road traffic
Commissioned as part of the
German Chinese Sustainable Fuel Partnership (GCSFP) _____________________
Date: 20.12.2010
Project participants:
German project leader:
EnergyAgency.NRW
Stefan GARCHE
Alexandra WOLFF
German project partners:
Centre for Solar Energy and Hydrogen Research (ZSW)
Dr. Harry DRING
Chinese project leader:
CATARC
Jonathan GUO
Jingjing LIANG
Ping YAN
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GCSFP Study - Regulations on a electric vehicle infrastructure for road traffic
Executive Summary
This study was carried out within the framework of the German Chinese Sustainable
Fuel Partnership (GCSFP) with the aim of identifying, summarizing and comparing
relevant legal regulations in the area of electric vehicles in Germany/European Union
and China.
This study focuses on the legal framework for an electric vehicle infrastructure in
Europe, Germany and China. Several laws, ordinances and standards were collected
and scanned by lawyers. A majority of the regulations come from the field of
approval, environmental and health and safety law. Amendments and new Directives
and Regulations with respect to the European and German legislation have been
highlighted.
The chapters are dedicated to the legal framework for EV production and
certification, use of EVs, and everything to do with batteries and recharging stations.
Every chapter finishes with a comparison. The last chapter contains
recommendations for the Chinese and German Ministries arising from the study.
Annexed is an overview on the European, German and Chinese legislation, written
for the existing study Analysis of European/German and Chinese Regulations
regarding a hydrogen infrastructure for road traffic1. Furthermore the structure of this
study follows the study on hydrogen.
Besides general provisions like production safety and product liability, the production
of electric vehicles has to fulfil specific requirements in regard to the installation of
industrially manufactured batteries. Given the fact that the parties of this study
emphasise the electrification of vehicles, no significant administrative barriers for
vehicles and charging infrastructure are expected.
1 Analysis of European/German and Chinese Regulations regarding a hydrogen infrastructure for road traffic
Commissioned as part of the German Chinese Sustainable Fuel Partnership (GCSFP), 3 September 2009
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Table of Contents
EXECUTIVE SUMMARY ............................................................................................................................. II
TABLE OF CONTENTS ............................................................................................................................. III
FIGURES ................................................................................................................................................. V
TABLES .................................................................................................................................................. V
LIST OF ABBREVIATIONS / TERMS AND DEFINITIONS ................................................................................. VI
0 PREFACE ........................................................................................................................................ 1
1 ELECTRIC VEHICLE REGULATIONS.................................................................................................... 4
1.1 PRODUCTION AND CERTIFICATION OF ELECTRIC VEHICLES (EV) ........................................................ 6
1.1.1 European Law and UNECE Regulations ........................................................................... 6
1.1.2 German Law .................................................................................................................... 20
1.1.3 Chinese Law .................................................................................................................... 22
1.1.4 Legal Comparison ............................................................................................................ 36
1.2 USE OF VEHICLES, POWER PURCHASE ........................................................................................... 38
1.2.1 Consumer information regarding environment, climate and energy policy ..................... 38
1.2.1.1 European Law .................................................................................................................. 38
1.2.1.2 German Law .................................................................................................................... 40
1.2.1.3 Chinese Law .................................................................................................................... 41
1.2.2 Taxes, Fees and Subsidies .............................................................................................. 45
1.2.2.1 European Law .................................................................................................................. 45
1.2.2.2 German Law .................................................................................................................... 48
1.2.2.3 Chinese Law .................................................................................................................... 52
1.2.3 Air Quality and Noise Pollution ........................................................................................ 56
1.2.3.1 European Law .................................................................................................................. 56
1.2.3.2 German Law .................................................................................................................... 56
1.2.3.3 China ................................................................................................................................ 58
1.2.4 Use of physical structures ................................................................................................ 59
1.2.4.1 European Law .................................................................................................................. 59
1.2.4.2 German Law .................................................................................................................... 60
1.2.4.3 Chinese Law .................................................................................................................... 60
1.2.5 Legal Comparison ............................................................................................................ 60
1.3 TRACTION BATTERIES ................................................................................................................... 62
1.3.1 Manufacturing and Disposal ............................................................................................ 63
1.3.1.1 European and UN Law .................................................................................................... 63
1.3.1.2 German Law .................................................................................................................... 69
1.3.1.3 Chinese Law .................................................................................................................... 70
1.3.2 Transportation .................................................................................................................. 72
1.3.2.1 Overview .......................................................................................................................... 72
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1.3.2.2 United Nations Recommendations on the Transport of Dangerous Goods .................... 74
1.3.2.3 Chinese Laws .................................................................................................................. 76
1.3.3 Fire Safety Regulations for Vehicle Batteries .................................................................. 77
1.3.4 Special topics of main emphasis ..................................................................................... 78
1.3.4.1 Producer .......................................................................................................................... 78
1.3.4.2 Classification .................................................................................................................... 80
1.3.4.3 Limitation of hazard materials .......................................................................................... 81
1.3.4.4 Labeling and Information Documents .............................................................................. 82
1.3.4.5 Transportation .................................................................................................................. 86
1.3.4.6 Safety Battery Tests (General) ......................................................................................... 88
1.3.4.7 Take Back (Collection) ..................................................................................................... 90
1.3.4.8 Reuse, recycling, treatment and disposal ........................................................................ 92
1.3.5 Legal Comparison ............................................................................................................ 96
1.4 RECHARGING STATIONS FOR VEHICLE BATTERIES ............................................................................ 99
1.4.1 European Law .................................................................................................................. 99
1.4.2 German Law .................................................................................................................. 100
1.4.3 Chinese Law .................................................................................................................. 104
1.4.4 Legal Comparison .......................................................................................................... 105
1.5 STATIONS FOR QUICK CHANGE OF VEHICLE BATTERIES .................................................................. 106
1.5.1 Europe and Germany .................................................................................................... 106
1.5.2 China .............................................................................................................................. 106
1.6 INFORMATION OF THE ENERGY MARKET ....................................................................................... 106
1.6.1 European and German Law ........................................................................................... 106
1.6.2 Chinese Law .................................................................................................................. 107
2 RESULTS, CONCLUSIONS AND RECOMMENDATIONS ....................................................................... 108
2.1 RESULTS AND CONCLUSIONS ....................................................................................................... 108
2.2 RECOMMENDATIONS .....................................................................................................................110
ANNEX 1 - OVERVIEW ON THE LEGAL SYSTEMS ......................................................................................... I
ANNEX 2 - THE STATUS QUO OF THE STANDARD SYSTEM OF CHINESE ELECTRIC VEHICLES ......................... XI
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Figures
Figure 1: High voltage sign, UNECE R-100 ........................................................................... 8
Figure 2: Approval sign according to UNECE-R 100, Annex 1 ............................................... 9
Figure 3: New European Driving Cycle (NEDC) test sequence, UNECE-R 101
Annex VII ............................................................................................................ 11
Figure 4: Classification of ESA for Automotive "e"-mark or other route to approval ...............15
Figure 5: CE-Marking (Communaut Europenne) ...............................................................19
Figure 6: German vehicle approval procedure ......................................................................21
Figure 7: Normative Chinese Test Cycles referring to Annex A of GB 18386 ........................34
Figure 8: China compulsory product certification (CCC) mark for safety (s) ..........................35
Figure 9: Request for information on fuel consumption, specific CO2 emissions
and power consumption (German) ......................................................................38
Figure 10: Automobile Fuel Consumption Labels, Normative Annex .....................................42
Figure 11: Environmental Zone and Fine Particulate Sticker, existing class 4 and
suggested class zero (blue or grey) ....................................................................57
Figure 12: Green Label and Vehicles with Yellow Label ........................................................58
Figure 13: Structure of the transport regulations ...................................................................73
Figure 14: Examples for producers .......................................................................................79
Figure 15: Symbol for separate collection for all batteries and accumulators ......................82
Figure 16: Label of batteries with critical content of Hg, Cd and Pb ......................................83
Figure 17: Label for shipped item .........................................................................................83
Figure 18: The mark of battery pack (Art. 4.1) As per the sign set forth in GB/T
5465.2; GB 2893 and GB 2894 ...........................................................................85
Figure 19: Sign 283 for Recharging Space of Vehicles (Berlin); [Source:
Wikipedia.de] .................................................................................................... 101
Figure 20: Example for plugs (see VDE-AR-E 2623-2-2:2009-10) ...................................... 103
Tables
Table 1: Access Conditions and Appraisal Requirements for New-energy Vehicle
Manufacturers (Annex 2 of the Administrative Rules) .........................................24
Table 2: Division Table of Technology Stages for New Energy Vehicles ...............................28
Table 3: Technical Stage Division Table of New Energy Vehicles ..........................................33
Table 4: Vehicle taxation for BEV and REEV in Germany .....................................................49
Table 5: Vehicle taxation for HEV in Germany ......................................................................49
Table 6: Passenger Cars (SUV included) Consumption Tax Rates Table ..............................55
Table 7: Acceptability of passenger cars in the Eurotunnel according to their fuel
type / power source (including dual fuelled & hybrid vehicles) .............................59
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List of abbreviations / Terms and Definitions
Active driving possible
mode
vehicle mode when application of pressure to the accelerator pedal (or
activation of an equivalent control) or release of the brake system will
cause the electric powertrain to move the vehicle.
