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 DÖRING
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 traffic‖1. 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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GCSFP Study - Regulations on a electric vehicle infrastructure for road traffic
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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GCSFP Study - Regulations on a electric vehicle infrastructure for road traffic
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 M ARKET ....................................................................................... 106
2
1.6.1
European and German Law........................................................................................... 106
1.6.2
Chinese Law .................................................................................................................. 107
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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GCSFP Study - Regulations on a electric vehicle infrastructure for road traffic
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 (Communauté Européenne) ...............................................................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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GCSFP Study - Regulations on a electric vehicle infrastructure for road traffic
List of abbreviations / Terms and Definitions
Active driving possible
vehicle mode when application of pressure to the accelerator pedal (or
mode
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 für 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
Electric
braking system which, during deceleration, provides for the conversion of
vehicle kinetic energy into electrical energy.
regenerative
device which modulates the action of the electric regenerative braking
braking control
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
system that generates and provides electric energy for electric propulsion
conversion system
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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GCSFP Study - Regulations on a electric vehicle infrastructure for road traffic
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
alternating current (AC) or direct current (DC) electric power supply
supply
outside of the vehicle
GB
Guóbiāo – mandatory national standard in China
GB/T
Guóbiāo tuījiàn – 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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GCSFP Study - Regulations on a electric vehicle infrastructure for road traffic
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 driver‘s 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
resistance
isolation
monitoring
device which monitors the isolation resistance between the high voltage
buses and the electrical chassis.
system
Open
type
traction
liquid type battery requiring refilling with water and generating hydrogen
battery
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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GCSFP Study - Regulations on a electric vehicle infrastructure for road traffic
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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GCSFP Study - Regulations on a electric vehicle infrastructure for road traffic
Working voltage
highest value of an electrical circuit voltage root meansquare (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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GCSFP Study - Regulations on a electric vehicle infrastructure for road traffic
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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GCSFP Study - Regulations on a electric vehicle infrastructure for road traffic
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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GCSFP Study - Regulations on a electric vehicle infrastructure for road traffic
The following team was responsible for the study:
Germany
Project leader:
EnergyAgency.NRW
Haroldstr. 4, D-40213 Düsseldorf; Germany, www.energieagentur.nrw.de
Stefan GARCHE, Tel: +49 211 - 866 42 23; garche@energieagentur.nrw.de
Alexandra WOLFF; Tel: +49 211 866 42297, wolff@energieagentur.nrw.de
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 DÖRING, + 49-731-9530-602, harry.doering@zsw-bw.de
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, gjq@catarc.com.cn
Jingjing LIANG, liangjingjing@catarc.ac.cn
Ping YAN, yanping@catarc.ac.cn
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GCSFP Study - Regulations on a electric vehicle infrastructure for road traffic
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 world‘s
largest producer of electric vehicles. The Renault-Nissan Alliance works together with
China‘s MIIT to help set up battery recharging networks throughout the city of
Wuhan, the pilot city in the country‘s 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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GCSFP Study - Regulations on a electric vehicle infrastructure for road traffic
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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GCSFP Study - Regulations on a electric vehicle infrastructure for road traffic
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
3
4
5
6
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. 1–160.
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)
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)
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
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
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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GCSFP Study - Regulations on a electric vehicle infrastructure for road traffic
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 EVrelevant 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
8
9
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
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.
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/s² (or N1 6 m/s²). 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/s² (N1 vehicles 6
10
11
12
ECE-R 10/03 (EU O.J.) (final) Approval of vehicles with regard to electromagnetic compatibility
E/ECE/324; E/ECE/TRANS/505 Addendum 12: Regulation No. 13 } Rev.1/Add.12/Rev.6 ; 14 January 2008
ECE/TRANS/WP.29/2007/3; Proposal for draft amendments to Regulation No. 13-H (Harmonized Braking)
9
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m/s²). 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
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
14
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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
18
19
20
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
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. 1–16.
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. 37–74.
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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/s² (or N1 6 m/s²). 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/s² (N1 vehicles 6 m/s²). 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
22
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. 24–37.
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 OEM‘s. 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.
15–24.
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 approval
27
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
28
Source: AutoEMC.net
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. 27–48.
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. 21–40.
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. 23–24.
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. 1–24.
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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
34
35
36
37
38
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. 16–20.
See fn. 13
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. 36–45.
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
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. 10–19.
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. 32–46.
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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 hydrogenpowered 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 (Communauté Européenne)
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 EGFGV43. 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
42
43
44
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
See fn. 56
Verordnung über die EG-Genehmigung für Kraftfahrzeuge und ihre Anhänger sowie für Systeme, Bauteile und
selbständige technische Einheiten für diese Fahrzeuge (EG-Fahrzeuggenehmigungsverordnung – EGFGV vom 21.
April 2009 (BGBl. I S. 872, 873)"
Straßenverkehrs-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
(新能源汽车生产准入管理规则) 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
46
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.
《新能源汽车生产企业及产品准入管理规则》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 newenergy 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
1
2*
II
3
4
5*
Manufacturing capability and conditions
Manufacturer shall have necessary production site, storage site or facilities,
as well as appropriate, neat production environment.
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.
Design and development capability
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.
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 selfproduced 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.
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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6*
7
8
III
9
10
11
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).
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.
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.
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 customer‘s consent shall be
obtained; in addition, the requirements for conformity of production and
product traceability shall be met.
Capability in assuring conformity of production
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.
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.
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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12
13*
IV
14
15
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.
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.
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 manufacturer‘s 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.
Product sales and after-sales services
It is required that the complete, documented management systems on sales
and after-sales services be established, including personnel training
(manufacturer‘s 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 aftersales service network shall apply to the products of the mature stage only.
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
V
17
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.
Components purchase management
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 newenergy 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.
1
Standard number
GB/T 4094.2-2005
Standard name
Marks of Controllers, Indicators and Signal Devices of
Electric Vehicles
This standard specifies basic requirements for electric
vehicle, regarding symbols for controls, indicators and telltales, and colours for tell-tales. (based on ISO
2575:2000/Amd.4:2001; JEVS Z 804:1998)
Part One of Safety Requirements for Electric Vehicles:
Vehicle-borne Energy Storing Device
2
3
47
48
GB/T 18384.1-200147 Part Two of Safety Requirements for Electric Vehicles:
Function Safety and Failure Emergency Protection
GB/T 18384.2-200148
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 environment.
This standard applies to electric passenger vehicles whose
max. working voltage of the on-board circuit is less than
GB18384.1-2001 (电动汽车 安全要求 第1部分:车载储能装置) Part One of Safety Requirements of Electric Vehicles:
Vehicle-borne Energy Storing Device
GB18384.2-2001 (电动汽车 安全要求 第2部分:功能安全和故障防护) Part Two of Safety Requirements of Electric
Vehicles: Function Safety and Failure Emergency Protection
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660V (AC) or 1000V (DC) (according to GB 156-1993), and
to electric commercial vehicles whose max. design total
mass is not more than 3,500kg. Electric vehicles whose
max. design mass is more than 3,500kg can refer to this
standard.
The standard does not apply to the guide assembly,
maintenance and repair of electric vehicle.
(based on ISO/DIS 6469.1:2000)
4
GB/T 18384.3-200149
5
The Test Methods for the Power Performance of Electric
GB/T 18385—200550 Vehicles
This standard is based on ISO 8715:2001.
GB/T 18386—2005
The Test Methods for the Energy Consumption Rate and
Driving Range of Electric Vehicles
This Standard sets out the procedures for testing the energy
consumption and range of battery electric vehicles. It applies
to battery-powered electric vehicles, which can be followed
as a reference by normal electric three-wheel motorcycles.
(based on ISO 8714:2002)
7
GB/T 18387—2008
Limits and Test Method for Magnetic and Electric Field
Strength from Electric Vehicles, Broadband, 9 kHz to 30
MHz (30 MHz ~ 1,000 MHz is covered by GB 14023)
This Standard sets out the limits and test method for
radiated emissions of magnetic and electric field from EV
over the frequency range of 9 kHz ~ 30 MHz, as well as the
limits and test method for conducted emissions over the
frequency range of 450 kHz ~ 30 MHz. Conducted emission
measurements in this Standard are applicable only to
battery-charging systems which utilize a switching frequency
above 9 kHz, are mounted on the vehicle, and whose power
is transferred by metallic conductors. Conducted emissions
requirements apply only during the charging of the batteries
from AC power lines. Conducted and radiated emissions
measurements of battery-charging systems that use an
induction power coupling device are not covered by this
Standard.
(based partly on SAE J551-5)
8
GB/T 18388—2005
The Type approval Test Procedures for Electric Vehicles
9
GB/T 18488.1-2006
6
Part One of Motors and Controllers of Electric Vehicles:
Technical Conditions
Part Two of Motors and Controllers of Electric Vehicles:
49
GB18384.3-2001 (电动汽车 安全要求 第3部分:人员触电防护) Part Three of Safety Requirements of Electric
Vehicles: Personnel Electric Shock Emergency Protection
50
GB 18385-2005 (电动汽车动力性能试验方法)
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10
11
GB/T 18488.2-2006
Testing Methods
This part specifies the duty, quota, environmental condition,
technical requirements, inspection test items and type
approval test and so on of the electrical machines and
controllers for electric vehicles. This part applies to the
electrical machines and controllers for electric vehicles. If
specially requested, the user and the manufacture may
specify the requirements in special technical agreement.
GB/T 19750-2005
Type approval Test Procedures of Hybrid Power Electric
Vehicles
This standard series gives special specification for M class
HEV defined in GB/T 19596.This Standard specifies the
implementation conditions, test items, test methods,
pass/fail judgment criteria and test report content for the
engineering approval evaluation tests of new products for
hybrid electric vehicles. A catalogue of compulsory
standards is annexed and the Annex A and B are normative.
The Safety Requirements of Hybrid Power Electric Vehicles
This standard specifies the special safety specification for
class of M class HEV
12
13
GB/T 19751-2005
GB/T 19752-2005
This standard applies to class of M HEV whose max.
working voltage of the on-board circuit is less than 660V
(AC) or 1000V (DC) (according to GB 156-1993). The other
classes of hybrid electric vehicle can refer to the standard.
For EMC the vehicles shall meet the requirements of GB/T
18387 as well as GB 14023, GB18655 and GB/T 17619.
(based on UNECE-R 100, ETA HTP001)
The Testing Method for the Power Performance of Hybrid
Power Electric Vehicles
This Standard specifies the methods for testing the power
performance of M and N class HEV as defined in GB/T
15089.
(based on European Standard EN 1821-2)
The Testing Methods for the Energy Consumption of Lightduty Hybrid Power Electric Automobiles
14
GB/T 19753-2005
This standard specifies the test methods for the energy
consumption of light-duty hybrid electric vehicles equipped
with positive-ignition engine or compression-ignition engine.
The rules for electric drive and off-charging are also
normative.
This standard applies to the categories of M1, M2 and N1
HEV equipped with ignition engine or compression engine
and with a maximum mass not exceeding 3,500 kg.
This standard is based on UNECE R101.01 and EN 19862–2001 and Annexes A, B and C are normative.
15
GB/T 19754-2005
The Testing Methods for the Energy Consumption of Heavyduty Hybrid Power Electric Vehicles
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This Standard specifies the test methods for the energy
consumption of heavy-duty HEVs on chassis dynamometer
or on road. It applies to heavy-duty HEVs with the gross
vehicle mass (GVM) of more than 3,500kg; however, it
does not recommend conduct of the energy consumption
test on heavy-duty HEVs where air-conditioners are used.
GB/T 19755-2005
The Measuring Methods for the Pollutant Emission of Lightduty Hybrid Power Electric Vehicles
This standard specifies the measuring methods for exhaust
pollutants after a cold start, emissions of crankcase gases,
evaporative emissions from light-duty HEVs with positiveignition engine and measuring methods for exhaust
pollutants after a cold start from light-duty HEVs with
compression-ignition engine.
This standard applies to the light-duty HEVs equipped with
positive-ignition engine or compression-ignition engine and
with a minimum design speed exceeding 50 km/h.
HEVs are classified in off-vehicle chargeable (OVC) and
non–off-vehicle chargeable (NOVC) and w/o manual
selection function of driving mode.
(based on amendment of 05 series for UNECE-R 83)
GB/T 19596-2004
Terminology of Electric Vehicles
This Standard sets out the terminology and definitions
relating to electric vehicles (not FCEV). It applies to the
complete vehicles, electric machines and controllers,
batteries, and chargers of electric vehicles.
(based on ISO 8713 and SAE J1715)
18
GB/T 19836-2005
Instruments for Electric Automobiles
This Standard sets out the classification of and applies to
the instrumentation for electric vehicles, as well as the
general requirements thereof.
(based on IEC 784:1984)
19
GB/Z 18333.2-2001
Zinc Air Batteries for Electric Road Vehicles
20
QC/T 741-2006
Electric Double-layer Capacitor for Vehicles
21
QC/T 742-2006
Lead-acid Battery for Electric Automobiles
22
QC/T 743-2006
Li-ion Battery for Electric Automobiles
23
QC/T 744-2006
Metal Hydride Nickel Battery for Electric Automobiles
16
17
If the relevant new-energy vehicle is in the technical stage of the starting and
development period, according to Art. 13 the following data should be submitted:
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- after-sales service commitments (including including product quality assurance
commitment; the construction of an after-sales service network; the training of
after-sales service staff and product users; the items and contents of after-sales
services; the provision of spare parts and the time limit of quality assurance; the
feedback of the problems discovered in process of after-sales services, the
recovery of finished vehicles and parts and components (e.g. battery); claim
settlement; the countermeasures for serious problems occurring with respect to
such aspects as product quality, safety and environmental protection, etc.)
- the description of the proposed sales territories, and the approval documents
concerning model operation regions and scopes provided for by the provincial
department in charge of industry and information technology in the place where the
product is used.
- agreements signed with the end-users; the vehicle operation management
regulations of end-users and the description of the quantity of use (only applicable
to products in the starting period).
Adopting different management methods to products in different technical stages.
Art. 7 states:
- small scale production can only be carried out for products in the starting period,
and model operation can only be carried out in or under the approved regions,
scopes, time limit and conditions, and a real-time monitoring should be carried out
to establish the operating status of all products.
- batch production can be carried out for products in the development stage. They
can be sold and used only in or under the approved regions, scopes, time limit and
conditions, and a real-time monitoring should be carried out to establish the
operating status of at least 20% of the sales products.
- the management means of the vehicle manufacturer and the product proclamation
(hereinafter referred to ―the proclamation‖) of products in the mature period is the
same as that for conventional vehicle products, and their sales and use are also
the same as that of conventional vehicle products.
