Electric vehicles now required to conform to ECE R100

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stuart mills
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Electric vehicles now required to conform to ECE R100

Postby stuart mills » Wed May 18, 2016 11:44 am

Sorry to be the bearer of bad news but I have just been copied in on a leaked memo that has been sent out to all VOSA officials regarding EV's They are now stating that any vehicle that has a battery conversion and subsequent application to change the V5 fuel type will have to conform with RESS. Rechargeable energy storage systems under ECE R100. The applicant wishing to change fuel type will then be asked to prove that it complies with the N1 category for the conversion as per the IVA manual. This is for commercial vehicles but apparently they have now decided to include cat M1 passenger cars under N1 if they have RESS.
The problem is cost. A test report is required that is overseen by VCA and conducted under laboratory conditions. Cost is around £6K I am told, this effectively kills the industry if enforced. I suspect that some V5 change of fuel applications will escape and others will be required to have an IVA test. IVA will not be registered until a CAT N1 report is provided. No details are available as to what the criteria is for an acceptable test. No regs have been made available to me. If anyone has any further info or needs any extra info please contact me at info@mevltd.co.uk

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skooler
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Re: Electric vehicles now required to conform to ECE R100

Postby skooler » Thu May 19, 2016 9:13 am

Bad news???

This is good news - It stops all of the poor quality conversions from taking place! Eventually one of those will do damage/cause harm and then the conversion industry really would be doomed.

FYI the battery doesn't need to be tested to UNECE Reg100. As a manufacturer you just need to state that it meets the requirements. We have just type approved a vehicle and are doing the same to another using exactly this approach.

Mike
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stuart mills
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Re: Electric vehicles now required to conform to ECE R100

Postby stuart mills » Fri May 20, 2016 9:10 am

Not correct now I am afraid. As of last week ALL cars with rechargeable energy storage systems will need laboratory testing to prove they comply with RESS ECE R100. Anyone converting may be pulled on this when they apply to change the V5. Anyone applying to IVA a vehicle will need to prove it complies with ECE R100.

I am confused that you see it as good news as your quotes are appear somewhat contradictory as below.

"This is good news - It stops all of the poor quality conversions from taking place! Eventually one of those will do damage/cause harm and then the conversion industry really would be doomed."

You then follow this with

"As a manufacturer you just need to state that it meets the requirements".

So you are saying that regardless if it meets requirements or not, you just state it does. No wonder they are tightening up!

stuart mills
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Re: Electric vehicles now required to conform to ECE R100

Postby stuart mills » Sun Jul 03, 2016 6:14 pm

Pleased to report this particularly demanding requirement has now been delayed until Nov 1st, see email below.




Government Security Classification - OFFICIAL

Thank you for your continued correspondence, without prejudice to the previous communications you've received I'd like to provide you with the following which will also be communicated to our engineers & technical support staff.

Today I have agreed with DfT a stay of implementation for Reg 100 within IVA, in part by pressing the industries’ case. Therefore, DVSA & DfT can guarantee that this legislation will not take effect in IVA before 1 November 2016. However, you should continue to make plans to obtain a suitable test report by 1 November 2016 as vehicles submitted after this date may be required to demonstrate full compliance as part of the application evidence.

DVSA propose to leave the N1 manual unchanged & to update the M1 manual imminently. This will allow stakeholders to familiarise themselves with the impending requirements ahead of implementation.

Notwithstanding all of the above our engineers will continue to make necessary & suitable assessments under the general construction section to ensure that any systems are safe, secure & installed without interference to other components under the requirements of IVA.

Product Specialist (Specialist Vehicle Tests and Approvals)
Driver and Vehicle Standards Agency
Phone: +44 (0) 300 123 9000
cid:_4_08E772F808E7708C0042C1CF80257FA4


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