Barrier part providing protection against direct contact with the live parts from any
direction of access
BEV Battery Electric Vehicle
BMVBS Federal Minister of Transport, Building and Urban Development
(Bundesministerium fr Verkehr, Bau und Stadtentwicklung)
ccm cubic centimeter
Conductive connection connection using connectors to an external power supply when the RESS
is charged
Direct contact contact of persons or livestock with live parts.
Euro (100 = 940 RMB; November 2010)
EEV Enhanced Environment-friendly Vehicle; vehicle with more than 3,5 t
propelled by an engine which complies with very low emissions
Electric regenerative
braking
braking system which, during deceleration, provides for the conversion of
vehicle kinetic energy into electrical energy.
Electric regenerative
braking control
device which modulates the action of the electric regenerative braking
system
Electrical chassis set made of conductive parts electrically linked together, whose potential is
taken as reference
Electrical circuit assembly of connected live parts which is designed to be electrically
energized in normal operation
Electric energy
conversion system
system that generates and provides electric energy for electric propulsion
Electric powertrain ECE R 100: electrical circuit which includes the traction motor(s), and may
include the RESS, the electric energy conversion system(s), the electronic
converters, the associated wiring harness and connectors, and the
coupling system for charging the RESS
ECE R 101: "Electric powertrain" means a system consisting of one or
more electric energy storage devices (e.g. a battery, electromechanical
flywheel or super capacitor), one or more electric power conditioning
devices and one or more electric machines that convert stored electric
energy to mechanical energy delivered at the wheels for propulsion of the
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vehicle;
Electronic converter device capable of controlling and/or converting electric power for electric
propulsion
ELV end of live vehicle
Enclosure part enclosing the internal units and providing protection against direct
contact from any direction of access
ESA electronic sub system
Exposed conductive part conductive part which can be touched under the provisions of the
protection degree IPXXB, and which may become electrically energized
under isolation failure conditions.
External electric power
supply
alternating current (AC) or direct current (DC) electric power supply
outside of the vehicle
GB Gubio mandatory national standard in China
GB/T Gubio tujin voluntary national standard in China
GG German Constitutional Law (Grundgesetz)
Green vehicle energy-efficient vehicle with less or no emission compared to traditional
vehicles
HEV Hybrid Electric Vehicle: combined conventional internal combustion engine
(ICE) propulsion system with an electric propulsion system (minimum of
one each) and stored energy/power:
- a consumable fuel
- an electrical energy/power storage device (e.g.: battery, capacitor,
flywheel/generator ...)
High Voltage UNECE-R 100: classification of an electric component or circuit, if its
working voltage is > 60 V and 1500 V DC or > 30 V and 1000 V AC
root mean square (rms)
EV Battery Draft: class-B voltage, DC system higher than 60V but lower
than or equal to 1,000V, with reference to GB/T 18384.3-2001.
High voltage bus electrical circuit, including the coupling system for charging the RESS that
operates on high voltage.
HVDC high-voltage, direct current
ICE Internal Combustion Engine: means vehicles powered by an internal
combustion engine only
Indirect contact contact of persons or livestock with exposed conductive parts.
IPXX International Protection Rating Code
first X is for solids, and second X for liquids
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additional letters classify the level of protection against access to
hazardous parts by persons
Live parts conductive part(s) intended to be electrically energized in normal use
Luggage compartment space in the vehicle for luggage accommodation,
bounded by the roof, hood, floor, side walls, as well as by the barrier and
enclosure provided for protecting the powertrain from direct contact with
live parts, being separated from the passenger compartment by the
front bulkhead or the rear bulk head
M1 vehicle Vehicles of category M: Motor vehicles with at least four wheels used for
the carriage of passengers
M1: Vehicles used for the carriage of passengers and comprising no
more than eight seats in addition to the drivers seat
70/156/EEC and GB/T 15089-2001
MIIT Ministry of Industry and Information Technology of P.R.C.
MOST Ministry of Science and Technology, P.R. China
MS EU Member State(s)
NEDC New European Driving Cycle consisting of four repeated ECE-15 driving
cycles and an Extra-Urban driving cycle
NDRC National Development and Reform Commission of P.R.C.
N1 vehicle vehicles of category N: Motor vehicles with at least four wheels used for
the carriage of goods
N1: Vehicles used for the carriage of goods and having a maximum
mass not exceeding 3.5 tons
70/156/EEC and GB/T 15089-2001
Ni-Cd, Ni-MH Nickel-Cadmium, Nickel-Metal Hydride
NOVC not Off-Vehicle Charging, also known as not externally chargeable or HEV
NRW German Federal State North Rhine-Westphalia
OEM Original Equipment Manufacturer, like Daimler or BYD
On-board isolation
resistance monitoring
system
device which monitors the isolation resistance between the high voltage
buses and the electrical chassis.
Open type traction
battery
liquid type battery requiring refilling with water and generating hydrogen
gas released to the atmosphere
OVC Off-Vehicle Charging, also known as externally chargeable or PHEV
Passenger compartment space for occupant accommodation, bounded by the roof, floor, side walls,
doors, window glass, front bulkhead and rear bulkhead, or rear gate, as
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well as by the barriers and enclosures provided for protecting the
powertrain from direct contact with live parts
PHEV Plug-in Hybrid Electric Vehicle, also known as a plug-in hybrid; hybrid
vehicle with rechargeable batteries that can be restored to full charge by
connecting a plug to an external electric power source
[no abbreviation for Parallel Hybrid Electric Vehicle, HEV propulsion
systems which run simultaneously or individually to supply power to run
the vehicle]
Power battery/cell Chinese term for Batteries/Cells in HEV, PHEV and EV
P.R.C. People's Republic of China
Protection degree protection provided by a barrier/enclosure related to the contact with live
parts by a test probe, such as a test finger (IPXXB) or a test wire (IPXXD),
R&TTE Radio and Telecommunications Terminal Equipment
REEV Range-Extended Electric Vehicle, also series hybrid; driven only by
electric traction but with a combustion engine assist.
RESS Rechargeable energy storage system, that provides electric energy for
electric propulsion. Electrical circuit used for charging the RESS from an
external electric power supply including the vehicle inlet.
RMB Renminbi Yuan (100 RMB: 10-11 Euro; November 2010)
Service disconnect device for deactivation of the electrical circuit when conducting checks and
services of the RESS, fuel cell stack, etc.
Solid insulator insulating coating of wiring harnesses provided in
order to cover and protect the live parts against direct contact from any
direction of access; covers for insulating the live parts of connectors, and
varnish or paint for the purpose of insulation.
