19

Licensing regulations for electric vehicles

legal requirements regarding rechargeable energy storage systems

T. Goldbach    Auf den Elfmorgen, Dalheim, Germany

Abstract

This chapter describes how the legal requirements for rechargeable energy storage systems have been worked out, starting with a white paper and ending with amending the respective regulation. The description shows the progress of the six meetings of the working group organized under the United Nations in Geneva. In addition, a summary of the legal requirements are part of this chapter. The end of the chapter describes the outlook of the legal work.

Keywords

Rechargeable energy storage systems

Vibration

Thermal shock and cycling

Mechanical shock

Mechanical integrity

Fire resistance

External short circuit protection

Overcharge protection

Over-discharge protection

Over-temperature protection

Emission.

19.1 Introduction

In Geneva, the GRSP (Working Group on Passive Safety) at the United Nations (UN) agreed to set up a group of interested experts to establish legal requirements for rechargeable energy storage systems (RESS).

Therefore, the World Forum for Harmonization of Vehicle Regulations (WP.29) agreed to extend the mandate of the existing informal group on electric safety (ELSA) to cover these new activities through a group of interested experts, instead of establishing a new informal group under GRSP.

The ELSA was responsible for developing electric vehicle safety (EVS) requirements under the 1998 Agreement. Although it was agreed that the RESS component and system requirements are part of the Type Approval Process under the 1958 Agreement, ELSA decided on its eighth meeting to start the business in a separate subgroup.

In a first step the group considered requirements for RESS in vehicles of categories M and N. In a second step the group may also consider requirements for RESS in vehicles of category L.

19.2 Objective of the legal requirements

The objective of the legal requirements is to ensure the safety of (REESS), which provides electric energy for electrical propulsion installed in vehicles of categories M and N during normal operation and postcrash.

For that purpose, if possible and practicable under the 1958 agreement, existing regulations should be amended for REESS requirements concerning their functional, mechanical, chemical, and electrical safety.

An approach for the approval of components and systems (e.g., Economic Commission for Europe (ECE) R 28) should be achieved. Existing regulations and standards (e.g., IEC, ISO) will be considered.

19.3 Meetings of rechargeable energy storage systems (RESS) to develop the requirements for vehicles of categories M and N

Table 19.1

Meetings of the RESS group

MeetingDateLocation
RESS 01November 2, 2010Ministry of Transport, Bonn, Germany
RESS 02January 11–12, 2011CCFA Facilities, Paris, France
RESS 03April 12–14, 2011SP, Boras, Sweden
RESS 04July 5–7, 2011GMAPC/Opel, Mainz, Germany
RESS 05October 18–20, 2011Ministerio de Indutria Turismo Comercio, Madrid, Spain
RESS 06January 10–12, 2012ACEA, Brussels, Belgium

19.4 Work in the informal working group

19.4.1 General information

The informal group was chaired by the German Ministry of Transport and supported by the World Association of Automobile Manufacturers (OICA) as secretariat.

The informal group started with a “blank white paper.” The decision where and how to incorporate the new requirements into the existing legislation should be done after the requirements are defined.

This approach was chosen because of the advantage to focus on the necessary requirements without being restricted by any interface to existing legislations.

19.4.2 First meeting of the informal group in Bonn

During the first meeting of the informal group the Terms of References (ToR) been finalized based on a proposal from Germany. The agreed ToR (GRSP-48-01 rev.1) can be found on the website of the UN in Geneva.

The informal group discussed the topics to be considered. As a first result the following was agreed to be considered:

(A) Requirements of the first priority:

25CF Vibration

25CF Thermal shock cycling

25CF Humidity/moisture exposure

25CF Mechanical shock

25CF Fire resistance

25CF External short circuit

25CF Overcharge protection

25CF Over-discharge protection

25CF Over-temperature protection

25CF Protection against direct contact

25CF Emission

25CF Over-current charge

25CF Short circuit (internal)

(B) Additional requirements:

25CF Immersion test (REESS completed under water)

25CF Dust

25CF Marking

25CF Electromagnetic compatibility

In addition, the structure to each topic should look like:

a. Rationale

b. Requirement

c. Conditions

d. Acceptance criteria

e. Verification

19.4.3 Second meeting of the informal group in Paris

At the beginning of the second meeting the members of the group agreed that it should be the goal to get a REESS approved as a component or together with the vehicle. Furthermore, the defined requirements should not consider a special chemistry of the battery such as lithium-ion.