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The concrete division of technical stages is listed in Appendix 1of Technical Stage
Division Table of New Energy Vehicles (applicable prior to Dec. 31, 2010)
Table 3: Technical Stage Division Table of New Energy Vehicles
Serial
number
Product
category
Type of energy storing device
Technical
stage
1
Li-ion power battery
2
Metal hydride nickel power battery
Mature
Lead-acid battery
Mature
Zinc air battery
Starting
5
Super capacitor
Development
6
Hydraulic/pneumatic energy storing device
Development
7
Li-ion power battery
Development
8
Metal hydride nickel power battery
Development
Lead-acid battery
Development
3
4
9
10
Hybrid
passenger
vehicles
Hybrid
commercial
vehicles
Development
Zinc air battery
Starting
11
Super capacitor
Development
12
Hydraulic/pneumatic energy storing device
Development
13
Li-ion power battery
Development
14
Metal hydride nickel power battery
Starting
Lead-acid battery
Mature
Zinc air battery
Starting
17
Super capacitor
Starting
18
Li-ion power battery
Starting
Metal hydride nickel power battery
Starting
Lead-acid battery
Mature
Zinc air battery
Starting
Super capacitor
Starting
15
16
19
20
21
Purely electric
passenger
vehicles
Purely electric
commercial
vehicles
22
23
24
FC passenger
car/commercial Fuel cell
vehicles
Hydrogen
powered
vehicles
Starting
Starting
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Notes:
1. The division of technical stages is chiefly based on the categories of energy storing devices;
2. As to the determination of the technical stages of vehicles adopting the scheme of electric
power (mixing), the lower technical stage in energy storing device shall prevail. For example, as
to the purely electric commercial vehicles adopting the scheme of Li-Ion power battery and super
capacitor electric power (mixing), the technical stage is determined as the starting period. As to
passenger cars/commercial vehicles adopting the scheme of fuel cell and super capacitor electric
power (mixing), its technical stage shall be determined as starting period.
3. The Li-Ion power battery listed in the table includes two types: manganic acid lithium-type LiIon power battery and iron phosphate lithium-type Li-Ion power battery. If an enterprise applies for
products adopting any other type of Li-Ion power battery, it needs to ask the expert committee to
determine the technical stage.
Beside this new Chinese standards on BEV and HEV more are in formulation or have
been drafted and will be adopted (see Annex II).
In Standard GB/T 18386-2007, the test procedures under running mode apply to
vehicles of categories M1 and N1. The test cycles are consistent with those specified
in GB 18352.1.
Figure 7: Normative Chinese Test Cycles referring to Annex A of GB 18386
The Certification and Accreditation Administration (CNCA) of the People's Republic of
China was created in 2003 and has designated several certification bodies that are
authorized to accept applications and evaluate products under the Regulations for
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Compulsory Certification51, which empower the authority to request the type
approval. This is the legal basis for CCC certification.
The vehicle has to be approved as well by the emission authorities. For the whole
China mainland this is the Ministry of Environmental Protection of the P.R.C. The
Beijing area is subject to the Beijing Environmental Protection Agency (Beijing EPA).
In the mandatory product list it is to find electrical wires and cables
For imported vehicles, the certification has to be approved by CNCA, which is part of
the State General Administration for Quality Supervision and Inspection and
Quarantine (AQSIQ) The China Quality Certification Centre (CQC) is designated by
CNCA to process CCC mark applications and defines the products that need CCC.
For vehicles produced in China, the vehicle has to be approved by the Ministry of
Industry and Information Technology (MIIT) as well. Like the CNCA, the MIIT also has
its own agency performing the day-to-day work, which is called the China Vehicle
Technology Service Center (CVTSC).
Figure 8: China compulsory product certification (CCC) mark for safety (s)
The CCC mark can be given for safety (s), for fire (f), for electromagnetic
compatibility (EMC) or combined (s&e).
51
Regulations for Compulsory Certification 《中国强制认证标志》
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1.1.4 Legal Comparison
In general, provisions for vehicle permission are approximately similar in China and
the EU. Both parties modify and expand the legal basis for the approval of EVs.
The numbers of Chinese Regulations related to EVs are higher than in Europe, but it
should be said that Chinese Standards are very specific while EC Regulations cover
the whole topic at once. A glance at the page of the regulations will help to underline
this statement. Direct comparison with some of these standards was not possible as
they have not yet been published. Some of Chinese Standards referring to EVs are
based on UNECE Regulations or ISO. It is to be expected that the new standards will
also be based on existing UNECE-R, ISO and DIN regulations.
A list of the Chinese Standards in modification or development is attached in Annex II.
A central regulation for Europe regarding the approval of EVs is UNECE-R 100,
amendment series 01, ―Uniform Provisions Concerning the Approval of Vehicles with
regard to Specific requirements for the Electric Powertrain‖. Combined with the
Council Decision on compulsory application the new regulation sets out main safety
requirements for the approval of vehicles equipped with an electric powertrain. All
electric vehicles marketed in Europe have to be constructed according to a common
safety standard and thereby protecting vehicle users from coming into contact with
high-voltage parts of the vehicle.
Chinese safety requirements for HEVs including high-voltage are based on UNECER 100 but dated before 2005 when it was called ―Uniform Provisions Concerning the
Approval of Battery Electric Vehicles With Respect to the Special Requirements for
Construction and Safety―. This means the actual draft of UNECE-R 100 regarding the
electric powertrain is not used directly but this standard is already in the process of
being modified and it is expected that the draft will be taken into consideration. In
China, lots of drafts of national standards for EVs regulate safety requirements for the
power system and powertrain focuses on electricity, emergency protection and
collision.
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High voltage is defined differently. In China high voltage in an on-board circuit is 60 –
1000 V (DC) while in the EU 60 - 1500 V (DC) is used. This means for China 660 V
(AC) and for Europe 1000 V (AC). This should be kept in mind as the great difference
in maximum voltage is not unimportant.
The Chinese definition of light-duty vehicles corresponds with European definition of
passenger cars. In China a minimum speed of 50 km/h is necessary for these
vehicles while Europe requires only 25 km/h.
The test procedures for energy consumption are very similar. The test cycle is
identical; both parties use the New European Driving Cycle. Pollutant emissions are
checked in an almost identical fashion because the same basis is used (UNECE-R
83). The specifications of PHEVs are also taken into consideration.
Like German and European Law, China established several funding facilities through
which it is possible to encourage the development of new energy automobiles. In
China, the encouragement of clean-energy vehicles is a kind of national law, written
down in several ―Rules52‖. Europe and China have been engaged in establishing
legal measures to facilitate the production and marketing of new-energy vehicles.
The purpose of European (Framework) Directives and the 2009 Rules on Access for
New-energy Vehicle Manufacturers is similar. To advance technical progress on newenergy vehicles and promote energy conservation different measures are
implemented.
Both parties have certification regulations for consumer products and parts of them
are mandatory.
52
E.g.: Administration Rules on Access to the Production of New Energy Vehicles.
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1.2 Use of Vehicles, Power Purchase
1.2.1 Consumer information regarding environment, climate and energy policy
1.2.1.1 European Law
For reasons of market transparency the consumers must be informed about the
products as well as possible. Following UNECE-R 100 the purpose of Directive
1999/94/EC53 regarding the availability of consumer information on fuel economy and
CO2 emissions in respect of the marketing of new passenger cars is to ensure that
information relating to the fuel economy and CO2 emissions of new passenger cars
offered for sale or lease in the Community is made available to consumers in order to
enable consumers to make an informed choice.
Figure 9: Request for information on fuel consumption, specific CO2 emissions and power
consumption (German)
53
Directive 1999/94/EC of the European Parliament and of the Council of 13 December 1999 relating to the availability
of consumer information on fuel economy and CO2 emissions in respect of the marketing of new passenger cars;
Last amended by 2003/73/EC of 24 July 2003 amending Annex III to Directive 1999/94/EC
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This kind of energy label is already known from consumer goods like refrigerators,
freezers and washing machines. In addition to that, information on the annual tax and
the average annual expenditure for energy costs (fuel and electric power) must be
available as an improved information base for the customer purchase.
Another directive to promote energy end-use efficiency is Directive 2006/32/EC54.
The purpose of the Directive is to make the final consumption of energy more
economic and efficient. Electricity and transport fuels are energy according to the
terms of Art. 1. Annex VI to the Directive contains measures that the public sector can
adopt, including the purchase of energy-efficient equipment and vehicles. MSs may, if
they so wish, set up financing mechanisms or adopt other measures to promote more
efficient end-use of energy. The promotion of energy-efficient vehicles and modal
shifts to less energy-consuming modes of transport are listed in Annex III as
examples of eligible energy efficiency improvement measures.
To compare different vehicle fuels, measures concerning the promotion of clean and
energy-efficient road transport vehicles are laid down in Directive 2009/33/EC55,
which has to be transposed into national law by December 4th 2010, Art. 11. The aim
of the Regulation is the market development of clean and efficient vehicles to
improve the contribution made by the transport sector to the environment, climate
and energy policy of the EU. The Directive applies to contracts for the purchase of
road transport vehicles entered into by contracting authorities and contracting entities
and operators with the purpose of discharging public service obligations under a
public service contract. MSs must ensure that they take into account the operational
lifetime energy and environmental impacts which include energy consumption,
emissions of CO2 and pollutant emissions. Fuel consumptions are expressed in
MJ/km. A table showing the different energy content of motor fuels is annexed.
54
55
Directive 2006/32/EC of the European Parliament and of the Council of 5 April 2006 on energy end-use efficiency
and energy services and repealing Council Directive 93/76/EEC
Directive 2009/33/EC of the European Parliament and of the Council of 23 April 2009 on the promotion of clean and
energy-efficient road transport vehicle
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In the methodology for the calculation of operational lifetime costs there is no explicit
data for electric vehicles. In regard to this Directive 2009/33/EC BEVs have the best
results in terms of the absence of emissions (costs). The lifetime mileage of
passenger cars is set to 200,000 km for conventional cars. The lifetime mileage and
costs of traction batteries are not defined.
To support low-emission vehicles with more than 3.5 t Directive 2005/55/EC56, last
amended by Directive 2005/78/EC and 2006/51/EC, defines emission and particulate
limits for diesel and gas vehicles like duty vehicles and buses. Vehicles called EEVs
are listed as having the lowest emissions. MSs can support the procurement. This
Directive could be relevant for low-emission parallel hybrid buses.
1.2.1.2 German Law
End users who want to buy a vehicle need information about the relevant vehicle
data like price, efficiency, consumption, range, size, tax, etc. Information on
consumption of energy and other essential resources, as well as CO2 emissions and
additional information (usage labelling) have to be outlined on sale signs and in
commercials, § 1 Energy Consumption Labelling Law (EnVKG) in conjunction with
Vehicle Energy Consumption Labelling Ordinance (Pkw-EnVKV), based on Directive
1999/94/EC.
At present a first Draft Regulation57 amending Pkw-EnVKV (Pkw-Energieverbrauchskennzeichnungsverordnung – Pkw-EnVKV) concerning consumer information on fuel
consumption, CO2 emissions and now electric power consumption of new passenger
cars is under negotiation and will be presented to the Federal Council of Germany in
January 2011. An energy label is to be introduced on which the specific efficiency
value of the vehicle is identified and also, with a view to consumer purchase,
56
57
Directive 2005/55/EC of the European Parliament and of the Council of 28 September 2005 on the approximation of
the laws of the MSs relating to the measures to be taken against the emission of gaseous and particulate pollutants
from compression-ignition engines for use in vehicles, and the emission of gaseous pollutants from positive-ignition
engines fuelled with natural gas or liquefied petroleum gas for use in vehicles
Verordnung über Verbraucherinformation zu Kraftstoffverbrauch, CO2-Emissionen und den Stromverbrauch neuer
Personenkraftwagen (Pkw- Energieverbrauchskennzeichnungsverordnung – Pkw-EnVKV); Draft of Oktober 13 2010:
http://www.bmwi.de/BMWi/Redaktion/PDF/P-R/pkw-envkv-aenderung-entwurf-oktober2010,property=pdf,bereich=bmwi,sprache=de,rwb=true.pdf
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GCSFP Study - Regulations on a electric vehicle infrastructure for road traffic
relevant information is given. Information on the annual tax and energy cost (fuel and
electric power) must be available as described above.
With regard to the development of electric vehicles (BEVs and HEVs), in future the
electric power consumption must also be reported, although as with conventional
vehicles the CO2 emissions of the pre-power chain (here from electricity and in
relation to the electricity mix) are not included. Since there is currently no market
price for the electric power of BEVs and PHEVs the current costs must already be
included as text on the energy label.
2009/33/EC has to be transposed into national law by 4 December 2010. With the
German National Action Plan for Renewable Energy, the Federal Government
reiterated on 4 August 2010 its goal of almost doubling the gross share of renewable
energies from the current 10% by 2020. In the transport sector in particular it is
expected that the share of renewable energies will increase in the same period to
13.2%.
1.2.1.3 Chinese Law
In China there exists a rule governing consumer information regarding environment,
climate and energy policy called Management Regulation for the Labeling of Fuel
Consumption of Light-duty Vehicles. As the name says, it is only for light-duty
vehicles and not a provision for new-energy vehicles. This Regulation applies to M1,
M2 and N1 vehicles sold in China with gasoline or diesel as fuel, with the greatest
designed total mass of no more than 3,500 kg (General principles, art 2). This
regulation was formulate specifically to strengthen management of the energy
conservation of vehicle products and implement the requirements of such documents
as ―The Circular of the State Council on Further Strengthening the Work of Oil and
Power Conservation‖ (Guo Fa No. [2008]23) and ―The Development Policy of
Automobile Industry, and to ensure the smooth enforcement of ―Labeling of Fuel
Consumption of Light-duty Vehicles‖ (GB 22757-2008)58. Vehicle manufacturers and
58
GB 22757-2008 (轻型汽车燃料消耗量标识)
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GCSFP Study - Regulations on a electric vehicle infrastructure for road traffic
import export distributors should ensure that all their vehicle products are pasted with
a Vehicle Fuel Consumption label when sold (Art. 3).
Figure 10: Automobile Fuel Consumption Labels, Normative Annex
Vehicle Fuel Consumption labels should be printed and pasted by the vehicle
manufacturer or import vehicle distributor according to the requirements of
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GCSFP Study - Regulations on a electric vehicle infrastructure for road traffic
GB 22757-2008 and conform to national standard requirements. Type M1, M2 and
N1 vehicles mentioned in the Regulation refer to GB/T 15089－2001. ―Vehicle
manufacturers‖ mentioned in the Regulation refer to vehicle manufacturers having
obtained the license of producing vehicle products and listed in the Vehicle
Manufacturer and Product Proclamation. ―Import vehicle distributors‖ in the
Regulation refer to import vehicle distributors who have obtained the license of
importing vehicle products. ―The testing institutions appointed by the MIIT in the
Regulation refer to the testing institutions undertaking the inspection of vehicle
products in the Vehicle Manufacturer and Product Proclamation. The Regulation is to
be enforced as of 1 January 2010 (Art. 20).
Vehicle manufacturers or import vehicle distributors should identify the fuel
consumption data applied according to ―The Test Methods of Fuel Consumption of
Light-duty Vehicles‖ (GB/T 19233-2008) and tested and confirmed by the testing
institution appointed by the MIIT (imported vehicles can be tested and confirmed by
the testing institution appointed by the quality check department). Article Eight: The
identification of date of commencement of use: The date of commencement of use
Vehicle Fuel Consumption label is the manufacturing date printed on the Ex-factory
Quality Certificate of Finished Automobile or the date of of submission of the Vehicle
Fuel Consumption label to the MIIT for registration. Article Nine: The identification of
registration number;
(I) Home-made vehicles take the vehicle identification code (VIN) or the vehicle
model of Vehicle Manufacturer and Product Proclamation plus suffix a identification
number, which should be capable of identifying the different oil consumption of the
same car model, and the numbering rules must be independently determined by the
enterprise;
(II) Imported vehicles take the number of the vehicle consistency certificate. Article
Ten: The identification of other contents must conform to the requirements of
GB22757-2008.