UNECE R United Nations Economic Commission for Europe; World Forum for
Harmonization of Vehicle Regulations is a Working Party (WP.29)
V2G Vehicle to Grid technology
Vehicle type vehicles which do not differ in such essential aspects as:
(a) installation of the electric powertrain and the galvanically connected
high voltage bus.
(b) nature and type of electric powertrain and the galvanically connected
high voltage components
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Working voltage highest value of an electrical circuit voltage root mean-
square (rms) specified by the manufacturer, which may occur between any
conductive parts in open circuit conditions or under normal operating
conditions. If the electrical circuit is divided by galvanic isolation, the
working voltage is defined for each divided circuit, respectively.
XtL X to Liquid, where X means synthetic energy carriers like biomass, coal,
gas or petroleum coke
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0 Preface
This study is written in the framework of the German-Chinese Sustainable Fuel
Partnership (GCSFP). Within the scope of the GCSFP Program, founded in
December 2003 by the German Federal Ministry of Transport, Building and Urban
Affairs (BMVBS) and the Chinese Central Ministry of Science and Technology
(MOST), Germany and China agreed to work together at a deeper level on questions
of improving energy efficiency in road transport and the use of alternative and
regenerative fuels.
Besides XtL and biodiesel, energy by electrons has also been considered as a
sustainable fuel in the GCSFP program, which considers both fuel cell electric
vehicles and battery electric vehicles. In a joint Chinese-German H2 & FC Workshop
in Berlin, on 20 25 May 2007, both sides presented their national R&D programs
with the aim of identifying major areas of potential mutual cooperation.
Although the main focus of that workshop was related to H2 vehicles, both sides
were already interested at this stage in cooperation in the field of battery driven
electric vehicles as well. Later this interest for battery EVs expanded continuously
and was highlighted by Sino-German Electro Mobility Workshops dedicated to both
EVs and traction batteries (Shanghai 5 December 2008, Wuhan 16 July 2010).
Furthermore a cooperation between the Chinese model region Wuhan and the
German model region Rhine-Ruhr (NRW) started up in 2010. In accordance with the
talk by BMVBS Minister Peter RAMSAUER und MOST Minister Gang WAN on 12
November 2010 in Berlin the model region cooperation is to be extended.
Though electric vehicles are not a new technology we are now entering a new period
of unprecedented development of this EV technology, caused by the enormous
increase in the battery performance. It is expected that EVs will very soon be
introduced commercially onto the market.
For this market launch both regulations and standards are necessary. This present
study points to the present status of regulations in both countries with the aim of
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seeing whether the regulations are both sufficient for the market launch and allow the
reciprocal import of EVs.
In view of the vigorous nature of the activities in China concerning the formulation
and modification of regulations some of these could only be discussed towards the
end of this study. For that reason Annex 2 presents a list of Chinese Standards within
the current status.
This study will not give final solutions, but will spotlight challenges and give
recommendations for mutual projects in the area of traction batteries and the relevant
infrastructure. Based on these recommendations detailed projects are to be initiated.
Information presented in this study is mainly based on literature studies, conference
materials, internet search, and interviews.
This study primarily covers passenger cars and if possible also buses, trucks and
commercial vehicles. Two- and three-wheeled vehicles are only addressed in
separate main regulations.
For figures and tables taken from the literature the sources are given. All figures and
tables without references are self drawn.
Finally it should be mentioned that EV and battery areas are very dynamic. New
regulations, rules and codes&standards are permanently in the process of
development. The present study summarizes the development so far. Nearly all the
regulations discussed are available from the authors and will be provided on request.
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The following team was responsible for the study:
Germany
Project leader: EnergyAgency.NRW Haroldstr. 4, D-40213 Dsseldorf; Germany, www.energieagentur.nrw.de
Stefan GARCHE, Tel: +49 211 - 866 42 23; [email protected] Alexandra WOLFF; Tel: +49 211 866 42297, [email protected]
Project partner (responsible for batteries): Center for Solar Energy and Hydrogen Research (ZSW) GB 3, Helmholtzstr. 8, D-89081 Ulm, Germany, www.zsw-bw.de
Harry DRING, + 49-731-9530-602, [email protected] China:
Project leader: China Automotive Technology and Research Center (CATARC) Block 7, Phase II, No.188 Western Rd., 4th South Ring Rd. Fengtai District, Beijing 100070, PR China, www.catarc.ac.cn
JiaQiang GUO, [email protected] Jingjing LIANG, [email protected] Ping YAN, [email protected]
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1 Electric Vehicle Regulations
Given the importance of reducing carbon emissions from road transport and the
independence of oil supply, electric cars may well provide a viable alternative to
traditional internal combustion engines using fossil fuels. In order to encourage the
electrification of road transport, it is necessary to eliminate potential regulatory
hurdles and to encourage standardisation activities on both intra- and extra-vehicle
technologies.
An EU Roadmap on Regulations and Standards for electrification of vehicles
describes the state-of-play with regard to regulatory and standardisation activities. A
strategy to eliminate the identified obstacles in a timely manner with the involvement
of all relevant stakeholders considers both the European and international level.
China also has a great interest in pushing forward with the electrification of vehicles.
Many electric vehicle companies are looking to China as the leader of future electric
vehicle implementation around the world. International cooperation and exchange of
technologies and experiences, as mentioned in the Renewable Energy Program, of
China will support this intention. This thesis is outlined thus: The Program will
intensify international exchanges and cooperation for basic research, technological
development, demonstration and application in the field of new and renewable
energy. It will encourage the inclusion of advanced Chinese new energy technologies
on the international exchange platform and the sharing with other countries of the
respective technologies and recourses.
In April 2009, Chinese officials announced their plan to make China the worlds
largest producer of electric vehicles. The Renault-Nissan Alliance works together with
Chinas MIIT to help set up battery recharging networks throughout the city of
Wuhan, the pilot city in the countrys electrical vehicle pilot program. The corporation
plans to have electric vehicles on the market by 2011. According to an April 10, 2009
New York Times article entitled China Outlines Plans for Making Electric Cars
vehicle manufacturers will possess the opportunity to successfully market their cars
to Chinese consumers due to the short and slow commutes that characterize
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Chinese transportation, and to the fact that many first time car-buyers are less
accustomed to the power of gasoline-powered cars, subsequently diminishing the
hindering nature of lower-powered electric vehicles. It reports that China would like to
assist the industry with automotive innovation by launching a program that is worth
as much as 10,000m RMB ($1,460m). In the same article, it also reports that the U.S.
government is providing $25,000m to help cover domestic automobile makers
research costs.
This mutual cooperation between China and Germany is the specific focus within the
framework of the German Chinese Sustainable Fuel Partnership (GCSFP).
The EV regulations contain regulations about production, registration, transportation,
operation, safety, take back, reuse, recycling and disposal. The relevant regulations
are to distinguish between vehicle, battery, charge and swapping stations. Whereas
some regulatory target areas of EVs are covered by general regulations for vehicles,
valid for both ICE and electric vehicles, regulations for batteries and
charging/swapping stations have to be drawn up anew. For these new regulations,
however, general regulations which have applied for some time, e.g. for handling
hazard materials, for environmental protection or recycling, are taken into account.
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1.1 Production and Certification of Electric Vehicles (EV)
1.1.1 European Law and UNECE Regulations
Framework Directive (Directive 2007/46/EC)
With the new Framework Directive (Directive 2007/46/EC2) the legislative framework
for the type approval of motor vehicles has been extended to cover all road vehicles
irrespective of their means of propulsion. Thus it now includes alternative powertrain
vehicles, for example BEVs and HEVs. EVs can be subsumed under article 3 No. 11
motor vehicle or No. 15 hybrid electric vehicle. At the moment there are no specific
technical requirements in the type approval legislation to deal with the specific
characteristics and specific risks of electric vehicles with a view to the protection of
users from electric shock, other safety issues and environmental performance.