Based on the structure agreed at the first meeting, the experts proposed requirements to be incorporated at different parts of the document. These proposals resulted in a working document for the second meeting.

A main part of the working document dealt with the idea to incorporate the existing requirements of UN 38.3 where possible.

UN 38.3 stays for a UN Manual “Test and Criteria” Part III, defining requirements for lithium batteries/cells, which they have been verified to fulfill. If they do not, their transport is not allowed.

Based on the discussions during the meeting it was agreed that the following topics should be finalized by different groups of experts:

25CF Vibration

25CF Thermal shock and cycling

25CF Dewing (temperature change): still under discussion whether requirements are necessary

25CF Mechanical impact

 Mechanical shock

 Mechanical integrity

25CF Fire resistance

25CF External short circuit

25CF Overcharge protection

25CF Over-discharge protection

25CF Over-temperature protection

25CF Protection against direct contact

25CF Emissions

Furthermore, the experts agreed that following two topics have no longer been considered because they are captured by the other topics:

25CF Over-current charge and discharge

25CF Short circuit (internal)

19.4.4 Third meeting of the informal group in Boras (Sweden)

The proposals elaborated by the different groups of experts became the basis for a new working document for the third meeting. This document was discussed during the meeting.

The outcome of the meeting was further improvement to the requirements for the different topics of the first priority. It was also agreed by the group of experts that “dewing” no longer has to be considered.

Furthermore, the following two topics were added to the possible “Additional Requirements” list:

25CF Telltale

25CF Storage of REESS at low and high temperature

In addition, a list of action items for different experts/expert groups was compiled.

19.4.5 Fourth meeting of the informal group in Mainz Kastel (Germany)

Also for the fourth meeting of the group, a working paper based on the outcome of the action items of the third meeting was compiled. During the meeting, the requirements were discussed and improved. The following two annexes were added:

25CF Annex 1: Measurement of isolation resistance

25CF Annex 2: Dimension and technical data of firebricks

In the list of possible additional requirements, the group agreed that “Telltale” and “Storage of REESS at low and high temperature” no longer has to be considered.

After the fourth meeting, the requirements had been elaborated in a way that it was time to discuss how to incorporate them in the existing legal framework. This was also important because of the idea raised during meetings at the UN in Geneva to develop a “Global Technical Regulation” (GTR) for EVS. As soon as such a work started, it had the consequence to stop the REESS work under the 1958 agreement. Therefore the experts of the group decided to amend UN R 100. Amending an existing regulation will not take as much time compared to passing a new regulation that has to be agreed upon by the relevant groups in Geneva (GRSP and WP.29).

19.4.6 Fifth meeting of the informal group in Madrid

During the fifth meeting the group of experts discussed a first proposal to amend Regulation 100. In this proposal, the requirements were divided into two parts. Part I (Chapter 5) contained the existing requirements of a vehicle with regard to its electrical safety. This is the part dealing with the so-called “in-use” requirements for electric vehicles. Part II (Chapter 6) contained the new requirements for rechargeable energy storage system with regard to its safety. There the requirements were defined that a REESS has to fulfill to get an approval under Regulation 100. The necessary tests to be executed are described in new Annexes 8–8I.

At the meeting in Madrid it was also agreed to change the acronym RESS for “Rechargeable Energy Storage System” to REESS. This was necessary because of in Regulation 92 the acronym RESS had already been used. There the acronym stood for replacement exhaust silencing systems for motorcycles, mopeds, and three-wheeled vehicles.

Further, it was agreed that for the upcoming GRSG session in December 2011 an informal document showing the status of the amendment of Regulation 100 would be sent to Geneva.

19.4.7 Sixth meeting of the informal group in Brussels

At the beginning of the sixth meeting, the chair informed the attendees that the status report based on the informal document 6 for the 50th session of GRSP was well received. In addition GRSP expressed their expectation for a so-called working document for the 51st session in May 2012.

To be able to send a working document to the 51st session of GRSP the experts of RESS finalized the technical input for the amendment of Regulation 100. The basis therefore was the outcome of the action items defined during the fifth meeting.

At the end of the sixth meeting the experts agreed that the secretary of the expert group should compile a final document to become the 02 series of Regulation 100.

19.4.8 Inforcement of the battery safety requirements

For the 51st session of GRSP in May 2012 the final document of the RESS group became the official working document ECE/TRANS/WP.29/GRSP/2012/10. Before the GRSP session took place, the experts of the RESS group recognized that some improvements to the final document were necessary. Therefore, the chair of the group sent an informal document (GRSP-51-02) to Geneva amending the final document. In addition, a document with the text of the complete 02 series of Regulation 100 was sent as an informal document (GRSP-51-11) to Geneva.