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Vehicle manufacturers or import vehicle distributors must submit the samples of
Vehicle Fuel Consumption Label of different oil-consumption vehicle types to the MIIT
(Equipment Industry Department) for registration before the market sale of vehicle
products. The MIIT must publicize the indexes of fuel consumption of light-duty
vehicles at regular intervals (Art. 12). If there any of the following circumstances is
discovered or assumed and verified, then a penalty will be levied according to
relevant national laws and statutes on the basis of the severity of the circumstance:
(I)
The mark is not visible or pasted according to the relevant regulations;
(II) The Vehicle Fuel Consumption Label is not submitted for registration
according to regulations;
(III) The labeling contents are inconsistent with those of the registration.
According to the new Regulation, passenger cars and light-duty commercial vehicles
with the largest designed total mass of less than 3,500 kg must bear a Vehicle Fuel
Consumption label when sold, and should be identified with the fuel consumption on
the basis of one of the three working conditions urban area, suburb and
comprehensive as determined by the testing institution appointed by the government
according to the uniform national standard. When purchasing a car, a consumer can
choose an oil-saving car suitable as his/her own means of travel according to his/her
own car use condition. In addition to the vehicle type produced by domestic vehicle
enterprises, all imported vehicle products must bear the Vehicle Fuel Consumption
Mark. As reported, this practice has been adopted by many countries worldwide. It
requires vehicle manufacturers to explain to the consumers the steering oil
consumption and comprehensive oil consumption of this type of vehicle and the
lowest and the highest oil consumption of this type of vehicle in urban areas and
suburbs respectively on the marks.
The MIIT hopes to offer fuel consumption information to consumers by setting up the
labeling system of vehicle fuel consumption, guide consumers to purchase energyefficient vehicles with low oil consumption, induce vehicle manufacturers to develop
more energy-efficient vehicles, and boost the development and progress of vehicle
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GCSFP Study - Regulations on a electric vehicle infrastructure for road traffic
energy-saving technology, thus playing an important role in accelerating the industrial
restructuring of Chinese vehicle industry and promoting energy conservation and
emission reduction.
Furthermore, the Law on Prevention and Control of Air Pollution encourages the
promotion of new energy vehicles (Art. 34). Local authorities have to care for the air
quality in their regions. Part 4 of this law regulates the support of clean transport.
Authorities are empowered to encourage the production and use of vehicles operated
by clean energies. National benchmarks may not be overrun, as is mentioned in Art.
32.
The Renewable Energy Program is another instrument to encourage the production
of fuel cell vehicles. The chapter ―Priority Areas‖ emphasizes new types of fuel cells
and the application of fuel cells in cars. Also notable is the Reorganisation and
Revitalisation Plan of the Automobile Industry (汽车产业调整和振兴规划细则). It
focuses on the combination of the transformation of traditional products and
promotes new-energy vehicles. It also includes planning objectives such as the scale
of electric vehicle production and marketing, implements the strategy for new energy
vehicles and the use of them.
1.2.2 Taxes, Fees and Subsidies
1.2.2.1 European Law
Regarding the purchase of EVs, value-added taxes are to be paid. Directive
2006/112/EC determines a minimum percentage in the amount of 15 %, e.g. currently
Germany´s value-added tax is 19 %. Exemptions for clean energy cars are not
provided for at the moment.
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GCSFP Study - Regulations on a electric vehicle infrastructure for road traffic
The use of certain infrastructures, especially motorways is also to be considered.
Directive 1999/62/EC59, last amended by Directive 2006/38/EC, regulates mandatory
motor vehicle fees and tolls for heavy goods vehicles. Although heavy goods vehicles
are not that relevant for BEVs, MSs charge motor-vehicle taxes for all types of
automobiles, with the exception of Poland and France.
―Fuel costs‖ depend on the Directive 2003/96/EC as it regulates a common minimal
tax rate for energy products and electricity. Electricity falls within CN code 271660.
Electricity as fuel can be exempted from tax by the MSs only for rail and tram
transport (Art. 15 I e).
72/166/EEC61
in
combination
with
Directives
84/5/EEC,
90/232/EEC
and
2005/14/EC, last amended by 2005/14/EC62, regulates the duty for a motor
insurance63 in Europe. No vehicle, including all kinds of EVs, is allowed to take part
on the public road traffic without a motor insurance for damage to others.
Overview of subsidies and incentives of EU MSs
The EU has no uniform rule on whether and how electric vehicles will be funded. The
right to levy taxes is a matter for each MS. At the moment some MSs support the
market entry of BEVs and HEVs with financial or other support64:
Austria grants exemptions from the single consumption tax and the motor vehicle
tax, which is around 2,000 EUR. Also discounts of > 1,100 EUR or 15% on the
vehicle price are given.
59
60
61
62
63
64
1999/62/EC on the charging of heavy goods vehicles for the use of certain infrastructures
CN= combined nomenclature of Directive 2031/2001/EC
72/166/EEC of 24 April 1972 on the approximation of the laws of MSs relating to insurance against civil liability in
respect of the use of motor vehicles, and to the enforcement of the obligation to insure against such liability
amending Council Directives 72/166/EEC, 84/5/EEC, 88/357/EEC and 90/232/EEC and Directive 2000/26/EC of the
European Parliament and of the Council relating to insurance against civil liability in respect of the use of motor
vehicles
Insurance against civil liability in respect of the use of motor vehicles, also known as motor liability insurance, motor
third party liability insurance or automobile third party insurance
Reference if necessary: Mercedes B 180 with 148 g/km CO2 emission
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GCSFP Study - Regulations on a electric vehicle infrastructure for road traffic
Finland is considering exemptions of the governmental car-related tax incomes.
In Denmark, petrol cars are taxed at 180% + 25%, however, EV cars up to 2t total
weight are only taxed at 25%. Free parking is also offered to EVs in Copenhagen and
other cities, and there is free charging at some parking spaces.
France pays 2,000 EUR for HEVs with less than 140 g/km CO2 emission and 5,000
EUR for all vehicles with less than 60 g/km. Commercial vehicles are also exempt
from company car tax (1,250 EUR/a).
Germany does not provide governmental sales support for BEVs at the moment.
Ireland grants 50% rebate on the Vehicle Registration Tax (VRT) which normally
amounts to 25% of the market value of a car. Incentives towards the purchase of
BEVs have been announced, including a 5,000 EUR capital grant, and HEVs get
2,500 EUR. Electricity supplied from new high-speed recharging points on interurban
routes will be free initially.
Italy grants private BEVs 1,500 EUR subsidy and commercial vehicles 4,000 EUR. In
addition there is a progressive discount on road tax in the first five years.
In the Netherlands, the Vehicle Registration Tax (VRT), payable when a car is sold
to its first buyer, can earn the owner of an HEV a discount up to 6,000 EUR.
Norway grants exemptions for BEVs from car taxes including VAT. Owners are free
from road tolls, parking fees and are allowed to use bus and taxi lanes for all BEVs.
In Portugal BEVs do not pay circulation tax and are exempt from taxes on
acquisition price until 2012. The first 5,000 electric vehicles sold in Portugal are
funded to the amount of 5,000 EUR, and the Cash-for-Clunkers program grants an
additional 1,500 EUR fund if the old car built before 2000 is taken out of service.
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GCSFP Study - Regulations on a electric vehicle infrastructure for road traffic
Spain plans a government subsidy of 20 % of the purchase price (but max. 6,000
EUR). There are also plans to issue a license for electric cars in downtown areas with
limited access or provide special electric vehicle parking spaces.
Sweden gives an "eco car" subsidy of 1,050 EUR for private car owners. Fringe
benefit cars get a reduction of the benefit tax of 40% for BEVs and HEVs and 20% for
other "eco cars".
The United Kingdom gives between 2011 and 2016 BEVs a subsidy with a sum
between 2,300 and 5,000 EUR. HEVs benefit from the lowest band of vehicle excise
duty (car tax), which is based on carbon dioxide emissions. In central London, these
vehicles are also exempt from the £8 daily London congestion charge.
1.2.2.2 German Law
For a vehicle to be used on the road it has to be registered. The German Vehicle
Registration Regulation (FZO)65 requires registration of each vehicle, including all
kinds of EV, which travel faster than 6 km/h and which have been given a type
approval and motor insurance.
The German Motor Vehicle Tax Law (KraftStG)66 regulates taxation. The Motor
Vehicle Tax Law originally was a Federal State tax and has now been changed into a
Federal tax. The new CO2-oriented version of this law determines a calculation base
of 2 EUR for every 100 ccm or part thereof and 2 EUR per every gram CO2
emissions per km. Electric vehicles are granted a tax exemption for the first five
years, Art. 3d KraftStG, after which they will be taxed at 50% of the regular fee. BEVs
and REEVs are considered electric vehicles as the drivetrain are solely electric
motors. This regular fee is defined in Art. 9 I KraftStG and depends on the vehicle
weight. This will kick in after a period of five years from the date of first registration,
65
66
Fahrzeugzulassungsverordnung of 25 April 2006
Motor Vehicle Tax Law, Kraftfahrzeugsteuergesetz of 27 May 2010
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GCSFP Study - Regulations on a electric vehicle infrastructure for road traffic
when the vehicle is tax free. This means the first five years BEVs are tax free. During
this period a new owner of the vehicle is also granted the exemption.
Table 4: Vehicle taxation for BEVs and REEVs in Germany
Vehicles up to 3,500 kg
for each 200 kg or part thereof
50 % for BEVs
The first 2,000 kg
11.25 EUR
5.63 EUR
2,000 – 3,000 kg
12.02 EUR
6.01 EUR
3,000 – 3,500 kg
12.78 EUR
6.39 EUR
The first 2,000 kg
6.42 EUR
3.21 EUR
2,000 – 3,000 kg
6.88 EUR
3.44 EUR
3,000 – 4,000 kg
7.31 EUR
3.66 EUR
…
…
…
Vehicles more than 3.500 kg
Hybrid vehicles are to be taxed according to their CO2 emissions. The calculation
basis is 2 EUR for each 100 ccm or part thereof and an additional 2 EUR per every
gram CO2 emission per km exceeding 120 gram.
Table 5: Vehicle taxation for HEVs in Germany
First-time registration from July 1st 2009
For each 100 ccm or
part thereof
Induced ignition
2 EUR
Self-ignition
9.50 EUR
- up to 120 g/km
CO2 emission
- each gram more than 120 g/km
free
from 2012 more than 110 g/km
2 EUR
from 2014 more than 95 g/km
All kinds of vehicles including EVs also need automobile third-party insurance. With a
view to protecting the victims of traffic accidents this is not a voluntary, but a
mandatory insurance. This is regulated in German Obligatory Car Insurance Law
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GCSFP Study - Regulations on a electric vehicle infrastructure for road traffic
(PflVG)67. The car owner has to maintain insurance cover for himself as owner and
for the driver when the vehicle is used in public transport, § 1 PflVG. Exceptions to
this insurance exist but these will not be relevant as BEVs will be driven
independently in public traffic with more than 6 km/h. Only special authorities with an
existing regional municipal insurance can obtain an exception if applicable.
Those who use a vehicle in public traffic or allow its use, even though for this vehicle
the required third-party liability insurance contract does not exist or no longer exists,
can be punished by up to one year's imprisonment or a fine, § 6 PflVG. The kind of
vehicle does not matter. Therefore BEVs also need automobile third-party insurance.
Insurance companies are starting to offer insurances for BEV in different ways. Some
divide the vehicles in classes up to 10 kW or more than 10 kW, and some use the
vehicle replacement value as grading.
In addition a voluntary comprehensive insurance coverage is useful. The rates are
different to those for normal vehicles. It depends on the use of the vehicle, the vehicle
replacement value and the co-insurance, also known as deductible. No-claims
bonuses seem not to exist at the moment. Insurance premium reductions for nonpolluting vehicles are not specified by law.
According to the General Conditions for Car Insurance, § 10 I AKB68, the motor
insurer regulates only those damages that were caused by the use of the vehicle.
This includes the term "vehicle operation" within the meaning of the Road Traffic Law,
§ 7 StVG69, and even goes beyond that.
It is determined by the interest of the insured person in not being burdened by the
use of a motor vehicle with liability claims, regardless of whether they are based on §
7 StVG, 823 ff BGB, or other liability standards.
67
68
69
German Obligatory Car Insurance Law, Pflichtversicherungsgesetz, last changed 18 December 2007
General Conditions For Car Insurance, Allgemeine Bedingungen für die Kfz-Versicherung (AKB)
Road Traffic Law, Straßenverkehrsgesetz
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GCSFP Study - Regulations on a electric vehicle infrastructure for road traffic
The German Energy Tax Law (EnergieStG70) is jointly responsible for the fuel
taxation of energy products. Unlike in the EC Directive, the taxation of energy
products and that of electricity are split into two laws. The German Electricity Tax Law
(StromStG)71 taxes electricity at 20.50 EUR per MWh.
Relevant exemptions are:
- electricity from renewable energy sources when the electricity is taken
exclusively from a renewable energy grid or equivalent power line
- electricity generated in electrical installations with a capacity of up to 2 MWh
and used for personal consumption or by end users, but both in the spatial
context of the plant
- reductions for trolley buses and trams with 11.42 EUR per MWh.
This shows that electricity as a fuel is not provided for in law. Fresh thinking is
needed and it must be implemented in existing laws. Until then electricity for mobility
is dealt with like electricity for households.
70
71
Energy Taxation Law (Energiesteuergesetz) of 15 July 2006 (BGBl. I P. 1534; 2008 I P. 660; 1007), last amended by
Art. 13 of 22 December 2009 (BGBl. I P. 3950; 2010 I 534)
Stromsteuergesetz of 24 March 1999, last changed on 15 July 2009
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1.2.2.3 Chinese Law
The project ―The Demonstration, Popularization and Application Project of One
Thousand Energy-efficient and New Energy Automobiles in Every Ten Cities‖
(Project of Ten Cities 1000) was co-initiated in January 2009 by the MOST, the
Ministry of Finance, the National Development and Reform Commission and the MIIT.
Ten cities will be developed every year in the coming three years by providing fiscal
subsidy. Each city launches 1,000 new energy vehicles for model operation, covering
such fields as bus, taxi, municipal administration and postal service in these large
and medium cities, with the aim of enabling the operation scale of new energy
vehicles in China to account for 10% of the total vehicle market by 2012. There are
13 cities which have been determined as the first batch to participate in the ―Ten City
and A Thousand Vehicle Project‖, including: Beijing, Shanghai, Chongqing,
Changchun, Dalian, Hangzhou, Jinan, Wuhan, Shenzhen, Hefei, Changsha,
Kunming and Nanchang. There are 7 cities which have been determined as the
second batch to participate in the ―Project of Ten Cities and A Thousand Vehicles‖,
including: Tianjin, Haikou, Zhengzhou, Xiamen, Suzhou, Tangshan and Guangzhou.
As reported, 5 cities including Shenyang, Chengdu, Nantong, Xiangfan and Hohhot
will be added, thus increasing the number of model cities to 25.
According to the Interim Procedures of Energy Conservation and New Energy
Vehicle Demonstration and Popularization Fiscal Subsidy Fund Management
co-issued by the Ministry of Finance and the MOST in February 2009, vehicle types
listed in the Catalogue of Vehicle Types Recommended for the Energy
Conservation and New Energy Vehicle Demonstration, Popularization and
Application Project will obtain a fiscal subsidy. This undertaking includes support for
objects and methods, conditions, subsidy standards, application and issues of funds,
supervision and management of funds. According to the following standards BEVs,
HEVs and FCEVs as passenger cars, light-duty commercial vehicles and hybrid
power vehicles will be divided into five grades according to the degree of mixing and
fuel economy, and the highest subsidy per vehicle is 50,000 RMB. The subsidy for
every purely electric vehicle is 60,000 RMB, for every fuel cell vehicle it is 250,000
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GCSFP Study - Regulations on a electric vehicle infrastructure for road traffic
RMB and for every urban transport passenger car and hybrid power passenger car it
is 500,000 and 600,000 RMB respectively. An auxiliary fund will also be arranged for
the local finances of 13 cities participating in the demonstration, and a moderate
amount of subsidy will be offered for the relevant expenditure, including the purchase
of energy-efficient and new-energy vehicles, the construction of auxiliary facilities and
maintenance and upkeep.