However, the proper functioning of the internal market must also be ensured for new
technology vehicles. Thus it is necessary to develop a harmonised approach
regarding the approval requirements of electric vehicles. Drafts therefore exist
amending Annex IV and Annex VI3 and Annex II and Annex VIII4 to Directive
2007/46/EC. Directive 385/2009/EC replaces Annex IX of 2007/46/EC to reflect the
changes to the template of the certificate of conformity.
For two- or three-wheel motor vehicles and quadricycles (class L) Directives
2002/24/EC5 and 97/24/EC6, both amended by several Directives7, are applicable.
2 Directive 2007/46/EC of the European Parliament and of the Council of 5 September 2007 establishing a framework
for the approval of motor vehicles and their trailers, and of systems, components and separate technical units intended for such vehicles, OJ L 263, 9.10.2007, pp. 1160. Last amended by Commission Regulations (EU) No 371/2010 of 16 April 2010 replacing Annexes V, X, XV and XVI
to Directive 2007/46/EC of the European Parliament and of the Council establishing a framework for the approval of motor vehicles and their trailers, and of systems, components and separate technical units intended for such vehicles (Framework Directive)
3 D010536/03: Draft amending Annexes IV and VI to Directive 2007/46/EC of the European Parliament and of the Council establishing a framework for the approval of motor vehicles and their trailers and of systems, components and separate technical units intended for such vehicles (Framework Directive)
4 Draft replacing Annexes II and VIII to Directive 2007/46/EC of the European Parliament and of the Council establishing a framework for the approval of motor vehicles and their trailers, and of systems, components and separate technical units intended for such vehicles
5 Directive 2002/24/EC of the European Parliament and of the Council of 18 March 2002 relating to the type approval of two or three-wheel motor vehicles and repealing Council Directive 92/61/EEC
6 Directive 97/24/EC of the European Parliament and of the Council of 17 June 1997 on certain components and
characteristics of two or three-wheel motor vehicles
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UNECE Regulations
Pursuant to the new Framework Directive (Directive 2007/46/EC), the legislative
framework for type approval of motor vehicles has been extended to cover all road
vehicles. Directive 2007/46/EC provides for the possibility of applying UNECE
Regulations for the purpose of EC vehicle type approval on a compulsory basis. Thus
it also includes alternative powertrain vehicles, such as full electric and hybrid cars.
On June 15 2010 a proposal was published by EC on the compulsory application of
61 UNECE Regulations latest 2014 for the type approval8. In this package most EV-
relevant UNECE Regulations like R 100 and 101 are not named.
UNECE-R 1009 deals with the electric safety of vehicles, but it is not yet applicable to
the EC type approval of vehicles on a mandatory basis. The current version of
UNECE-R 100 applies only to pure electric vehicles, however an electric safety
working group (ELSA) under the Passive Safety Working Party (GRSP) of UNECE
developed a revised version of UNECE-R 100 (series of amendments 01,
ECE/TRANS/ WP.29/2010/52). The proposal aims at ensuring that all EVs marketed
in Europe are constructed according to a common safety standard, at the same time
protecting vehicle users from coming into contact with high voltage parts of the
vehicle. UNECE-R 100 sets out safety requirements for the approval of vehicles
equipped with an electric powertrain (fully electric and hybrid vehicles). Mandating
UNECE-R 100 would ensure simplification of the approval procedure through
harmonized requirements on electric safety. There is a broad support for the
proposal, since harmonized test requirements will simplify the approval of electric
vehicles. Indeed it will replace divergent approval practices of some MSs and hence
will result in substantial savings for manufacturers.
7 http://ec.europa.eu/enterprise/sectors/automotive/documents/directives/directive-2002-24-ec_en.htm and
http://ec.europa.eu/enterprise/sectors/automotive/documents/directives/directive-97-24-ec_en.htm 8 COM(2010)310 final, NLE(2010)0169: Proposal for a Council Decision of [...] on the compulsory application of
Regulations No 1, 3, 4, 6, 7, 8, 10, 11, 12, 13, 13 H, 14, 16, 17, 18, 19, 20, 21, 23, 25, 26, 28, 31, 34, 37, 38, 39, 43,
44, 46, 48, 55, 58, 61, 66, 67, 73, 77, 79, 80, 87, 89, 90, 91, 93, 94, 95, 97, 98, 99, 102, 105, 107, 110, 112, 116, 118, 121, 122, 123 and 125 of the United Nations Economic Commission for Europe for the type approval of motor vehicles, their trailers and systems, components and separate technical units intended therefore.
9 ECE/TRANS/WP.29/2010/52; Proposal 01 series for Regulation No. 100; 22 December 2009.
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The final adoption of the revised version took place at the WP.29 session in March
2010 and is to become effective in 2010. This extension to existing provisions in
regard to specifications for the electric powertrain to ensure a high level of public
safety in relation to EVs includes terms and definitions and application aspects for the
approval of EVs. It also encompasses provisions for specifications and tests (No.5).
EVs must incorporate protection against electric shock and direct contact. To provide
protection with respect to live parts inside the passenger compartment or luggage
compartment, the protection degree IPXXD must be provided for. In other areas, the
protection degree IPXXB must be adhered to for live parts. High voltage is defined as
>60V and 1500V DC or >30V and 1000V AC root mean square.
Figure 1: High voltage sign, UNECE R-100
The figure above must appear on or near the Rechargeable Energy Storage System
(RESS). Protection with respect to indirect contact and insulation resistance is
required. The batteries must be submitted to hydrogen emission tests (UNECE-R 100
No. 5.1.1.5).
If the approval of this vehicle type is granted, the approval mark is the number
alongside letter E, which is the country code listed in UNECE-R 100 No. 4.4.1. The
approval mark is affixed to the vehicle and may not be not smaller than 8 mm, and it
shows where the road vehicle type concerned has been approved. The number
beside it provides information about the Regulation applied and which series of
amendment.
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Figure 2: Approval sign according to UNECE-R 100, Annex 1
UNECE-R 10 rev. 0310 will be mandatory in all other MSs as from autumn 2010, Art.
12.4. It applies to vehicles, components and separate technical units intended for
installation in these vehicles with a view to electromagnetic compatibility. It covers
requirements regarding the immunity to radiated and conducted disturbances and the
control of unwanted radiated and conducted emissions. The updated mandatory
EMC tests that are required according to ECE Regulation R10.03 include the
following.
- Broadband radiated emission (CISPR 25)
- Narrowband radiated emission (CISPR 25)
- Immunity to electromagnetic radiation (ISO 11451-1, ISO 11451-2, ISO 11451-4)
- Immunity to transient disturbances (ISO 76 7-2)
- Emission of conducted disturbances (ISO 76 7-2)
UNECE-R 1311 and 13H12 regulates braking. Electric regenerative braking systems,
which produce a retarding force upon release of the throttle pedal, is not to generate
a signal mentioned above. The signal is not to be activated by the application of the
service braking system below 4 m/s (or N1 6 m/s). A service braking system is
defined as a braking system that makes it possible to control the movement of the
vehicle and to halt it safely, speedily and effectively, whatever its speed and load, on
any up or down gradient. It must be possible to graduate this braking action.
Assumed an electric regenerative braking system is a service braking system the
braking signal has to flash while recuperating with more than 4 m/s (N1 vehicles 6
10 ECE-R 10/03 (EU O.J.) (final) Approval of vehicles with regard to electromagnetic compatibility 11 E/ECE/324; E/ECE/TRANS/505 Addendum 12: Regulation No. 13 } Rev.1/Add.12/Rev.6 ; 14 January 2008 12 ECE/TRANS/WP.29/2007/3; Proposal for draft amendments to Regulation No. 13-H (Harmonized Braking)
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m/s). The Appendix of Annex 4 demands procedures for monitoring the state of the
charge of vehicle batteries used for traction and regenerative braking. Annex 14
specializes in trailers with electric braking systems.