Based on the above-mentioned documents the 51st session of GRSP adopted the proposed amendment of Regulation 100 and sent it to WP.29 for their November 2012 session for adoption.

During their November session, Working Party 29 at the UN in Geneva adopted the amendment of Regulation 100.

Considering that Transitional Provisions were agreed by WP.29 the 02 series of Regulation were planned as follows:

OptionalJuly 15, 2013
MandatoryJuly 15, 2016

19.5 Content of the legal requirements

The following main paragraphs and annexes were added to Regulation 100:

Paragraph 6.2 “Vibration” and Annex 8A: “Vibration Test”:

The purpose of this test is to verify the safety performance of the REESS under a vibration environment which the REESS will likely experience during the normal operation of the vehicle.

Paragraph 6.3 “Thermal shock and cycling” and Annex 8B:

The purpose of this test is to verify the resistance of the REESS to sudden changes in temperature. The REESS shall undergo a specified number of temperature cycles, which start at ambient temperature followed by high and low temperature cycling. It simulates a rapid environmental temperature change which a REESS would likely experience during its life.

Paragraph 6.4.1 “Mechanical Shock” and Annex 8C:

The purpose of this test is to verify the safety performance of the REESS under inertial loads, which may occur during a vehicle crash.

Paragraph 6.4.2 “Mechanical Integrity” and Annex 8D:

The purpose of this test is to verify the safety performance of the REESS under contact loads, which may occur during vehicle crash situation.

Paragraph 6.5 “Fire Resistance” and Annex 8E:

The purpose of this test is to verify the resistance of the REESS, against exposure to fire from outside of the vehicle due to, e.g., a fuel spill from a vehicle (either the vehicle itself or a nearby vehicle). This situation should leave the driver and passengers with enough time to evacuate.

Paragraph 6.6 “External Short Circuit Protection” and Annex 8F:

The purpose of this test is to verify the performance of the short circuit protection. This functionality, if implemented, shall interrupt or limit the short circuit current to prevent the REESS from any further related severe events caused by short circuit current.

Paragraph 6.7 “Overcharge Protection” and Annex 8G:

The purpose of this test is to verify the performance of the overcharge protection.

Paragraph 6.8 “Over-discharge Protection” and Annex 8H:

The purpose of this test is to verify the performance of the over-discharge protection. This functionality, if implemented, shall interrupt or limit the discharge current to prevent the REESS from any severe events caused by a too low SOC as specified by the manufacturer.

Paragraph 6.9 “Over-temperature Protection” and Annex 8I:

The purpose of this test is to verify the performance of the protection measures of the REESS against internal overheating during operation, and the failure of the cooling function if available. In the case that no specific protection measures are necessary to prevent the REESS from reaching an unsafe state due to internal over-temperature, this safe operation must be demonstrated.

Paragraph 6.10 “Emission.”

19.6 Outlook

During the seventh meeting of RESS the experts started to work out the requirements regarding “in-use” and battery safety for vehicles of category L.

The aim is that for the May 2014 session of GRSP a working document to amend regulation 100 will be finalized.

As soon as these requirements for category L vehicles are agreed by GRSP the RESS informal group will be suspended.

Appendix: abbreviations and symbols

1958 Agreement Legal framework wherein participating countries (contracting parties) agree on a common set of technical prescriptions and protocols for type approval of vehicles and components

1998 Agreement Legal framework with meta regulations called Global Technical Regulations (GTR). GTRs are without administrative procedures for type approval. Therefore countries with or without a type approval system are signatory Countries of the Agreement (e.g., EU, USA)

ACEA Association des Constructeurs Européens d’Automobiles (European Automobile Manufacturer Association)

CCFA Comité des Constructeurs Français d’Automobiles (French Automobile Association)

ECE Economic Commission for Europe

ELSA Informal group on electric safety

GRSP Groupe de travail de la sécurité passive (Working Group on Passive Safety)

RESS Group of interested experts on rechargeable energy storage systems (To indicate that the acronym stands for the informal working group, it is written only with one E)

REESS Rechargeable energy storage systems

Vehicles of category L Mopeds, motorcycles, motor tricycles, and quadricycles

Vehicle of category M Motor vehicles with at least four wheels designed and constructed for the carriage of passengers

Vehicle of category N Motor vehicles with at least four wheels designed and constructed for the carriage of goods

WP.29 World Forum for Harmonization of Vehicle Regulations

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