On 1 June 2010, the four ministries/commissions co-promulgated The Circular on
Developing Pilot Subsidy for Individuals to Purchase New Energy Automobiles,
determining that the pilot subsidy for individuals to purchase new energy vehicles will
be initiated in such 5 cities as Shenzhen, Shanghai, Changchun, Hangzhou and
Hefei. The subsidy standards are determined according to the energy of the power
battery. A subsidy of 3,000 RMB/kWh will be offered to new energy vehicles that meet
the supporting conditions. The highest subsidy for HEVs is 50,000 RMB, and for
BEVs 60,000 RMB.
To encourage individuals to purchase new-energy vehicles, local pilot cities add the
subsidy on this basis, ranging from 20,000 to 60,000 RMB.
As to the policy for the use of new-energy vehicles, it is suggested that in the draft of
the Development Plan of Energy-efficient and New Energy Automobile Industry
that:
1. A complete set of policy framework systems of new-energy vehicles should be set
up, the guidance and support of the policies of fiscal tax, technology, management
and finance should be strengthened, and the rapid cultivation and development of the
new-energy vehicle industry should be promoted. Fiscal policy should be formulated,
the taxation proportion of registration, holding and use should be adjusted according
to the energy consumption reform tax calculation system, and fiscal tax support
should be offered to such key areas as R&D, production and consumption of newenergy vehicles. The energy-saving management system of vehicle products should
be established, the rapid enhancement of the energy-saving level of vehicles should
be promoted, and the production of new-energy vehicles should be encouraged.
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GCSFP Study - Regulations on a electric vehicle infrastructure for road traffic
The enterprise access and product access management systems of new-energy
vehicles should be adjusted and perfected in connection with the organizational
structure of the industry. The demonstration operation management system of newenergy vehicles should be established and perfected, the supervision, check and
elimination mechanism should be set up, and the guidance role of pilot and
demonstration projects should be fully exercised. The recycling management system
of such key parts and components as the power battery of new-energy vehicles
should be studied and established, and the investment and financing policy
conducive to the development of new-energy vehicles should be perfected.
2. According to the principles of encouraging energy conservation, technical
progress, promoting consumption and neutral taxation, we should formulate the
taxation system so that it is conducive to the development of energy-efficient and
new-energy vehicles, study how to conduct the necessary adjustment and reform to
the existing vehicle taxation system, reform the means of levying existing tax types,
and adjust the collection completely based on price, vehicle type and discharge to
the collection chiefly based on oil consumption indexes, expand the tax proportion in
the holding link and especially the using link, reduce the tax proportion of the
registration link, adjust some taxes from collection in the manufacturing link to
collection in the consumption link, and offer tax reduction and exemption and
necessary fiscal rewards to new-energy vehicle products.
3. We should create a preferential consumption and usage environment. We should
carry out supporting measures which encourage the consumption and usage of newenergy vehicles, including preference for parking and passing and the reduction and
exemption of road and bridge passage tolls.
- Import duties 25% for all vehicles (it has been of 180% for less than 3.0l engines
and 220% for more than 3.0l engines)
- Value-added tax 17%
- Consumption tax rate (as follows)
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GCSFP Study - Regulations on a electric vehicle infrastructure for road traffic
Table 6: Passenger Cars (SUV included) Consumption Tax Rates Table
Displacement
<=1.0l
rate
1%
1.0L - 1.5L（1.5l included）
3%
1.5L - 2.0L（2.0l included）
5%
2.0L - 2.5L（2.5l included）
9%
2.5L - 3.0L（3.0l included）
12%
3.0L - 4.0L（4.0l included）
25%
Above 4.0l
40%
Vehicle insurance
In China, vehicle insurance includes compulsory insurance and non-compulsory
insurance. Compulsory insurance is a motor vehicle traffic accident liability insurance
(Traffic Insurance).
Non-compulsory forms of insurance are:
- third party liability insurance
- driver passenger accident Insurance (that is car liability insurance)
- car Theft Protection Insurance
- vehicle loss insurance
- spontaneous loss of insurance
- non-deductible insurance by special arrangement
- single insurance of windshield glass breakage
- additional equipment loss insurance
- faultless responsibility insurance
To date there have been no special safety provisions for electric vehicles in
China.
At present new-energy vehicles are still at the demonstration stage in China.
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GCSFP Study - Regulations on a electric vehicle infrastructure for road traffic
1.2.3 Air Quality and Noise Pollution
1.2.3.1 European Law
Environmental protection is a main objective of the European Union. To increase air
quality in urban areas Directive 2008/50/EC72 on ambient air quality and cleaner air
for Europe was established.
Noise Level Directive 70/157/EEC and UNECE-R 51 lay down that only the driving
noise of electric vehicles has to be controlled, not the stationary noise.
An issue also worthy of mention is the reduction of environmental noise. Directive
2002/49/EC73
regulates
the
evaluation
and
reduction
and
abatement
of
environmental noise. Whereas EVs are less noisy than petrol- or diesel-powered
cars, the requirements of this Directive impose no restrictions. MSs must establish
noise maps. Within agglomerations, internal combustion engines vehicles could be
prohibited due to their noise levels. This should be an advantage for EVs.
1.2.3.2 German Law
In Germany the 35th Ordinance on the Federal Pollution Control Act (35. BImSchV74)
for identification of low-emission vehicles (also briefly: Fine Particulate Ordinance),
allows the establishment of environmental zones as a means of compliance with the
air levels of fine particulates and nitrogen oxides. Not all vehicles or vehicles groups
may enter these zones. These emission groups are based on the Euro emission
standards and the particulate emissions of a vehicle. Through § 40 BImSchG and
Annex II para. 3 of 35th BImSchV vehicles without internal combustion engine, like
FCEVs and BEVs, are classified in emission group 4 (best) with a green ―Fine
Particulate Sticker‖. Displayed in the lower part of the windshield, this sticker allows
72
Directive 2008/50/EC of the European Parliament and of the Council of 21 May 2008 on ambient air quality and
cleaner air for Europe
73
Directive 2002/49/EC of the European Parliament and of the Council of 25 June 2002 relating to the assessment and
management of environmental noise - Declaration by the Commission in the Conciliation Committee on the Directive
relating to the assessment and management of environmental noise, OJ L 189, 18.7.2002, pp. 12–25.
74
Ordinance ofon theidentification of motor vehicles with a small share of the pollutant - 35 BimSchV of 10 October
2006 (BGBl. I P. 2218), last amended by the Ordinance of 5 December 2007 (BGBl. I P. 2793)
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entering environmental zones established by several German cities. Ideas exist to
implement a class for zero-emission vehicles.
Figure 11:
Environmental Zone and Fine Particulate Sticker, existing class 4 and suggested
class zero (blue or grey)
PHEVs and HEVs should normally also be group 4 but it depends on the emissions
of the internal combustion engine.
The maximum ozone level of the EU is implemented in national German law by the
33th Regulation of the Federal Pollution Control Law. Regarding road traffic,
measures to reduce the ozone level could include restrictions for polluting vehicles.
The BImSchG contains obligations for the establishment of air quality and noise
reduction plans. Environmental zones already exist which complicate the use of high
emission vehicles. EVs may profit from these restrictions through having no or
significantly less emissions.
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1.2.3.3 China
In 2010, it is reported that China, aiming to improve air quality and reduce reliance on
fossil fuels, is going to commence a two-year pilot program of subsidizing buyers of
alternative-energy vehicles in the five cities: Shanghai, Changchun, Shenzhen,
Hangzhou and Hefei. The subsidy will be as much as 60,000 RMB for BEVs and
50,000 RMB ($7,320) for plug-in hybrids. In 2009, BYD delivered 48 F3DM plug-in
hybrids in the country. China also plans to expand a project of encouraging the use of
energy-efficient and alternative-energy vehicles in public transport to 20 cities from
13.
China has implemented a Green Particulate Sticker Rule. There are yellow labeled
vehicles and green labeled vehicles. Yellow labeled vehicles means the vehicles
whose emission could not met EuroⅠemissions standards for gasoline vehicles and
whose emission could not met Euro Ⅲ emissions standards for diesel vehicles. For
the time being, there is no national legislation for the restriction of yellow labeled
vehicles, but in some cities and areas local governments has issued local regulations
according to their local situation, for example yellow labeled vehicles are forbidden
on roads within (and including) the Fifth Ring Road for the whole day in Beijing from 1
Jan.2009 unless the vehicles are used for guaranteeing urban production and life.
Guangzhou incorporated the city center area (260 km²) within city high-speed roads
in the restriction area.
Figure 12: Green Label and Vehicles with Yellow Label
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1.2.4 Use of physical structures
1.2.4.1 European Law
Electric vehicles will use physical structures, especially tunnels and garages.
Therefore the legal framework is to be considered. Basically the Law of the European
Union does not regulate any issues of building law. Aspects of approval and
requirements on the construction are left to the MSs.
Based on its responsibility for traffic and emergency management, the European
Parliament enacted Directive 2004/54/EC75 due to several accidents in tunnels. It
contains provisions regarding tunnel safety in order to avoid accidents causing
damage to humans, the environment and tunnel equipment. To date there have been
no special safety provisions for electric vehicles.
Eurotunnel, operator of the Channel Tunnel between France and England, does not
accept LPG or equivalent flammable gas and dual powered vehicles (i.e. vehicles
fitted with an LPG or equivalent tank as an alternative fuel) for transport. No electric
vehicles are permitted.
Table 7: Acceptability of passenger cars in the Eurotunnel according to their fuel type / power source
(including dual fuelled & hybrid vehicles)
75
76
76
Directive 2004/54/EC of the European Parliament and of the Council of 29 April 2004 on minimum safety
requirements for tunnels in the Trans-European Road Network, OJ L 167, 30.4.2004, pp. 39–91.
Source: http://www.eurotunnel.com
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1.2.4.2 German Law
Provisions for the Facilities and Operation of Road Tunnels (RABT) exist in
Germany. These are basic rules concerning tunnel safety, especially fire protection,
but EVs are not mentioned.
1.2.4.3 Chinese Law
At present, new-energy vehicles are still at the demonstration stage in China. To date
there have been no special safety provisions for electric vehicles in China.
1.2.5 Legal Comparison
Both parties have increased consumer decisions for buying vehicles by providing
consumption information. New vehicles have to be labelled with information important
for running costs. The main focus lays on fuel consumption, engine power and total
weight. The difference is that information about CO2 consumption will not yet be
implemented in Chinese consumption labels.
With regard to clean air in urban areas, both parties see EVs as a supporting
technology. To relieve the environment and decrease CO2 production more efficient
and greener vehicles are to be used, also by the authorities. Both countries have
thus issued an order to public fleet operators to increase the number of new-energy
vehicles.
Another possibility for market preparation is provided by subsidies. Many European
countries support the consumer of EVs with subsidies related to the vehicle price
and/or benefits regarding to road traffic or parking fees. China has set out concrete
amounts for the purchase of EVs. Germany has announced it will not support the
customer by subsidies. At the moment the aim is to enhance user acceptance by
demonstration projects.
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Tax on vehicles with big-volume engines which cause high emissions is rising on
both sides. EVs belong to every best vehicle emission class which enjoys benefits
with respect to entering some city zones and partly for parking.
Tunnel regulations do not cover EVs. Similarly other regulations restricting road traffic
do not cover EVs at the moment. Other safety provisions have to be developed by
the time of market entry or of test user experience.
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1.3 Traction batteries - Production, Transport, Safety, Take Back, Reuse,
Recycling and Reuse
For some time battery-related regulations and standards have existed. These
documents deal with the battery in general or in special cases also with traction
batteries. These traction batteries, however, were on one hand mostly used for light
urban electric road vehicles and the battery systems were of the aqueous electrolyte
class (e.g. lead-acid, Ni-Cd, Ni-MH).
New EVs are intended for greater ranges and are equipped with a non-aqueous LiIon battery. This battery shows high energy, high voltage and is made up partially of
hazardous materials. These characteristics required new regulations, especially with
regard to safety/abuse and environmental protection.
Therefore in the following we will deal with older, general battery regulations and
newer ones related to the Li-ion tractions battery.
As mentioned for EVs the whole value chain of the battery from production via
transport, storage, application, take-back to recycling and reuse is also the subject of
the legislation. The focus of the legislation is how to handle, in the different steps of
the value chain, the battery with high chemical energy (explosion, fire risk) and with
hazardous substances (health and environmental hazard).
In the following sections different parts of this value chain will be presented in general
and subsequently main points will discussed from the point of view of the different
laws. Unfortunately a clear classification in terms of individual elements of the value
chain is not always possible, because the laws sometimes cover a number of value
chain elements.
As already mentioned, in China mandatory standards exist which are attributed
regulatory characteristics77. This is valid also for batteries; therefore this section will
77
These mandatory standards therefore contain much detailed information which are mainly discussed in the GCSFP
study ―Analysis and Comparison of Norms and Standards for the Application of Electric Vehicles and Vehicle
Batteries‖.
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mention only the relevant Chinese standards (GB and GB/T) and discuss the main
points, but not in detail.
1.3.1 Manufacture and Disposal
1.3.1.1 European and UN Law
EU Battery Directive 2006/66/EC (Manufacture and Disposal of Batteries)
The most important Directive 2006/66/EC78, repealing Directive 91/157/EEC79, aims
at minimizing the negative impacts of batteries and accumulators on the environment
and also harmonizing requirements for the smooth functioning of the internal market.
To achieve these objectives, the Directive introduces measures to prohibit the
marketing of some batteries containing hazardous substances. It contains measures
for establishing schemes aiming at high level of collection and recycling of batteries
with quantified collection and recycling targets. The Directive sets out minimum rules
for producer responsibility and provisions with regard to labelling of batteries and
their removability from equipment.
This Directive distinguishes between portable batteries and accumulators on the one
hand and industrial and automotive batteries and accumulators on the other.
Batteries for any type of vehicle are classified as industrial and automotive batteries.
The following areas are mainly addressed: placing on the market, collections,
removal, treatment, reuse and recycling batteries, new recycling technologies,
disposal, exports, Information for end-users, and labeling.
Exemptions from this directive exist for space, military, munitions, and "essential
security" applications.
78
79
Directive 2006/66/EC of the European Parliament and of the Council of 6 September 2006 on batteries and
accumulators and waste batteries and accumulators and repealing Directive 91/157/EEC.
Council Directive 91/157/EEC of 18 March 1991 on batteries and accumulators containing certain dangerous
substances
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It will lay down rules on penalties applicable to infringements of national provisions
adopted pursuant to this Directive and will take all necessary measures to ensure
that they are implemented. The penalties provided for must be effective,
proportionate and dissuasive.
The Directive applies without prejudice to Community legislation on safety, quality
and health requirements and specific Community waste management legislation, in
particular Directive 2000/53/EC80 on end-of-life vehicles (ELV) and Directive
2002/96/EC81 on Waste Electrical and Electronic Equipment (WEEE) in connection
with 2002/95/EC82 on the restriction of the use of certain hazardous substances in
electrical and electronic equipment.