UNECE-R 5113 on noise. The vehicle, its motor and muffler have to be structured in a
way that the vehicle conforms to UNECE-R 51 under regular operating conditions.
According to No. 6.2.1.1 of UNECE-R 51, only the driving noise of EVs is to be
controlled, not the noise in stationary state.
EVs have also to comply with the provisions of UNECE-R 8514 concerning the
approval of electric drive trains intended for the propulsion of M and N vehicles with
regard to the net power and the maximum 30 minutes electric power.
UNECE-R 83 as well as UNECE-R 101 are relevant for emissions from EVs.
UNECE-R 8315 provides the approval of vehicles with regard to the emission of
pollutants according to engine fuel requirements. Also HEVs and PHEVs are defined
and specific provisions are made in Annex 14 regarding type approval based on
emission tests. A positive aspect is that the type approval can be extended to
vehicles of the same type following the rules of Art. 7. The decision on this lies with
the technical service in charge of the tests.
UNECE-R 10116 applies, alongside the emission of CO2 and fuel consumption of
ICE, to the measurement of electric energy consumption and electric range of M1
HEVs and PHEVs as well as M1 and N1 BEVs. Electrical energy consumption is
expressed in watt hours per kilometer (Wh/km).
These vehicle tests run in the "New European Driving Cycle (NEDC) as used for
conventional vehicles but the results are "corrected" as a function of the battery
energy balance before and after the NEDC. This means:
13 ECE Regulations 51, Rev.1/Add.50/Rev.1/Amend.4 14 ECE Regulations 85, Rev.1/Add.84/Amend.5 15 ECE Regulation 83, Rev.1/Add.82/Rev.3/Amend.3 16 ECE Regulation 101, Rev.2/Add.100/Rev.2/Amend.2
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- If the battery is being charged during the NEDC the CO2 result is corrected
proportionally downwards
- If the battery is being discharged during the NEDC the CO2 result is corrected
proportionally upwards
The PHEV tests also run in the NEDC New European Driving Cycle. Two tests are
performed because part of the propulsion energy is external to the grid:
- measurement of CO2 in an NEDC starting with a fully charged battery
- measurement of CO2 in an NEDC starting with a empty battery
In this way the CO2 result (g/km) is independent of the initial battery state of charge
and thus a fair reflection of the actual performance of the hybrid system whose sole
source of energy is the fuel. In addition the total electric driving range is measured,
too.The final CO2 result is a weighted average of both CO2 test results as a function
of the electric driving range and European average distance between two charges
(=25 km).
Figure 3: New European Driving Cycle (NEDC) test sequence, UNECE-R 101 Annex VII
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EC Regulations
In regard to the EC type approval under Framework Directive 2007/46/EC additional
Directives and Regulations have to be considered:
- The amendments series 01 of UNECE-R 100 are to be adopted by the EU. A
proposal for a Council Decision17 on the compulsory application has already
existed since June 2010. The legal basis of the proposal is Article 34(2) of Directive
2007/46/EC. Following this proposal Amendments 00 of UNECE-R 100 are to
become affective in the EU by 2011 regarding type approval and by 2012 regarding
registration, sale and entry into service of EVs, as well as Amendments 01
regarding type approval by 2013 and registration, sale and entry into service of EVs
by 2014.
- Regulation (EC) 715/200718 of emissions. The regulation establishes common
technical requirements for the type approval of motor vehicles and replacement
parts. It also lays down rules for in-service conformity, durability of pollution control
devices, on-board diagnostics, measurement of fuel consumption and accessibility
of vehicle repair and maintenance information. It is applicable to vehicles with
combustion engines including hybrid vehicles. The definition hybrid vehicle means
a vehicle with at least two different energy converters and two different energy
storage systems (on vehicle) for the purpose of vehicle propulsion. Combined with
UNECE-R 10, limited emissions in regard to energy consumption and range are
provided for.
- Directive 71/320/EEC19 for braking systems. Energy recuperation is not mentioned
in this Directive. UNECE-R 1320 regulates braking. According to UNECE-R 13-H
17 COM(2010)280 final: Proposal for a Council Decision on the compulsory application of Regulation No 100 of the United Nations Economic Commission for Europe for the approval of motor vehicles with regard to electric safety
(2010/0168 (NLE)); Brussels, 15.6.2010 18 Regulation (EC) No 715/2007 of the European Parliament and of the Council of 20 June 2007 on type approval of
motor vehicles with respect to emissions from light passenger and commercial vehicles (Euro 5 and Euro 6) and on
access to vehicle repair and maintenance information, OJ L 171, 29.6.2007, p. 116. 19 Council Directive 71/320/EEC of 26 July 1971 on the approximation of the laws of the MSs relating to the braking
devices of certain categories of motor vehicles and of their trailers, OJ L 202, 6.9.1971, p. 3774. 20
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electric brakes, brakes with electrical transmission and brakes with energy
recuperation can be approved. Electric regenerative braking systems, which
produce a retarding force upon release of the throttle pedal, may not generate a
signal light. The signal may not be activated by the application of the service
braking system below 4 m/s (or N1 6 m/s). The service braking system defined is
a braking system that makes it possible to control the movement of the vehicle and
to halt it safely, speedily and effectively, whatever its speed and load, on any up or
down gradient. It must be possible to graduate this braking action. Assuming an
electric regenerative braking system is a service braking system the braking signal
has to flash while recuperating with more than 4 m/s (N1 vehicles 6 m/s). The
Appendix of Annex 4 demands procedures for monitoring the state of battery charge
of vehicle batteries used for traction and regenerative braking. Annex 14 specializes
in trailers with electrical braking systems.
- The Directive 2004/108/EC21 applies to a vast range of equipment encompassing
electrical and electronic appliances, systems and installations. The main objective
of the Directive is to guarantee the free movement of apparatus and to create an
acceptable electromagnetic environment in the EU. The level of protection
requested is further specified in this Directive by protection aims in the field of
electromagnetic compatibility.
According to Article 1(4) of this Directive, if the EMC requirements for equipment are
wholly or partly laid down more specifically by other Directives, this Directive shall
not apply, or shall cease to apply, to that equipment in respect to such requirements
from the date of the mandatory application of those Directives.
Specific EMC protection and safety requirements applicable to motor vehicles are
laid down by the EMC Directive 2004/104/EC22, which amends Directive
21 Directive 2004/108/EC of the European Parliament and of the Council of 15 December 2004 on the approximation of the laws of the MSs relating to electromagnetic compatibility and repealing Directive 89/336/EEC, OJ L 390, 31.12.2004, p. 2437.
22 Commission Directive 2004/104/EC of 14 October 2004 adapting to technical progress Council Directive 72/245/EEC relating to the radio interference (electromagnetic compatibility) of vehicles and amending Directive 70/156/EEC on the approximation of the laws of the MSs relating to the type approval of motor vehicles and their
trailers
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72/245/EEC23 concerning the electromagnetic compatibility of motor vehicles. This
concerns electronic subassemblies (ESAs) and after-market electronic equipment
with respect to to immunity related functions. For such equipment a type approval
following Directive 2004/104/EC is required. No interference should come from the
vehicle or parts of the vehicle. The type approval legislation does not deal with
emissions and immunity during the charging of electric vehicles. This may be
covered by Directive 2006/95/EC24.
The new EMC Directive is a significant improvement over the 1995 Directive
95/54/EC25. It is both clearer in the requirements and test levels. In using
international automotive test standards it brings the test methods for the EU
directive into line with the test configurations used by most automotive OEMs. In
the future translating the results from e-mark testing to an international ISO,
CISPR or VM specification will be much more straightforward.
The last amendment to Directive 72/245/EEC was effected by 2009/19/EC26, which
relates to the electromagnetic compatibility of vehicles and was released in March
2009. The EMC requirements for vehicles and their electric/electronic subassembly
(ESA) included in the EC Directive (e-mark) and ECE Regulation (E-mark) are
technically equivalent again.
23 Council Directive 72/245/EEC of 20 June 1972 on the approximation of the laws of the MSs relating to the suppression of radio interference produced by spark-ignition engines fitted to motor vehicles, OJ L 152, 6.7.1972, p.
1524. 24 See fn 37 25 Commission Directive 95/54/EC of 31 October 1995 adapting to technical progress Council Directive 72/245/EEC
on the approximation of the laws of the Member States relating to the suppression of radio interference produced by spark-ignition engines fitted to motor vehicles
26 Commission Directive 2009/19/EC of 12 March 2009 amending, for the purposes of its adaptation to technical
progress, Council Directive 72/245/EEC relating to the radio interference (electromagnetic compatibility) of vehicles
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Figure 4: Classification of ESA for Automotive "e"-mark or other route to approval27
Components sold as after-market equipment and intended for installation in motor
vehicles need no type approval under the motor vehicle EMC Directive if they are
not related to immunity-related functions (see Annex I, section 3.2.3 of EMC
Directive). This type of equipment is assessed with the EMC Directive or the R&TTE
Directive 1999/5/EC28 as necessary. It carries the CE marking and an EC
Declaration of Conformity must be issued.
27 Source: AutoEMC.net 28 Directive 1999/5/EC of the European Parliament and of the Council of 9 March 1999 on radio equipment and
telecommunications terminal equipment and the mutual recognition of their conformity
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- Directive 78/317/EEC29 for defrosting. Requirements are for all vehicles class M1. It
must be considered that no significant motor heat is given off. By analogy these
provisions apply for EVs with combustion heating systems.
- Directive 2001/56/EC30 concerning heating systems. According to number 3.1
annex II, every vehicle must have a heating system within the passenger
compartment. If therefore a combustion heating is specified, the tank for liquid or
gaseous fuel has to comply with the corresponding provisions.
- Directive 70/221/EEC31 of liquid fuel tanks was applicable for liquid tanks and
therefore partly applicable for EVs (just in regard to their heating systems). The
Directive was recently repealed by the Regulation (EC) 661/200932 concerning type
approval requirements for the general safety of motor vehicles. It therefore
regulates the type approval of motor vehicles, their trailers and systems and
separate units intended with regard to their safety. Manufacturers may choose to
apply for type approval with regard to all the systems, and the installation of all the
components and separate technical units covered by this Regulation, or for type
approval with regard to one or more systems and the installation of one or more
components and one or more separate technical units covered by this Regulation.
Type approval in accordance with the UNECE Regulations listed in Annex IV is to
be considered as an EC type approval in accordance with this Regulation and its
implementing measures. Manufacturers must ensure that vehicles are designed,
constructed and assembled so as to minimize the risk of injury to vehicle occupants
and other road users. Provisions for fuel cell vehicles are the subject of Regulation
(EC) 29/2009.
29 Council Directive 78/317/EEC of 21 December 1977 on the approximation of the laws of the MSs relating to the defrosting and demisting systems of glazed surfaces of motor vehicles, OJ L 81, 28.3.1978, p. 2748.
30 Directive 2001/56/EC of the European Parliament and of the Council of 27 September 2001 relating to heating
systems for motor vehicles and their trailers, amending Council Directive 70/156/EEC and repealing Council Directive 78/548/EEC, OJ L 292, 9.11.2001, p. 2140.
31 Council Directive 70/221/EEC of 20 March 1970 on the approximation of the laws of the MSs relating to liquid fuel
tanks and rear protective devices for motor vehicles and their trailers, OJ L 76, 6.4.1970, p. 2324. 32 Regulation (EC) No 661/2009 of the European Parliament and of the Council of 13 July 2009 concerning type
approval requirements for the general safety of motor vehicles, their trailers and systems, components and separate
technical units intended therefor, OJ L 200, 31.7.2009, p. 124.
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- Noise Level Directive 70/157/EEC33 relating to the permissible sound level and the
exhaust system of motor vehicles combined with UNECE-R 5134. The recent
developments in engine technology make it necessary to define more explicitly the
testing process.
- Directive 80/1268/EEC35 of CO2 emissions. This Directive is only applicable for
vehicles with combustion engines. For EVs provisions of UNECE-R 101 are
applicable regarding energy consumption and range. Directive 80/1269/EEC36 for
motor power is also limited to internal combustion engines.
EVs are not exempted from the Low Voltage Directive 2006/95/EC37. For this reason
the provisions are also to be transferred to electric vehicles.
Hybrid EVs containing fuel cells have to be in line with Regulation (EC) 79/200938. It
contains general provisions for the testing methods for hydrogen vehicles of the
category M and N. It is mandatory for all MSs. It lays down fundamental provisions
regarding requirements for the type approval of motor vehicles with regard to
hydrogen propulsion, for the type approval of hydrogen components and hydrogen
systems and for the installation of such components and systems. This Regulation is
a separate one for the purposes of the Community type approval procedure provided
for in Directive 2007/46/EC establishing a framework for the approval of motor
vehicles and their trailers, and of systems, components and separate technical units
intended for such vehicles.
Vehicles which are granted an approval for small series are able to obtain a reduction
of restrictions according to Art. 23 of Directive 2007/46/EC. For individual approvals
33 Council Directive 70/157/EEC of 6 February 1970 on the approximation of the laws of the MSs relating to the permissible sound level and the exhaust system of motor vehicles, OJ L 42, 23.2.1970, p. 1620.
34 See fn. 13 35 Council Directive 80/1268/EEC of 16 December 1980 on the approximation of the laws of the MSs relating to the fuel
consumption of motor vehicles, OJ L 375, 31.12.1980, p. 3645. 36 Directive 80/1269/EEC of 16 December 1980 on the approximation of the laws of the MSs relating to the engine
power of motor vehicles 37 Directive 2006/95/EC of the European Parliament and of the Council of 12 December 2006 on the harmonisation of
the laws of MSs relating to electrical equipment designed for use within certain voltage limits, OJ L 374, 27.12.2006, p. 1019.
38 Regulation (EC) No 79/2009 of the European Parliament and of the Council of 14 January 2009 on type approval of
hydrogen-powered motor vehicles, and amending Directive 2007/46/EC, OJ L 35, 4.2.2009, p. 3246.
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MSs may exempt a particular vehicle, whether unique or not, from compliance with
one or more of the provisions of this Directive or with one or more of the regulatory
acts listed in Annex IV or Annex XI, provided that they impose alternative
requirements.
However, some of the separate Directives in the context of the Community type
approval procedure under Directive 2007/46/EC or some of their requirements will
not apply to hydrogen-powered vehicles, since the technical characteristics of
hydrogen-powered vehicles differ significantly from conventional ones, for which
these type approval Directives were essentially designed. Pending the amendment of
those Directives to include specific provisions and test procedures on hydrogen-
powered vehicles, it is necessary to set out transitional provisions in order to exempt
hydrogen-powered vehicles from these Directives or some of their requirements.
Manufacturers will be able to apply for the EC whole-vehicle type approval of
hydrogen-powered vehicles on a voluntary basis. The manufacturer must provide to
the type approval authority the information set out in Annexes of Regulation (EC)
406/201039. This Regulation supplements Regulation (EC) No 79/2009 by specifying
the precise definitions of terms such as hydrogen sensor, filling cycle, fitting or
hydrogen filter. It also lays down administrative provisions for the EC type approval
of a vehicle with regard to hydrogen propulsion, and administrative provisions for the
EC component type approval of hydrogen components and systems.
The European CE Marking of products is intended to support the free movement of
goods within the European Economic Area. All products that bear CE marking must
comply with all provisions of the applicable directives. Where a product carries
appropriate CE marking, the member countries of the European Economic Area must
allow the product to be placed on the market.