The Battery Directive, made official on 26 Sept. 2006, was to implement into national
laws and rules in all 23 European MSs.
EU Directive 2000/53/EC (End-of-life Vehicles)
ELV-Directive 2000/53/EC83 aims to decrease the quantity of waste arising from
vehicles. It therefore encourages vehicle manufacturers and importers of vehicles
into the European Union to limit the use of hazardous substances in their new
vehicles, to design and produce vehicles which facilitate re-use and recycling and to
develop the integration of recycled materials.
Since 1 July 2003, the use of mercury, hexavalent chromium, cadmium and lead in
the components of vehicles placed on the market has been prohibited. However,
these substances may be used for certain applications if the use of these substances
is unavoidable (see Annex II to the Directive 2000/53/EEC).
80
81
82
83
Directive 2000/53/EC of the European Parliament and of the Council of 18 September 2000 on end-of life vehicles
Directive 2002/96/EC of the European Parliament and of the Council of 27 January 2003 on waste electrical and
electronic equipment (WEEE), amended by Directive 2003/108/EC of the European Parliament and of the Council of
8 December 2003
Directive 2002/95/EC of the European Parliament and of the Council of 27 January 2003 on the restriction of the use
of certain hazardous substances in electrical and electronic equipment
Directive 2000/53/EC of the European Parliament and of the Council of 18 September 2000 on end-of life vehicles
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Producers, distributors, dismantlers, etc. must give information on the design of the
vehicles and their components (capacity for recovery and recycling), the treatment of
end-of-life vehicles, the development and improvement of methods for re-using,
recycling and recovering end-of-life vehicles and their components.
Small producers can obtain an exemption in regard to the financial participation,
which will enable them to break into the market with new technologies
This ELV Directive 2000/53/EC does not address particularly EVs – but all rules are
to be applied to EVs as well.
Directive 2002/95/EC (RoHS) and Directive 2002/96/EC (WEEE)
Directive 2002/95/EC84 - (Restriction of the Use of Certain Hazardous Substances in
Electrical and Electronic Equipments - RoHS) restricts the use of hazardous
substances in electrical and electronic equipment and Directive 2002/96/EC85
(Prevention of Waste Electrical and Electronic Equipment - WEEE)) promotes the
collection and recycling of such equipment. These directives have been in force since
February 2003.
The legislation provides for the creation of collection schemes where consumers
return their used e-waste free of charge. The objective of these schemes is to
increase the recycling and/or re-use of such products. It also requires heavy metals
such as lead, mercury, cadmium, and hexavalent chromium and flame retardants
such as polybrominated biphenyls (PBB) or polybrominated diphenyl ethers (PBDE)
to be substituted by safer alternatives.
They are also to encourage in particular the reuse and recycling of WEEE, their
components and materials. WEEE-Directive will apply to electrical and electronic
84
85
Directive 2002/95/EC of the European Parliament and of the Council of 27 January 2003 on the restriction of the use
of certain hazardous substances in electrical and electronic equipment
Directive 2002/96/EC of the European Parliament and of the Council of 27 January 2003 on waste electrical and
electronic equipment (WEEE), amended by Directive 2003/108/EC of the European Parliament and of the Council of
8 December 2003
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equipment falling under the categories set out in Annex IA/B. The ten categories
centre on household appliances and consumer equipment. But if the equipment
concerned is part of another type of equipment that does not fall within this scope,
WEEE-Directive and 2002/95/EC are not applicable. This is important and applies to
electric vehicles as they or their parts are not named.
Inadequately treated e-waste poses environmental and health risks. In December
2008, the European Commission therefore proposed to revise the directives on
electrical and electronic equipment in order to tackle the fast increasing waste stream
of such products. The Commission proposes to set mandatory collection targets
equal to 65% of the average weight of electrical and electronic equipment placed on
the market over the two previous years in each MS. The recycling and recovery
targets of such equipment would cover the re-use of whole appliances and weightbase targets would increase by 5%.
EU Directive 2001/95/EC (General Product Safety)
Directive 2001/95/EC86 applies in the absence of specific provisions among the
Community regulations governing the safety of products concerned or if sectoral
legislation is insufficient. Furthermore, it is to be applied without prejudice to Directive
85/374/EEC87 concerning liability for defective products. The Directive imposes a
general safety requirement on any product put on the market for consumers or likely
to be used by them, including all products that provide a service.
Manufacturers must put on the market products which comply with the general safety
requirement. In addition, they must provide consumers with the necessary
information in order to assess a product's inherent threat, particularly when this is not
directly obvious, and take the necessary measures to avoid such threats (e.g.
86
87
Council Directive 2001/95/EC of the European Parliament and of the Council of 3 December 2001 on general
product safety, OJ L 11, 15.1.2002, p. 4–17.
Council Directive 85/374/EEC of 25 July 1985 on the approximation of the laws, regulations and administrative
provisions of the MSs concerning liability for defective products, OJ L 210, 7.8.1985, p. 29–33
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withdraw products from the market, inform consumers, recall products which have
already been supplied to consumers, etc.).
Distributors are also obliged to supply products that comply with the general safety
requirement, to monitor the safety of products on the market and to provide the
necessary documents ensuring that the products can be traced.
Like conventional vehicles, electric vehicles are also subject to product liability.
EU Regulation (EC) No 1272/2008 (Classification, Labeling and Packaging
of Substances and Mixtures)
Regulation (EC) No 1272/200888 on classification, labeling and packaging is aimed at
ensuring a high level of protection of human health and the environment and the
functioning of the internal market. It does so by laying down EU-wide criteria that
must be applied to determine whether a substance or mixture which is manufactured
or imported into the European market has properties which could damage human
health or the environment. In cases where the substance or mixture meets these socalled ―classification criteria‖, i.e. if it has certain hazardous properties, the substance
or mixture must be classified accordingly, e.g. for acute toxicity or for flammability.
Suppliers must then communicate the identified hazards of these substances or
mixtures to their customers, including to consumers. The most common tool for
hazard communication is the labeling on the packaged substance or mixture, but also
the Safety Data Sheet (SDS) which is provided to other companies in the supply
chain.
Hazard labeling allows the alerting of the user of a substance or mixture to the
presence of a hazard and the need to avoid exposure and the resulting risks. Further
rules relating to packaging are intended help to ensure the safe supply of hazardous
substances and mixtures.
88
Regulation (EC) No 1272/2008 of the European Parliament and of the Council of 16 December 2008 on
classification, labelling and packaging of substances and mixtures, amending and repealing Directives 67/548/EEC
and 1999/45/EC, and amending Regulation (EC) No 1907/2006
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This EU Regulation must also apply for batteries, especially by the accurate labeling
of the batteries and drawing up of Safety Data Sheets.
EU Regulation 1907/2006/EC (Registration, Evaluation, Authorization and
Restriction of Chemicals - REACH)
REACH89 is a European Union Regulation of 18 December 2006. REACH addresses
the production and use of chemical substances, and their potential impacts on both
human health and the environment. Its 849 pages took seven years to pass, and it
has been described as the most complex legislation in the Union's history. REACH
entered into force in June 2007, with a phased implementation over the next decade.
In May 2008, the European Chemicals Agency90 (EChA) published the final
―Guidance on requirements for substances in articles 2 ―with the objective of
supplying guidance for the implementation of REACH‖. This Guidance Document
delivers clarification on definition of batteries under REACH and it confirms that
batteries are considered as ―articles - an object which during production is given a
special shape, surface or design which determines its function to a greater degree
than its chemical composition‖. Articles, and therefore batteries, are only subject to
REACH if they contain substances of very high concern (SVHC). SVHCs are
substances for which the current restrictions on use (where these exist) may be
insufficient.
Manufacturers and importers of articles containing SVHC that are not intended for
release during normal and foreseeable conditions of use have to fulfill the
requirements described in Art. 7 (2) (notification) and 33 (communication of
substances).
89
90
Regulation (EC) No 1907/2006 of the European Parliament and of the Council of 18 December 2006 concerning the
Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), establishing a European Chemicals
Agency, amending Directive 1999/45/EC and repealing Council Regulation (EEC) No 793/93 and Commission
Regulation (EC) No 1488/94 as well as Council Directive 76/769/EEC and Commission Directives 91/155/EEC,
93/67/EEC, 93/105/EC and 2000/21/EC
http://echa.europa.eu/home_en.asp
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The first candidate list was published by European Chemicals Agency ECHA in
October 2008 and it includes 15 SVHCs. It does not include substances contained in
batteries.
In conclusion, the notification and communication requirements of REACH do not
apply to batteries as articles, as long batteries do not use any of the substances
listed in the official candidate list proposed by ECHA. Therefore REACH has no
consequences regarding the battery.
1.3.1.2 German Law
In Germany the EU Directive 2006/66/EC was implemented in the form of the
Deutsches Batteriegesetz (German Battery Law, BattG)91 on 25.06.2009. It applies
to German battery manufacturers, importers of batteries and battery-powered
products if the battery is already attached.
Chapter 2 ―Placing on the market and taking back of batteries” regulates prohibitions,
duty of notification of producer, take back requirements of producers, taking back
system for used batteries, duties of distributor, deposit duty for automotive batteries,
duties of end-users recovery and disposal, success control and collection targets.
Chapter 3 describes labeling and information obligations, chapter 4 commissioning of
third parties and authorization for issue ordinance and chapter 5 offences and final
provisions.
Entirely new is the introduction of a central register in the Federal Environmental
Agency (UBA). The obligation to report applies to everyone who brings batteries
commercially into the market the first time. Distributors and brokers will also be
deemed as commercial producers if they intentionally or negligently sell unreported
batteries.
91
Batteriegesetz: Law on placing on the market, removal and environmentally acceptable disposal of batteries and
accumulators (Gesetz über das Inverkehrbringen, die Rücknahme und die umweltverträgliche Entsorgung von
Batterien und Akkumulatoren) of 25 June 2009 (BGBl. I P. 1582), amended by Art.2 of the Law of 11 August 2010
(BGBl. I SP 1163)
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Germany and also the other MSs must send to the EC reports on achievement of the
implementation of the Directive. The first report will cover the period until 26
September 2012; subsequent reports must be produced every three years.
Subsequent reports must be produced every three years.
Batteries and accumulators of used products are also mentioned in the German
Electrical and Electronic Equipment Law (ElektroG)92. To avoid electronic litter and
increase the reuse of electronic litter this law regulates production and
documentation rules as well as different duties for collection and reuse. In any case
this law does not apply for the vehicle sector. The scopes of this law are domestic
appliances and consumer electronics which are separate from vehicles and vehicle
batteries by definition.
1.3.1.3 Chinese Law
Chinese Regulations on Pollution of Dangerous Wastes and Recycling
In China a lot of regulations and directives are issued specifically to reduce and
finally to prohibit the use of mercury and cadmium in consumer cells:
-
Nine national ministries/commissions issue Regulations on Limiting the
Mercury Content in Battery - Standard HJBZ009－95 Dry Cells Containing no
Mercury is formulated in China.
-
Nine ministries/commissions of State Council including former China Light
Industry Federation co-issued the document QZHG No. [1997] 4 -Regulations
on Limiting the Mercury Content in Battery. Supplementary regulations
concerning button cells are also set forth in the Regulation:
-
The Circular on Carrying out Obligatory Inspection to the Mercury Content of
Imported and Exported Battery Products: GJJ No. [2000] 218;
-
The Circular on Printing and Issuing The Inspection and Supervision Measures
of the Mercury Content of Imported and Exported Battery Products: GJJ No.
[2000]244;
92
Gesetz über das Inverkehrbringen, die Rücknahme und die umweltverträgliche Entsorgung von Elektro- und
Elektronikgeräten (Elektro- und Elektronikgerätegesetz - ElektroG), of 16 March 2005
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-
The Supplementary Circular on the Relevant Issues of Carrying out Obligatory
Inspection to the Mercury Content of Imported and Exported Battery Products:
GJJ No.[2000] 70;
-
The Circular on Convening National Working Conference of Starting to Inspect
out the Mercury Content of Imported and Exported Battery Products: JBJ
No.[2000]270;
Besides the directly battery-relevant regulations and directives the topic of elimination
of mercury and cadmium and recycling of lead-acid batteries is addressed in batteryrelevant paragraphs in the Policy of the Technology of Preventing and
Controlling the Pollution of Dangerous Wastes. This document was co-issued by
the National Environmental Protection Administration, National Economic and Trade
Commission and the MOST on 17 December 2001.
To prevent and control battery-relevant pollutions approval was given to the Policy of
the Technology of Preventing and Controlling the Pollution of Used Batteries
on 19 October 2003, National Environmental Protection Administration, the National
Development and Reform Commission, the Ministry of Construction, the MOST and
the Ministry of Commerce.
After the detailed analysis “Investigation into the status quo of the recycling of used
dry cells in China” and also by analyzing the environmental protection laws and
regulations concerning used and discarded cells prevailing in various countries
worldwide the ―Management Measures of the Recycling of Used Batteries‖ were
formulated on 1 May 2007 by six ministries and commissions, including the Ministry
of Commerce, the Development and Reform Commission, the Ministry of Public
Security, the Ministry of Construction, the Administration of Industry and Commerce,
and the Administration of Environmental Protection.
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1.3.2 Transportation
1.3.2.1 Overview
The transport regulations are intended to prevent, as far as possible, accidents to
persons or property and damage to the environment, the means of transport
employed or to other goods.
With different regulations for different modes of transport and for different countries,
international trade in chemicals and dangerous products would be seriously impeded,
if not made impossible and unsafe. Moreover, dangerous goods are also subject to
other kinds of regulations, e.g. work safety regulations, consumer protection
regulations, storage regulations, environment protection regulations. In order to
ensure consistency between all these regulatory systems, the United Nations has
developed mechanisms for the harmonization of hazard classification criteria and
hazard communication tools (GHS) as well as for transport conditions for all modes
for transport (TDG). In addition, the UNECE administers regional agreements that
ensure the effective implementation of these mechanisms as far as transport of
dangerous goods by road, rail and inland waterways is concerned. This is shown in
the following figure.
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Figure 13: Structure of the transport regulations
Air Transport:
DGP – Dangerous Goods Panel of ICAOICAO - International Civil Aviation Organization
IATA – International Air Transport Association
DGR – Dangerous Goods Regulations
TI – Technical Instructions for the safe transportation of dangerous goods
LuftVG – Luftverkehrsgesetz
LuftVZO – Luftverkehrs-Zulassungsordnung
Sea Transport
DSC – Sub-Committee on Goods, Solid Cargoes and Containers of MSC
MSC – Maritime Safety Committee (MSC) of IMO
IMO – International Maritime Organization (IMO)
IMDG Code – International Maritime Organization has developed the International
Maritime Dangerous Goods Code
GGVSee – Gefahrgutverordnung See (Bund)
Road Transport (Europe):
WP 15 – Working Party on the Transport of Dangerous Goods of ECE
ECE – United Nations Economic Commission for Europe
ADR – Accord européen relatif au transport international des marchandises Dangereuses
par Route (European Agreement concerning the International Carriage of
Dangerous Goods by Road)
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GGVSE – Gefahrgutverordnung Straße und Eisenbahn (Road and Railway
Dangerous Goods Directive)
Rail Transport (Europe):
RID – Regulations concerning the International Carriage of Dangerous Goods by Rail
OTIF – Organisation intergouvernementale pour les Transports Internationaux Ferroviaires
(Intergovernmental Organisation for International Carriage by Rail)
GGVSE – Gefahrgutverordnung Straße und Eisenbahn (Road and Railway
Dangerous Goods Directive)
All Modes:
ECOSOC – UN Economic and Social Council with United Nations Economic Commission for
Europe (UNECE)
1.3.2.2 United Nations Recommendations on the Transport of Dangerous
Goods
The UN Recommendations on the Transport of Dangerous Goods are contained in
two documents prepared by the Sub-Committee of Experts on the Transport of
Dangerous Goods of the United Nations Economic and Social Council (ECOSOC).