CE Marking directives cover many product areas. Some of the relevant CE marking
directives are:
39 Commission Regulation (EC) No 406/2010 of 26 April 2010 implementing Regulation (EC) No 79/2009 of the
European Parliament and of the Council on type approval of hydrogen-powered motor vehicles
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Low Voltage Directive 73/23/EEC (amended 93/68/EEC)
Electromagnetic Compatibility 89/336/EEC (amended 92/31/EEC, 93/68/EEC,
98/13/EC)
Machinery 98/37/EC (amended 98/79/EC)
Figure 5: CE Marking (Communaut Europenne)
Note: Some products have a CE symbol that has been alleged to stand for China Export and is
confusingly very similar to the E.U.'s CE mark. The two letters are close together, not spaced as in the
European conformance mark.
The Commission of the EU announced in April 201040 that they by working together
with international partners at the UNECE will:
- propose electric safety requirements for vehicle type approval in 2010;
- review all type approval requirements covered by Directive 2007/46/EC by 2011;
- review crash safety requirements and consider whether the quietness of these
vehicles is potentially dangerous to vulnerable road users by 2012.
Non-vehicle engine type approval
In order to reduce air pollution caused by the engines of non-road mobile
machinery, Directive 97/68/EC41 specifies acceptable emission standards and
40 http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2010:0186:FIN:EN:HTML
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certification procedures for these engines. Non-road mobile machinery means any
mobile machine, transportable industrial equipment or vehicle with or without
bodywork that is not intended for use to carry goods or passengers on the road, in
which an internal combustion engine is installed, for example excavators and other
construction equipment, locomotives and inland waterway vessels. Approvals
granted in accordance with Directive 2005/55/EC42 are accepted. EVs are not
covered by this Directive.
1.1.2 German Law
The holder of an EC type approval of vehicles can be sure of the validity in the EU
and the European Economic Area. The manufacturer has the advantage that its
products can be sold in all MSs, without undergoing other national approval
procedures. In Germany the EC type approval of vehicles is regulated by the EG-
FGV43. It refers to Directive 2007/46/EC and 2002/24/EC and it is applicable for all
vehicles of classes M, N and O. This means that for vehicles in mass production
national approval is no longer necessary.
For non-EC type approved vehicles manufactured or built in series general approval
can be granted, 20 StVZO. Not unimportant is 21a StVZO which allows the
recognition of permits and approvals on the basis of international agreements and
acts of the EC.
For other vehicles 21 StVZO44 is relevant if vehicles are not type approved. In that
case the approval authority deals with the request.
41 Directive 97/68/EC of the European Parliament and of the Council of 16 December 1997 on the approximation of the laws of the MSs relating to measures against the emission of gaseous and particulate pollutants from internal combustion engines to be installed in non-road mobile machinery, amended by Directive 2001/63/EC, 2002/88/EC,
2004/26/EC and 2006/105/EC 42 See fn. 56 43 Verordnung ber die EG-Genehmigung fr Kraftfahrzeuge und ihre Anhnger sowie fr Systeme, Bauteile und
selbstndige technische Einheiten fr diese Fahrzeuge (EG-Fahrzeuggenehmigungsverordnung EGFGV vom 21. April 2009 (BGBl. I S. 872, 873)"
44 Straenverkehrs-Zulassungs-Ordnung of 28. September 1988 (BGBl. I S. 1793), last amended by Art. 3 of this
Regulation of 21. April 2009 (BGBl. I S. 872)
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Figure 6: German vehicle approval procedure
The Federal Motor Transport Authority deals with all matters regarding approval of
vehicles, parts and systems and the use in road traffic. This authority recommends
controlling safety requirements according to the UNECE-R 100. Designated test
laboratories for technical service regarding (ECE) approval are listed by this authority.
UNECE-R 10 is already mandatory in Germany.
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1.1.3 Chinese Law
To enhance the production and development of better vehicles, the 2007
Administration Rules on Access to the Production of New-Energy Vehicles45
() was enacted in 2007 by NDRC. Automobile enterprises
applying to manufacture new-energy vehicles powered by new energies should have
adequate research, production and after-sales service capacities and need to ensure
the reliability of the vehicles. The definition new energy includes hybrid electric
vehicles (HEVs), pure electric vehicles (BEVs, including solar-powered car), fuel cell
electric vehicles (FCEVs) other new sources (such as super capacitors, flywheel
energy storage devices such as high-performance) automobiles. The Regulation
applies to manufacturers producing and selling new-energy vehicles. It refers to
vehicles using irregular fuels as power sources. The Regulation contains provisions
for the classification for new-energy vehicles, qualifications of new-energy automobile
production as well as management for enterprises and products.
In addition MIIT implemented in China framework provisions called 2009
Administrative Rules on Access for New-energy Vehicle Manufacturers and
Products46. These Rules (No. 44 of GCY [2009]) are valid from July 1, 2009. As
compared with the Administrative Rules 2007, the content of these rules is more
specific on the conditions of approval for new-energy vehicle products. Both
authorities claim to be responsible for the access administration for new-energy
vehicle manufacturers and products, and the rules of 2009 do not refer to the rules of
2007. In these rules the use of lead-acid battery hybrid passenger cars, pure electric
and pure electric passenger cars, commercial vehicles, and the use of metal hydride
nickel-powered hybrid vehicles is classified as relating to mature products.
One highlight of the Rules 2009 lies in clear definitions of three conditions of
approval: compliance with a series of standards regarding safety, environmental
45 Administration Rules on Access to the Production of New-Energy Vehicles, promulgated by the National
Development and Reform Commission of the P.R.C., 2007.11.01. 46 MIIT of P.R. of China Announcement No. 44 of GCY [2009]
Administrative Rules on Access for New-energy Vehicle Manufacturers and Products. These Rules come into force
on July 1st of 2009: http://www.miit.gov.cn/n11293472/n11293832/n11294057/n11302390/12427300.html
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protection, energy saving, theft proofing, etc., the passing of some quality tests and
no infringement of intellectual property rights.
Production Conditions:
The manufacturer:
- must conform to the provisions of relevant national laws, statutes, regulations and
national policies for the development of the automobile industry and national
macroeconomic regulatory policies;
- should be a vehicle manufacturer or a manufacturer of modified commercial
vehicles in the Proclamation; for a newly-built automobile enterprise or an existing
automobile enterprise producing other types of new energy vehicles, it should go
through the approval or registration formalities of the project according to relevant
national provisions of investment management in advance.
- have the necessary capacity of and the necessary conditions for producing new-
energy automobile products;
- have the capacity of researching and designing new energy automobile products;
- have the capacity of ensuring the production consistency of new-energy
automobile products;
- have the capacity of sales and after-sales services of new-energy automobile
products;
- establish the purchase system of parts and components adaptable to new-energy
automobile products produced;
- Vehicle products should meet the requirements of relevant national standards and
industrial standards, technical criteria, and vehicle product approval test
procedures, and the exclusive technical conditions and inspection criteria
adaptable to new-energy automobiles;
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Table 1: Access Conditions and Appraisal Requirements for New-energy Vehicle Manufacturers
(Annex 2 of the Administrative Rules)
I Manufacturing capability and conditions
1 Manufacturer shall have necessary production site, storage site or facilities,
as well as appropriate, neat production environment.
2* The processing precision and capability of production equipment shall match
the features of product.
Special facilities, tooling and tools necessary for new-energy vehicle
production are required, safety protection measurements should be laid
down and carried out. If necessary, a charger is needed.
II Design and development capability
3 Manufacturer shall set up the product R&D body responsible for the
activities in the design and development of new-energy vehicles. The
professionals shall be capable of performing the design and development
work, promptly follow up both local and foreign latest developments
regarding new-energy vehicle technologies, be able to follow up, evaluate
and transform national and professional technical standards and regulations,
and be able to accomplish system development, complete vehicle matching,
and other activities.
4 Manufacturer shall establish the product design and development flow
adapted to the enterprise itself as well as the design specifications and job
instructions intended for directing concrete design work; as a minimum, this
must cover the entire design course of proprietary product and complete
vehicle, management of technical documents, standardization, etc.; in
addition they must be capable of being applied in actual work.