They cover the transport of dangerous goods by all modes of transport except by
bulk tanker. They do not cover the manufacture, use or disposal of dangerous goods.
They are not obligatory or legally binding on individual countries, but have gained a
wide degree of international acceptance: they form the basis of several international
agreements and many national laws.
"Dangerous goods" (also known as "hazardous materials" or "HAZMAT" in the United
States) may be pure chemical substance, mixtures or manufactured articles. The
transport hazards that they pose are grouped into nine classes, which may be
subdivided into divisions and/or packing groups. The most common dangerous goods
are assigned a UN number, a four digit code. Batteries belongs to
class 8, dangerous goods - caustic
Alkaline batteries – described by UN 3028; there are exemptions, special provision
304 for ADR/RID and IMDG-Code and special provisions 123 IATA DGR for alkaline
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consumer batteries.
class 9, dangerous goods - miscellaneous
Ni-MH batteries - described by UN 3496; for sea transport of batteries but not valid
for batteries functionally installed into equipment/vehicles.
Li-batteries – described by:
- UN 3090 - Li-Metal batteries
- UN 3091 - Li-Metal batteries in equipment
- UN 3480 - Li-Ion batteries
- UN 3481 - Li-Ion batteries in equipment
All Li-batteries independent of the system chemistry and the Li-mass are dangerous
goods on all transport modes (e.g. air, sea, roads).
UN Recommendations on the Transport of Dangerous Goods – Manuals of Tests
and Criteria93 and Model Regulations94
The Manual of Tests and Criteria contains criteria, test methods and procedures to be
used for classification of dangerous goods according to the provisions of Parts 2 and
3 of the United Nations Recommendations on the Transport of Dangerous Goods,
Model Regulations, as well as of chemicals presenting physical hazards according to
the Globally Harmonized System of Classification and Labeling of Chemicals (GHS).
The Manual of Tests and Criteria and Model Regulations documents are permanently
renewed. Li-batteries are described in part III, section 38.3 of Manuals of Tests and
Criteria.
As prerequisite for transport permissions the Li-cells or batteries have to fulfill the
following practical tests: altitude simulation, thermal test, vibration, shock, external
short circuit, impact, overcharge and forced discharge.
93
94
The UN Recommendations on the Transport of Dangerous Goods Manual of Tests and Criteria; Fifth revised edition:
http://www.unece.org/trans/danger/publi/manual/pubdet_manual.html also in Chinese
UN Recommendations on the Transport of Dangerous Goods - Model Regulations Nature, Purpose and Significance
of the Recommendations; Sixteenth revised edition: http://www.unece.org/trans/danger/publi/unrec/mr_pubdet.html
also in Chinese
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These tests are adopted by the IATA Dangerous Goods Regulation (IATA T1–T8
certificate).
1.3.2.3 Chinese Laws
The following Chinese laws are reviewed and relate to the transportation of batteries.
GB 21966-2008 (Safety Requirements for Lithium Primary Battery and Storage
Battery in Transportation)
Safety Requirements for Lithium Primary Battery and Storage Battery in
Transportation GB 21966-2008 are exclusive standards for the safety and package
used in the transportation of lithium primary batteries and storage batteries, including
safety requirements, type inspection, sampling, re-inspection, testing methods and
requirements, safety information, packing and handling notices and marks in
transportation, etc.
GB 8897-2008 (Lithium Battery Safety Requirements)
The mandatory standard GB 8897-2008 - Lithium Battery Safety Requirements is
equivalent to IEC 60086-4:2007. It gives detailed requirements for the safety of
lithium primary batteries, including design, sampling, inspection and requirements,
transportation, display, storage, and treatment. However, there is no special
requirement for EV batteries.
Standard GB/T 18384.1-2001 - Electric Vehicle Safety Requirement describes the
battery in the Energy Storage Equipment part of the Electric Vehicle section.
The concrete provisions of the standards for transportation of batteries are too
extensive to mention here; provisions are discussed later.
International transport rules for lithium batteries are formulated in accordance with
the suggestion of the Dangerous Goods Transportation Expert Committee of UN.
Transport rules are often modified, so we should refer to the following latest version
of the rules of air, sea and land transport for the transport of lithium batteries.
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Air Transport: There are provisions about the air transport of lithium batteries in the
Dangerous Goods Air Transport Safety Technology Guidance Rules published by the
International Civil Aviation Organization (ICAO)
95
and the Dangerous Goods Rules
published by the International Aviation Association (IATA)96. What corresponds with
this is the Lithium Battery Air Transport Criteria of China (MH/T 1020-2009)97.
Sea transport: There are provisions for the sea transport criteria for lithium batteries
in the International Sea Transport Dangerous Goods Rules (IMDG)98 published by
International Maritime Transport Organization. Sea transport rules for lithium batteries
are set forth in the International Sea Transport Dangerous Goods Rules released by
the International Maritime Organization.
Land transport: The road and railway transport rules for lithium batteries are
formulated by one or more countries. Although more and more managers adopt the
Model of Regulations of the UN, it is still suggested that we should refer to the
transport rules formulated by the relevant country before the freight transport.
UNECE R 100 provides for appropriate requirements to ensure a high level of public
safety in relation to electric vehicles. In fact it focuses on the EVs and the electric
powertrain but also gives also some instruction for the traction battery and the battery
compartment, such as gas ventilation, necessary fuses and circuit breakers for the
battery system or battery labeling.
1.3.3 Fire Safety Regulations for Vehicle Batteries
There are at present no fire safety regulations in Germany/Europe and China.
The best fire safety measure is of course the prevention of a fire due to battery
accidents. The risk of such accidents is relatively low if the battery was successful
tested in accordance with the UN Recommendations on the Transport of Dangerous
95
96
97
98
Transport of Lithium Batteries in Accordance with the ICAO Technical Instructions:
http://www.icao.int/anb/fls/dangerousgoods/ICAOLithiumBatteryGuidance/ICAOLithiumBatteryGuidance.pdf
IATA Dangerous Goods Regulations, 51st Edition 1 January 2009:
http://www.iata.org/SiteCollectionDocuments/Documents/GuidanceDocumentontheTransportofLiBatt_2010.pdf
see EV Standards project
IMDG Code, 2010 Edition (incl. amendment 35-10)
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Goods and also Chinese and other international standards (see above). In particular
the so-called fire test (see SAE J2424) or radiated heat test (see Chinese GB/T xxxx201x – Safety Requirements of Traction Battery for Electric Vehicles) is useful in such
a case.
There are also no regulations for firefighting measures. In Europe and Germany,
however CLP-Regulation (EC) No 1272/2008 and REACH Regulation (EC) No
1907/2006 call for Safety Data Sheet (SDS) for batteries as part of the shipping
documents of the battery. These SDSs also have to give information about
firefighting measures.
With regard to the firefighting in relation to batteries account must also be taken of
regulations which are general connected with firefighting. In Germany these are, for
example, § 25 fire and explosion protection of the Occupational Safety and Health
Act (ArbSchG)99, Ordinance on Hazardous Substances (GefStoffV 2004)100,
Washing and Cleaning Agents Law (WRMG)101 etc.
1.3.4 Special topics of particular importance
1.3.4.1 Producer
Battery producer have to be registered. Without registration no trade is possible in
the MSs.
When placing batteries on the market the producers have had to register in Germany
at the Federal Environment Department (Umweltbundesamt – UBA) since 1
December 2009 (§ 4 BattG). With this registration producers agree with product
stewardship.
99
100
101
Occupational Safety and Health Act - Gesetz über die Durchführung von Maßnahmen des Arbeitsschutzes zur
Verbesserung der Sicherheit und des Gesundheitsschutzes der Beschäftigten bei der Arbeit (Arbeitsschutzgesetz ArbSchG) of 7 August 1996; § 25 fire and explosion protection (Brandschutz und Explosionsschutz)
Verordnung zum Schutz vor Gefahrstoffen (Gefahrstoffverordnung - GefStoffV) of 23 December 2004
Gesetz über die Umweltverträglichkeit von Wasch- und Reinigungsmitteln (Wasch- und Reinigungsmittelgesetz –
WRMG)
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A producer is anyone who places batteries on the market for the first time within the
scope of the BattG or the EC Battery Directive. Therefore the producer is deemed to
be the first person in the supply chain that physically receives and takes ownership of
the product. This means not only the battery manufacturers are producers but also
battery distributors or battery direct customers, if they imported the battery within the
scope of the BattG or the EC Battery Directive. If the battery direct customers,
however, received the batteries from a battery distributor in the EU, then they are not
deemed to be a producer.
Figure 14: Examples for producers
Examples for definition of Battery Producer:
- An equipment/car manufacturer buys batteries within an MS; these batteries
are then sold together with the equipment/car in the same MS
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A battery manufacturer or domestic importer in an MS sells batteries to an equipment
or car manufacturer in the same MS who will then put the battery into equipment or a
car and sell it on the market of this MS. In this case, the battery manufacturer or
domestic importer is the producer in this MS as they are placing the batteries on the
market for the first time.
- A vehicle/equipment manufacturer buys batteries outside an MS, then
incorporates them into equipment/a car and sells this in the MS.
The car/equipment manufacturer or domestic importer sells cars/equipment in a
given MS with batteries incorporated. The batteries for the car/equipment were
bought outside this MS. Since in this case it is the equipment or car manufacturer or
domestic importer who places these batteries on the market of the MS for the first
time, they are the battery producers in this MS.
In China there is a ―Registration Procedure for Import and Export Batteries‖
((进出口电池备案程序). This registration procedure regulates that products within
―HS‖（The Harmonized Commodity Description and Coding System - 8506/8507)
should be registered. For the registration of imported battery the manufacturer, the
importer or the import agent is responsible. For the registration of exported batteries
the battery manufacturer is responsible.
1.3.4.2 Classification
Because guidelines of battery regulations often make a distinction between the
different battery types in relation to applications, a classification of the different
battery types must be implemented (§2 (4)-(6) of German BattG).
Notice: Propulsion batteries are classified as industrial batteries and not as
automotive batteries; automotive batteries are starter batteries.
For Li batteries the classification is as follows:
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Li-primary batteries
Camera, electronic memories
Li-Ion consumer batteries
Mobile phones, camcorders, notebooks,
organizers, medical device technology,
power tools
Li-Ion industrial batteries
e.g. propulsion battery for HEVs and
BEVs; battery energy storage systems for
renewables ( wind, sun, and water).
In China this classification is not used. In the GB/T 19596-2004 ―Terminology of
Electric Vehicles‖ (电动汽车术) the traction battery is defined as ―battery which
supplies power to powertrain of the EV‖. With that definition the difference in relation
to the auxiliary battery is established, which supplies power to the auxiliary system of
vehicles.
1.3.4.3 Limitation of hazardous materials
In accordance to the BattG there are particular limits for cadmium. It is prohibited to
bring onto the market new batteries containing more than 0.0005 % mercury or
portable batteries containing more than 0.002 % cadmium, unless they are used for
emergency and alarm systems, emergency lighting, medical equipment or cordless
power tools. The prohibition does not apply to batteries in old vehicles when they are
exempted under Directive 2000/53/EC from the cadmium ban.
Since 2008 it has been forbidden to bring onto the market nickel-cadmium batteries.
Furthermore the ELV Directive 2000/53/EC, especially Article 4 thereof, prohibits the
use of cadmium in industrial batteries and accumulators for electric vehicles unless
benefit is to be gained from an exemption. This benefit is not deemed to exist in the
case of the use of Ni-Cd batteries for EVs.
Article 4 of ELV Directive mentions batteries which are prohibited by this Directive,
e.g.: all batteries or accumulators, whether or not incorporated into appliances, that
contain more than 0.0005 % of mercury by weight.
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In addition Directives 2002/95/EC and 2002/96/EC mentioned that the MSs must
ensure that electrical and electronic equipment, i.e. in this case batteries, do not
contain lead, mercury, and cadmium.
In accordance with Art. 9 (Economic Instruments) of 2006/66/EC the MSs may use
instruments like differential tax rates to encourage less toxic batteries and recycling.
In accordance with the Chinese standard HJBZ009－1995 the mercury content of
the cell may not exceed 0.0001 % of the total weight of a cell.
The Chinese standard QZHG No. [1997] 4 prohibits the production and sale of cells
with a mercury content of ≥ 0.025 % for various cells and of ≥ 0.0001% for alkaline
zinc-manganese cells as from 1 January 2000.
1.3.4.4 Labeling and Information Documents
According to Art. 21 of 2006/66/EC and § 17 of the BattG battery labels should state
collection information and the chemical content of batteries. They should show a
symbol of the "crossed-out" wheeled recycling bin to indicate that the battery should
NOT go in the bin. This symbol size is specified as a percentage of the battery area
on its largest side (3%), except for cylindrical batteries, where the symbol should be
1.5% of the total surface area.
All batteries have to be labeled with the following sign [§ 17(1)]:
Figure 15: Symbol for ‗separate collection‘ for all batteries and accumulators
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In addition the ELV Directive (2000/53/EC) includes this labeling provision.
Batteries with > 5 ppm Hg, > 20 ppm Cd und > 40 ppm Pb are to be labeled in
addition with Hg, Cd and Pb [§ 17(3)] as shown in the following Figure:
Figure 16: Label of batteries with critical levels of Hg, Cd and Pb
With regard to RID/ARD (rail, road) and IMDG Code (sea) the shipped item must be
labeled with information about:
- Kind of cells/batteries: Li-Metal or Li-Ion
- Careful handling and ignition danger
- Attention if package is damaged
- Phone number for additional information
Figure 17: Label for shipped item
In addition the UNECE-R 100 gives information about necessary labeling of the
battery (trade name, nominal voltage, energy, end of discharge voltage, etc.).
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In accordance to (EC) No 1272/2008 on classification, labeling and packaging and
(EC) No 1907/2006 (REACH) the shipping documents of the battery also have to
contain a Safety Data Sheet (SDS) with information on:
-
PRODUCT NAME:
-
TRADE NAMES:
-
CHEMICAL SYSTEM
-
MANUFACTURER INFORMATION (Name, Address, phone)
-
HAZARDS IDENTIFICATION
-
INGREDIENTS
-
FIRST AID MEASURES
-
FIRE FIGHTING MEASURES
-
ACCIDENTAL RELEASE MEASURES
-
HANDLING AND STORAGE
-
EXPOSURE CONTROLS/PERSONAL PROTECTION
-
STABILITY AND REACTIVITY
-
TOXICOLOGICAL INFORMATION
-
ECOLOGICAL INFORMATION
-
DISPOSAL CONSIDERATIONS
-
TRANSPORT INFORMATION
-
REGULATORY INFORMATION
Such a Safety Data Sheet (SDS) is not yet used in China. The GB 8897.4-2008/IEC
60086-4:2007 Lithium Battery Safety Requirements gives detailed requirements for
the safety of lithium batteries, however up to now only about primary batteries.
In accordance to Chinese GB 21966-2008 and GB 8897-2008 every battery should
be marked with the following items:
-
Model
Production time (year and month) and guaranty period, or suggested deadline
of service life;
The polarity of positive and negative end (applicable);
Nominal voltage;
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-
The name and address of manufacturer or supplier;
Trademark;
The number of executive standard;
The precautions for safe use (warning);
The warning concerning prevention of inadvertently swallowing small batteries
Both the packing box submitted for transport and the accompanied shipping
documents should be marked with the following information (unless otherwise
specified in relevant rules):
-
Contains lithium battery;
Handle with care;
In case of damage, please carry out an isolated check, and repack;
Contact telephone (for inquiry).
While approaching the battery, people should be able to see the warning mark
concerning high voltage.
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
Vehicles whose highest working voltage is lower than 25 V (AC) or 60 V (DC) are not
required to meet this provision.
The chemical types of power battery must be vividly indicated for identification
purposes.
The labeling provisions given so far are mostly related to technical and safety
questions. The Policy of the Technology of Preventing and Controlling the
Pollution of Used Batteries (废电池污染防治技术政策), however, provides for
labeling with collecting, recycling and disposal-related information: Formulate the
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technical standard so as to be helpful for the separate collection of the battery,
resource utilization and resource disposal. Battery classification labels should include
these items: the first is a recycling label which indicates whether the battery is
recyclable or un-recyclable, the second is a category label which indicates the
category the battery belongs to and the third is the label which indicates the
hazardous materials contained. To date, however, this policy as not yet been
implemented in terms of national regulations.
1.3.4.5 Transportation
Li-Mass limitation
Owing to the high chemical energy of Li batteries (explosion and fire risk) they must
be transported as dangerous goods; but there are also some exemptions.
RID/ARD (rail, road) and IMDG Code (sea):
All Li-batteries must be transported as dangerous goods in relation to the special
provisions 230 and packing instruction P903 (RID/ARD and IMDG-Code), i.e. they
have to have passed the UN-test 38.3 and the batteries/cell must be protected
against short circuit in the packing.
Exemptions (special provision 188):
- Li-mass per cell ≤ 1 g ( Li-Metal)
- Li-mass per battery ≤ 2 g ( Li-Metal)
- Energy per cell ≤ 20 Wh ( Li-Ion)
- Energy per battery ≤ 100 Wh ( Li-Ion)
- Li-Ion battery is labeled with the nominal energy in Wh
- Passed the UN-test 38.3.
IATA DGR (air):
All Li-Batteries for the transport must be declared as dangerous goods and
transported in accordance with the packing instructions 965-970 part 2.
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The exceptions for air transport are roughly the same as for special provision 188
except for the gross mass. In accordance with the packing instructions 968 part 1/2
the gross mass for shipped items with Li-Metal batteries is ≤ 2.5 kg and with Li-Ion
batteries is ≤ 10 kg (IATA DGR 01.01.2009). Furthermore the battery must have
passed the UN-test 38.3.
Faulty and damaged Li-batteries may not be transported by air (special provision
A154).
This legislation has been adopted in China in the Lithium Battery Air Transport
Criteria of (MH/T 1020-2009).
Battery Safety Tests (Transport relevant)
As already mentioned, Li-batteries must pass a safety test prior to transport (UN
38.3) in addition to the Li-mass limitations.
These tests simulate both normal conditions such as as high altitudes, vibration,
higher temperature and abnormal conditions such as shock, external short circuit,
impact, overcharge and forced discharge.
The test manual gives also requirements for passing tests such as no mass loss, no
leakage, no venting, no disassembly, no rupture and no fire etc.
These tests have been incorporated in the IATA Dangerous Goods Regulation (IATA
T1–T8 certificate).
The IAT DGR (air) permits exceptions (special provisions 310 and A88) for
―Prototype‖ and ―Low production‖ (<100 batteries/a) lithium batteries, i.e. these
batteries do not have to be tested under UN 38.3.
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1.3.4.6 Safety Battery Tests (General)
In the previous section only safety tests related to the transportation regulation UN
38.3. were discussed. There are, however, more reliability, safety and abuse tests
which also reflect different operating conditions.
Reliability tests: Simulating normal operating conditions
e.g. - vibrations, temperature changes (leads to dewing)
Safety tests: Simulating abnormal operating conditions
e.g. – overcharge, overdischarge
Abuse tests: Simulating improper "operating conditions"
e.g. – penetration, fire etc.
There are, however, no totally clear boundaries between reliability, safety and abuse
tests in the literature. Therefore in the following only safety tests which included
reliability, safety and abuse will be mentioned.
A good overview of safety tests is given in the GCSFP-study ―Analysis and
Comparison of Norms and Standards for the Application of Electric Vehicles and
Vehicle Batteries‖. Furthermore a GCSFP-initiated ―Battery Safety Test Manual‖ is
currently under development.
In Germany/Europe there are no special regulations for battery safety except the
accepted UN test regulation 38.3.
In China the safety requirements of the vehicle-borne energy storage device of the
electric vehicle driving system are set forth in GB 18384.1-2001, thus ensuring the
safety of the user and surroundings of vehicles, including the marks of the EV battery,
the concrete requirements concerning discharged air, the measuring methods for
insulated resistance, requirements concerning creep age resistance, various
concrete provisions for ventilation, the concrete requirements for the overcurrent
disconnector and the special requirements regarding collision.
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Special requirements such as a collision test on the vehicle-borne energy storage
device are laid down in Art. 8 of GB 18384.1-2001.
There are other two standards regarding battery safety:
The functional safety measures and failure protection requirements concerning the
dangers from electric power of electric vehicles are set forth in GB 18384.2-2001.
The requirements for personnel electric-shock protection when electric vehicles are
not connected with an external power supply source are set forth in GB 18384.32001.
In China, however, relevant mandatory standards are in preparation (see Annex 2):
GB/T XXXX-XXXX (draft) - Electric vehicles - Safety specifications - Part 2: Vehicle
operational safety means and protection against failures
GB/T XXXX-XXXX (draft) - Electric vehicles - Safety specifications - Part 3:
Protection of persons against electric shock
GB/T XXXX-XXXX (draft) - Electrically propelled road vehicles – Test specification for
lithium-ion traction battery systems – Part 1: High power applications
(adapted from ISO/DIS 12405-1:2009, Electrically propelled road vehicles – Test
specification for lithium-ion traction battery systems – Part 1: High power
applications, NEQ)
This GB contains the following reliability tests: dewing (temperature change), thermal
shock, vibration and mechanical shock.
GB/T XXXX-200X (draft) - Safety requirements for traction battery for electric
vehicles. This GB/T will replace the standard QC/T 743-2006, which also contains
safety tests. The new GB/T describes the following safety and abuse tests:
- Mechanical safety tests: extrusion, puncture, drop, seawater soaking
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- Electrical safety tests: short circuit, partial short circuit, over-charging, overdischarging
- Environmental safety tests: oven test, high-temperature charging-discharging
cycle, high-temperature storage, overheat/Thermal runaway, radiated heat
(simulation combustion test)
- Safety protection tests: short-circuit protection, over-charging protection, overdischarging protection.
1.3.4.7 Take Back (Collection)
Art. 8 and 10 of Battery Directive 2006/66/EC mentions that MSs shall ensure that
producers of automotive batteries and accumulators or third parties set up schemes
for the collection of waste automotive batteries and accumulators from end-users or
from an accessible collection point in their vicinity, where collection is not carried out
under the schemes referred to in Art. 5(1) of ELV Directive 2000/53/EC. In the case
of automotive batteries and accumulators from private, noncommercial vehicles, such
schemes shall not involve any charge to end-users when discarding waste batteries
or accumulators, nor any obligation to buy a new battery or accumulator.
Manufacturers also have to ensure, that batteries and accumulators can be easily
separated. Batteries which are used must include information on how to remove
these batteries safely.
The MS must provide collection sites that are accessible and free of charge to the
public. Battery distributors may be required to provide this (Art. 8).
Art. 7 of the 2006/66/EC Directive emphasizes that the MSs must maximize the
"separation" of batteries from regular municipal waste and requires spent batteries to
be collected separately. So that fewer batteries reach the landfills, recycling and
collection are called for, with target percentages for the future.
End-of-Life vehicles are the subject of Directive 2000/53/EC. As for conventional
vehicles, MSs must take the necessary measures to ensure that economic operators
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set up systems for the collection of all end-of life vehicles and vehicle parts, e.g.
batteries.
Paragraphs 5-8 of the German BattG regulate the taking back of batteries. The
BattG is in conformity with the Waste Management and Recycling Law
(Kreislaufwirtschaft- und Abfallgesetz - KrW-/AbfG) and the European Waste Types
List (Europäischem Abfallverzeichnis in der Abfallverzeichnis-Verordnung – AVV).
The detailed German national ways and targets (BattG) for the collection are:
Consumer batteries:
Take-back of used batteries is carried out via Common taking back system for
used batteries (Stiftung Gemeinsames Rücknahmesystem Batterien – GRS; § 6
BattG)
or
via
Producer
Owned
Take-back
System
(Herstellereigenes
Rücknahmesysteme für Geräte-Altbatterien – HRS; § 7 BattG).
The Take-back targets (§16 BattG) are: 2012 - 35%
2016 - 45%
Automotive and industrial batteries:
For automotive and industrial batteries (i.e. traction batteries) there exists an
individual take-back (§ 8 BattG). There are no take-back targets due to the usually
high take-back rate. Owing to the larger size these batteries do not pass into
household waste.
An efficiency review about used battery disposal is to be conducted for consumer
batteries using the data of the Stiftung Gemeinsames Rücknahmesystem Batterien
(GRS) and Herstellereigenes Rücknahmesysteme für Geräte-Altbatterien (HRS). For
automotive and industrial batteries the take-back is organized through the
Fachverband Batterien (battery trade association) of ZVEI.
Relevant Chinese battery environmental protection and recycling regulations
have already been introduced in section 1.3.1.3. Most of them, however, are focused
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on consumer batteries. At present, under the Chinese technical and economic
conditions of a lack of effective recycling, China does not encourage the centralized
collection of used primary cells that have met the national low-mercury or no-mercury
requirements. The collection of used batteries is focused on such used rechargeable
cells as nickel-cadmium cells, nickel-metal hydride cells, Li-Ion cells and lead-acid
cells and such used button-style primaries as oxidized silver.
At the same time, consumers should be encouraged to deliver the used rechargeable
and button-style cells to corresponding facilities for recycling used batteries in the
shops selling cells or electrical appliances to enable sales merchants to recycle them.
1.3.4.8 Reuse, recycling, treatment and disposal
To ensure the same understanding of the meaning of relevant terms the following
explanations are intended to help:
Reuse:
The battery‘s outer casing is stripped off and the metal re-used in steel-making.
Wires and electronic parts could also be reused.
The US-American DoE is currently investigating the reuse of end-of-life traction
batteries (end-of-life is at 80 % of nominal capacity) in stationary renewable energy
systems. Regulations for this reuse still have to be developed, however.
Recycling:
Recycling batteries is a process for material recovery which is used again for
batteries or other products.
Treatment:
Treatment of batteries is a process where hazard waste batteries are so treated that
the products can be landfilled. A minimum treatment must include removal of all
fluids/acids.
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Disposal:
Dumping of treated batteries in landfills.
Directive 2006/66/EC Art 12 addresses treatment and recycling. The main topics are:
- Producers or third parties set up schemes using best available techniques
in terms of the protection of health and the environment, to provide for the treatment
and recycling of waste batteries and accumulators;
- all identifiable batteries and accumulators collected in accordance with Article 8 of
this Directive or with Directive 2002/96/EC undergo treatment and recycling through
schemes that comply, as a minimum, with Community legislation, in particular as
regards health, safety and waste management.
However, MSs may, in accordance with the Treaty, dispose of collected portable
batteries or accumulators containing cadmium, mercury or lead in landfills or
underground storage facilities when no viable end market is available.
The MSs may also, in accordance with the Treaty, dispose of collected portable
batteries or accumulators containing cadmium, mercury or lead in landfills or
underground storage facilities as part of a strategy to phase out heavy metals which,
on the basis of a detailed assessment of the environmental, economic, and social
impacts, shows that this disposal option should be preferred over recycling.
The MSs must make public this assessment and notify draft measures to the
Commission in accordance with Directive 98/34/EC of the European Parliament and
of the Council of 22 June 1998, laying down a procedure for the provision of
information in the field of technical standards and regulations and of rules on
information society services.
In Art. 13 of 2006/66/EC the MSs are called upon to encourage the development of
new recycling and treatment technologies
and to promote research into
environmentally friendly and cost-effective recycling methods for all types of batteries
and accumulators. The MSs must encourage treatment facilities to introduce certified
environmental management schemes in accordance with Regulation (EC) No
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761/2001 of the European Parliament and of the Council of 19 March 2001 allowing
voluntary participation by organizations in a Community eco-management and audit
scheme (EMAS).
In accordance to Art. 9 (Economic instruments) of Directive 2006/66/EC the MSs may
use instruments like differential tax rates to encourage recycling. Art. 14 regulates the
disposal: MSs must prohibit disposal in landfills or by incineration of waste industrial
and automotive batteries and accumulators. However, residues of any batteries and
accumulators that have undergone both treatment and recycling in accordance with
Article 12(1) may be disposed of in landfills or by incineration. The export of waste
batteries and the recycling and treatment outside the EU MSs is regulated by Art. 15.
In compliance with shipments of waste regulation102, waste batteries and
accumulators exported out of EC shall count towards the fulfillment of the obligations
and efficiencies laid down in Annex III to the Battery Directive only if there is sound
evidence that the recycling operation took place under conditions equivalent to the
requirements of the Battery Directive. Detailed rules for the implementation of export
shall be adopted by the waste committee103.
In addition the ELV Directive 2000/53/EC regulates reuse and recycling. As far as
technically feasible, used waste parts have to be removed when passenger cars are
repaired, and the adequate availability of collection facilities within their territory is
ensured (Art.5). Provisions for reuse and recovery of electric vehicles are similar to
conventional vehicles apart from specific requirements on battery recycling.
Article 12 of the ELV supplement (12 September 12 2009.) contains provisions for
the treatment and recycling of batteries.
Furthermore the WEEE-Directive 2002/96/EC promotes the reuse, recycling and
other forms of recovery of such wastes as used batteries to reduce the disposal of
waste (see also 2002/95/EC).
102
Council Regulation (EEC) No. 259/93 of 1 February 1993 on the supervision and control of shipments of waste
within, into and out of the European Community, last amended by Commission Regulation (EC) No. 2557/2001
103
Defined in article 18 of Directive 2006/12/EC of 5 April 2006 on waste
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The Chinese policy is in accordance to the regulations given in 1.3.1.3 as follows:
The manufacturers and importers of rechargeable cells are responsible for recycling
their cells. They must guide, organize and set up the recycling system of used
batteries. The sales merchants of rechargeable and button-style cells and the
merchants using these cells must set up classified recycling facilities for used
batteries. The recycled used batteries in batches must be classified and delivered to
qualified factories (facilities) for resource regeneration or harmless treatment and
disposal.
In China there are at present no relevant national regulations governing the recycling
of power cells. However some local governments have formulated the relevant
standards in advance.
In 2001, the Shanghai Bicycle Industry Association promulgated a Industrial Selfdiscipline Convention to all industrial and commercial enterprises of bicycles. This
Convention required all manufacturers to sign relevant agreements with recycling
institutions for used cells, and the concrete articles concerning the recycling of used
cells must be set up in such documents as a product description and sales guide; all
enterprises engaged in production and sales may not buy and sell lead-acid cells
which leak liquid or electricity or which exhibit a poor performance.