The process of design and development should be similar to that of
conventional vehicles, focusing on the steps and requirements concerning
design and development of new-energy vehicles.
The design criteria shall guide the design and evaluation of the self-
produced and refitted new-energy vehicles, R&D and validation of
purchased assembly function and performance; this must include as a
minimum the complete vehicle control, motor control, transmission and
power coupling control, onboard energy management, onboard recharger
management, communication and data exchange system and subsystem.
5* Manufacturer shall possess the core technology of at least one of the
following three systems: on-board energy system, power transmission
system, and control system of the new-energy vehicle.
Manufacturer shall be fully familiar with and master the core technology:
technical principle, structure, function and performance requirements,
control method, communication and data exchange, failure mode, security
risk, evaluation test and diagnosis and solution of main default patterns.
Manufacturer shall also understand and determine the boundary division
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and interface definition of control system, onboard energy system AND
driving system.
The manufacturer should have the intellectual property right to the core
technology (including as a minimum modification right and usufruct of
design).
6* Manufacturer shall have the pilot production capability adapted to the
complete vehicle, systems and critical assemblies of the new-energy vehicle
to be manufactured, including test validation adapted to self-research of the
manufacturer.
7 The design & development input for the product and manufacturing process
shall be sufficient and appropriate; the design & development output for
product and manufacturing process shall be put forward in a way that
verification can be conducted specifically with consideration of the design
input, which shall be reviewed, demonstrated and confirmed, and related
records shall be retained.
8 Prior to execution of a design amendment of the product and manufacturing
process (including any amendment arising from the supplier), review
(including reviewing the effects of the design amendment on product
constituents and the delivered products), demonstration and approval shall
be conducted again; if appropriate, the customers consent shall be
obtained; in addition, the requirements for conformity of production and
product traceability shall be met.
III Capability in assuring conformity of production
9 The staff involved in product quality shall have the corresponding capability
and operate strictly in accordance with procedural documents, job
instructions or relevant process documents.
It is necessary to establish and implement the staff capability evaluation &
appraisal system, and retain appropriate records.
10 Documented inspection rules or inspection job instructions shall be
developed for the important receiving inspection, process inspection and
final inspection; inspections and demonstration shall be carried out as per
the stipulated items, approaches, frequency and limit values; particular
attention shall be paid to the compliance with safety, environmental
protection and energy conservation regulations, the special requirements of
clients, and the requirements for testing items specific to new-energy
vehicles.
As for key and special processes, the operation instruction shall be
developed, clear-cut process requirements and control method shall be
made available, the operation shall be normalized, and process surveillance
and measurement shall be implemented.
11 The inspection equipment for electrical performance and safety, temperature
measurement and dangerous gas concentrations of the power battery
system and drive motor and safety test line for the completed vehicles are
required.
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Testing of the performance of the control system and its subsystem, at least
including function and performance of controller hardware and software
(control unit), is required.
Testing the performance of the main function and performance with regard
to new energy vehicles, at least including power performance and economy
(energy consumption), is required.
12 It is required that the entire product traceability system be established from
the suppliers of key components and assemblies to the delivery of the
complete vehicle. In the case of any serious common-nature issues
regarding product quality, safety, environmental protection, and energy
conservation, the cause should be ascertained quickly and the recall scope
can then be decided; if customer requests spare parts, the technical status
of the spare part concerned must be capable of being determined quickly.
13* Products (complete vehicle, components and assemblies) shall conform to
the national compulsory standards and verified technical norms; the
products to enter the formal manufacturing stage shall also meet the
requirements for conformity of production.
In the case of any big change regarding manufacturers capacity in assuring
conformity of production (including staff capability, manufacturing/inspection
equipment, procured raw materials, components, assemblies and their
suppliers, manufacturing technology, work environment, management
system, etc.), sufficient evidence shall be made available to prove that the
original requirements can be still met.
IV Product sales and after-sales services
14 It is required that the complete, documented management systems on sales
and after-sales services be established, including personnel training
(manufacturers staff, contracted sales and repair personnel, customers, or
staff of using entity), construction of sales and after-sales service network,
supply of repair services, supply of spare parts, handling of claims, feedback
of information, recall of complete vehicle, recovery of complete vehicle and
components (e.g., battery), client management, etc.; in addition
manufacturer shall be capable of implementing such systems.
It shall be noted that the requirements for sales and construction of after-
sales service network shall apply to the products of the mature stage only.
15 Repair services and supply of spare parts shall meet all customers
requirements; it shall be assured that, in the life cycle of the product,
customers can obtain reliable spare parts, repair and consulting services
within the specified time limits as committed by the manufacturer.
After-service system should be capable of controlling defect detection of
systems and subsystems and maintenance, both independently of or in
cooperation with suppliers to complete the after-service items in the same
way as those for conservative vehicles. It should be also capable of
performing basic defect detection and replacements for onboard energy,
driving system, onboard charger and other systems and assemblies.
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As for the products at the start-up and growth stages, the commitments
regarding after-sales services shall be sufficient and appropriate, and this
shall be definitely communicated to each party and shall be strictly
implemented.
16 It is necessary to establish such a mechanism that quality-related
information can be fed back promptly.
As for the products at start-up and growth stages, manufacturer shall set up
an archive for every vehicle, in addition to a regular follow-up and quality
information management system relating to it.
V Components purchase management
17 It is necessary to set up a component purchase and management system,
and define the evaluation criteria for evaluating and selecting suppliers and
purchasing from the qualified suppliers. The evaluation covers product
safety, quality management system, technology, manufacture and inspection
capability of suppliers. The relevant records shall be kept.
The enterprise for new-energy vehicles which is producing products in the starting
and development period should offer after-sales services to users according to the
pledges regarding after-sales services; it should establish a corresponding file for
each vehicle and track the operation of the vehicle until the vehicle goes out of
service or becomes unusable (Art. 16).
The enterprise which is producing products in starting and development period
should complete the quarterly model operation report together with the user, and
submit it to the MIIT.
If the enterprise for new-energy vehicles finds any serious problem that affect the
safety, environmental protection and energy conservation of any of its products, it
should immediately stop production and sales and make due rectification within a
time limit. It must then make a timely report to the MIIT and the provincial department
in charge of industry and information technology in the place where the product is
used (Art. 17).
The enterprise which has obtained the qualification as a manufacturer of electric
vehicle can apply for the homologation of new-energy vehicle products.
The product certification stipulations include:
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- Products must meet the relevant standards and regulations concerning safety,
environmental protection, energy conservation and prevention of theft.
- Products must have passed the inspection by a testing organ appointed by the
MIIT (hereinafter referred to as testing organ). New-energy vehicles need to meet
not only standards for traditional vehicles but also exclusive standards for new-
energy vehicle products, shown in the table.
- Products must not infringe the intellectual property rights of third parties.
In the Rules 2009 a series of important standards regarding safety, environmental
protection, energy saving etc. was implemented. This list is as follows and the main
contents, if known, are explained in italics.
Table 2: Division Table of Technology Stages for New Energy Vehicles (applicable prior to December 31 of 2010; Annex 1 of the Administrative Rules)
Serial no.
Standard number Standard name
1 GB/T 4094.2-2005
Marks of Controllers, Indicators and Signal Devices of Electric Vehicles This standard specifies basic requirements for electric vehicle, regarding symbols for controls, indicators and tell-tales, and colours for tell-tales. (based on ISO 2575:2000/Amd.4:2001; JEVS Z 804:1998)
2 GB/T 18384.1-200147
Part One of Safety Requirements for Electric Vehicles: Vehicle-borne Energy Storing Device
Part Two of Safety Requirements for Electric Vehicles: Function Safety and Failure Emergency Protection
Part Three of Safety Requirements for Electric Vehicles: Personnel Electric Shock Emergency Protection
This standard specifies the safety specification for on-board energy storage of the electric vehicle propulsion system to ensure the safety of users and vehicle env