Kunming Municipal Government has already drafted the Management Measures of
Preventing and Controlling the Pollution of Dangerous Wastes in Kunming City
(draft), which specified the management of used batteries of electric vehicles for the
first time. According to the regulations, the sellers of electric vehicles must notify
purchasers in writing that used cells are dangerous wastes and offer the replacement
and recycling services for used batteries. The collected used cells should be
submitted to institutions which have obtained the business license for the disposal of
dangerous wastes. If sellers do not comply with the written notification obligation
under the regulations, the administrative department of environmental protection will
impose a fine of between 200 and 500 RMB on them. If the replacement and
recycling services for used cells are not offered, a fine of between 5,000 and 10,000
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will be imposed. This is perhaps a preliminary document concerning the recycling of
power cells.
1.3.5 Legal Comparison
In this chapter a comparison will be drawn between the existing general battery
regulations in both countries which are mostly related to production and trade,
labeling and informative documents, take back, reuse, recycling, treatment and
disposal, and health hazard materials. It will also focus on newer regulations related
to safety/abuse risks of Li-ion traction batteries.
Both sides have similar regulations governing definitions and the registration of
battery producers and for those organizations responsible for export and import of
batteries.
Battery classification in Germany/EU assigns the traction battery to industrial
batteries. In China the classification is different. Traction batteries are defined as
battery which supplies with power to the powertrain of the EV.
The limitation of hazardous materials in both countries focuses on cadmium and
mercury as hazardous to health. Consequently the content of hazardous materials in
batteries has been reduced by regulations. In Germany/EU the critical concentration
of mercury is 0.0005 % of the battery weight and of cadmium 0.002 % of the weight
of portable batteries. In China the critical concentrations for mercury is 0.0001 % of
the battery weight, which is five times lower than in Germany/EU.
The labeling of batteries in Germany/EU and China gives information about
production dates, voltage, polarity, manufacturer address, etc. In addition, in
Germany /EU the labeling includes an indication of hazardous-to-health materials to
prevent their disposal with household waste. The Chinese Policy of the Technology of
Preventing and Controlling the Pollution of Used Batteries, which relates to disposal
and recycling-relevant labeling has not yet been implemented in the form of national
standards.
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In both countries there exists sufficient product information relating to Li-battery
safety. These documents are partially also accompanying shipping documents. In
Germany/EU there also exists a Safety Data Sheet (SDS) with further information on
hazardous substances identification, first aid measures, toxicology, stability and
information on reactivity.
The Li-Mass limitation plays an important role in the granting of permission for the
air transport of the battery/cell. Because both parties have adopted the UN-test 38.3,
the limitation is identical as follows:
- Li-mass per cell ≤ 1 g ( Li-Metal)
- Li-mass per battery ≤ 2 g ( Li-Metal)
- Energy per cell ≤ 20 Wh ( Li-Ion)
- Energy per battery ≤ 100 Wh ( Li-Ion)
A distinction must be drawn between safety tests reflecting problems during
transport of the batteries (mainly by air) and tests reflecting operating or storage
conditions. The safety tests related to transportation are mostly identical between
Germany/EU and China, because both sides accept extensively the UN-test 38.3.
The tests on operation and storage, however, have the same structure in both
countries but differ in detail with great effect.
Both sides have sufficient regulations for the collection of batteries after use. But
different take-back systems with collecting quotas have already been developed.
Because in Germany a very high take-back rate exists for many years no collecting
quotas have been enacted. Due to the present lack of effective recycling, however,
China focuses at present on older batteries which do not yet meet the national lowmercury or no-mercury requirements.
In both countries general regulations have been passed for the reuse, recycling,
treatment and disposal of used batteries. These regulations are valid in
Germany/EU for industrial batteries (i.e. also traction batteries) as well. In China,
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however, there are at present no relevant national regulations governing the recycling
of HEV, PHEV and EV batteries.
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1.4 Recharging stations for vehicle batteries
Recharging stations are part of the infrastructure and consist of stations and special
parking space. The fields of law are Building and Zoning Law, Road Traffic Law, Road
Use Law and others like Fiscal and Tax Law.
EVs have within them the energy source and power electronics capable of producing
the 60 Hz AC electricity that powers homes and offices. When connections are added
to allow this electricity to flow from cars to power lines, it is called "vehicle to grid"
power, or V2G. One typical EV can output over 10kW, the average consumption of
ten houses. The key to realizing economic value from V2G is the precise timing of its
grid power production to fit within driving requirements while meeting the time-critical
power "dispatch" of the electric distribution system, the recharging station.
Only in the U.S. is there a first bill from 2009 which requires electricity utilities to
compensate owners of EVs for electricity returned to the grid at the same rate they
pay for electricity to charge the battery104.
Different international registers of recharging stations exist and are updated on some
websites105.
1.4.1 European Law
The main obstacles in arriving at a fully operational and competitive internal market
relate amongst other things to issues of access to the network, tarification issues and
different degrees of market opening between MSs. The European Commission has
announced plans to promote the development of a network of publicly accessible
high-voltage charging stations around Europe. It also aims to produce European
safety and technical standards for these stations by 2011.
The existing Directive 2003/54/EC106 concerning common rules for the internal
market in electricity establishes common rules for the generation, transmission,
104
105
www.udel.edu/V2G
www.lemnet.org for light electric vehicles; for Germany also www.ebike-tankstellen.de and www.drehstromnetz.de
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distribution and supply of electricity. It lays down the rules relating to the organization
and functioning of the electricity sector, access to the market, the criteria and
procedures applicable to calls for tenders and the granting of authorizations and the
operation of systems.
The technical rules named in Art. 5 are intended to ensure the interoperability of
systems and are to be objective and non-discriminatory.
1.4.2 German Law
Recharging stations need to be authorized. There are two different models: private
and public stations. Private stations can be set up in a simple way. More complicated
are public stations on private or public ground. Public ground is defined as space
dedicated to public thoroughfares. Regarding this space, recharging stations also
need parking space to serve the purpose. Important is the classification. The heading
is the legal term ―restriction of public access in road traffic‖. This is part of the Road
Traffic Law (StVG) and the Road Traffic Regulation (StVO), which also could be
called the Highway Code107.
The Road Traffic Law contains the basic regulations for road traffic in Germany and
covers, together with the driving license regulations (FeV), the Vehicle Registration
Regulation (FZV), the Road Traffic Regulation (StVO) and the Road Traffic Licensing
Regulations (StVZO), as far as possible the road traffic regulations108.
The StVO explains general traffic regulations, defines road signs and allows different
kinds of traffic fines. It must be checked whether recharging stations are automatic
vending machines and if this could affect road traffic, § 33 I. § 45 I No. 6 and § 46 II
together with § 12 StVO regulate exemptions from and permits for common rules
including parking rules. There is no legal right to permission. Based on this, NRW
106
107
108
Council Directive 2003/54/EC of the European Parliament and of the Council of 26 June 2003 concerning common
rules for the internal market in electricity and repealing Directive 96/92/EC - Statements made with regard to
decommissioning and waste management activities
StVG – Straßenverkehrsgesetz; StVO – Straßenverkehrs-Ordnung
FeV - Verordnung über die Zulassung von Personen zum Straßenverkehr (Fahrerlaubnis-Verordnung); FZV –
Fahrzeugzulassungs-Verordnung; StVZO - Straßenverkehrs-Zulassungs-Ordnung
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allows local authorities to label public charging space with special road signs, sign
283 (absolute stopping restriction) or sign 286 (restricted stopping restriction) with an
additional plate ―electric vehicles during recharging free‖ (German: Elektrofahrzeuge
während Ladevorgang frei). Also the signs 314 (parking space) can be added with
and additional plate ―only for electric vehicles during recharging‖ (German: Nur für
Elektrofahrzeuge während des Ladevorgangs). This order is limited to three years for
the present.
Figure 19: Sign 283 for Recharging Space of Vehicles (Berlin); [Source: Wikipedia.de]
The StVG does not give priority to different powertrains. There will presumably be no
change to implement special allowances for electric vehicle parking space such as
exist for residents or handicapped people, § 6 I No. 14 StVG. There is an opinion that
this matter should be handled in a similar fashion. But with regard to parking spaces
to compensate for handicaps or disadvantages suffered by residents a special
authority had to be granted. This is covered by the equality principle of Art. 3 GG. In
addition this relates to a certain group of people and not vehicles with a special kind
of transmission. And in any case § 6 StVG is soon to be simplified, which is why an
additional entry at this time would be counterproductive.
Apart from this recharging stations need to be authorized as special use facilities with
regard to legal road classification. Following the Town and Country Planning Code
(BauGB)109 space dedicated as public thoroughfares can be classified as special
use, supply zone or special areas. Municipalities have to ensure they act in
109
Baugesetzbuch (BauGB) - Town and Country Planning Code or Federal Building Code
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conformity with relevant financial regulations, public procurement law, data security,
etc110.
In addition to this, the right of the energy supplier to use recharging stations exists. A
final definition is not yet provided for in the legislation. The Energy Economics Law
(EnWG)111 is relevant here. Energy suppliers can have access to charging stations of
other companies in accordance with § 20 I 1 EnWG. Anyone is must be granted
access to energy grids in a non-discriminating way. The recharging structure is
defined as the power grid § 3 No. 16 EnWG. Power grids have a legal definition in § 3
No. 16 EnWG as electricity networks using one or more voltage levels. Given the lack
of an explicit definition for electricity networks, § 3 No. 3 EnWG, defines the operators
of electricity networks, as operators of electricity transmission or distribution
networks. Accordingly, the concept of the electricity network coveres both
transmission and distribution networks. A charging infrastructure would therefore be
classified as distribution. It meets all technical requirements involved in a power grid.
It is not to be classified as a customer installation as an undetermined number of final
consumers are to be supplied and their sole task is the transport of energy. Within
provisions of § 5 and 13 NAV, the interpretation of the Federal Network Agency and
the definition of the jurisdiction, a customer's installation must meet two essential
criteria: it must connect the final consumer and it must start from the house
connection fuse or the meter system. These criteria are not met by public charging
stations.
Final consumers are referred to in § 3 No. 25 EnWG as customers who need the
energy for their own use. Public recharging stations are not a network connection
between a particular group of final consumers and the power supply grid, but rather
an indefinite number of end users are addressed. It is therefore not part of the EV if
these vehicles are to be qualified as customer equipment, but a simple extension of
their normal power grid to which different, previously not identifiable final customers
will connect with their customer facilities, the on-board unit in electric vehicles. In
110
111
Further information at Deutsches Institut für Urbanistik (German institute for urbanistics), Stefanie Hantke, LL.M.
Gesetz über die Elektrizitäts- und Gasversorgung (Energiewirtschaftsgesetz - EnWG) of 7 July 2005, amended 2011
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addition, in the final stages recharging stations will possibly feed power into the public
grid using "vehicle to grid (V2G) technology". The recharging station will thus be an
integral part of the grid transporting energy in both directions. This is also not a
typical feature of a customer installation.
Many V2G business models and cost calculations as well as recommendations for
standards exist.
In addition, according to the EnWG and the underlying Directive 2003/54/EC. every
final consumer has the right to a free choice of electricity suppliers.
This right requires essentially that the electricity supplier has full access to the
associated transport equipment for the purpose of supplying customers. Only if it is
deemed to be unreasonable would third power suppliers not be granted access to the
charging structure. This chance is very small and the electricity supplier bears the
burden of proof.
A German application rule exists regarding plugs and couplers. This VDE application
rule VDE-AR-E 2623-2-2:2009-10112 was made for vehicle couplers with pins and
contact sockets of the standardized ratings. A rated operating voltage of 500 V AC,
50 Hz to 60 Hz, and a rated current up to 63 A (AC) or 70 A (single phase), for the
conducted charge of electric vehicles are intended. The study on EV Codes and
Standards is concerned with this application rule.
Figure 20: Example for plugs (see VDE-AR-E 2623-2-2:2009-10)
112
Stecker, Steckdosen, Fahrzeugsteckvorrichtungen und Fahrzeugstecker – Ladung von Elektrofahrzeugen Teil 2-2:
Anforderungen und Hauptmaße für die Austauschbarkeit von Stift- und Buchsensteckvorrichtungen
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1.4.3 Chinese Law
The Chinese government has not yet promulgated relevant policies for charging
stations. National standards for charging stations are being formulated, but local
governments have promulgated construction standards for charging stations. In July
2010, the Quality Supervision Bureau of Beijing promulgated a technical document of
standardized guidance entitled Charging Stations of Electric Energy Supply and
Security Technology of Electric Vehicles, which put forward the requirements for
the grading, function, composition, technology and location of charging stations in
Beijing.
According to the storage energy and charging service capacity of power batteries,
charging stations are classified into four grades. The battery storage energy of the
first-grade charging stations is no less than 6,800 kWh, or the one-way distribution
capacity is no less than 5,000 kW, capable of offering battery replacement or
recharging services to over 200 commercial vehicles of large and medium types or
over 500 passenger cars every day. The battery storage energy of the fourth-grade
charging stations is less than 1,700 kWh, or the one-way distribution capacity is less
than 1,000 kW, capable of offering battery replacement or recharging services to less
than 40 commercial vehicles of large and medium types or less than 100 passenger
cars every day.
According to the principle of using land economically and with a view to the use
features of electric vehicles, the standard puts forward that charging stations should
be built together with existing public service facilities, and they should not affect the
safety and use functions of the original facilities. According to an appraisal of traffic
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influence, the charging stations in the urban area should be built near urban roads,
instead of near the cross-roads of urban trunks and sections with busy traffic. The
charging stations of electric vehicles for public transport should be built inside bus
terminals, and the charging stations of other exclusively electric vehicles should be
built inside corresponding stopping stations. Charging stations should not be built in
places with violent vibrations, high temperatures and in lowlands with possible
waterlog. As to charging stations adjacent to places with much dust or with corrosive
gas, they should be built on the lee of the smallest frequency wind direction.
Collision-proof columns (pillars) should be built near charging machines of charging
stations, with a height of no less than 0.8m. The places for charging connectors of
charging machines should have obvious written marks and warning signs. Safety
warning signs should be pasted at the conspicuous places of charging stations.
Inflammable gas warning systems should also be set up in such places as charging
areas and battery storage areas. The distance between the boundary line of the
explosive and dangerous areas of charging stations, the battery charging equipment,
the batter replacement facilities and dangerous equipment built together with the
gasoline and gas filling stations to the outer edge of diesel equipment must be not
less than 3 m.
In addition, this standard has requirements for the traffic lane and parking spots in
charging stations. The entrance and the exit of charging stations must be set up
separately. There must be at least two lanes from the entrance to the exit. The width
of the lanes in charging stations must be no less than 4m, and the turning radius of
the roads in stations must not be less than 9m. Asphalt road surfaces must not be
laid in charging areas, battery storage areas and replacement areas.
1.4.4 Legal Comparison
Neither party has advanced federal regulations for the implementation recharging
stations. First legal steps are being taken to implement this technology in the public
domain. Many legal questions exist not only with regard to the installation of
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recharging stations but also their operation. Today the main focus is on
codes&standards to prepare uniform conditions for customers and producers.
China has classified charging stations into four grades depending on storage energy.
Existing German special allowances to dedicate parking space as public charging
space have not been transposed into main laws and general practice yet.
Federal regulations and rules have to be implemented to obtain common approval
rules and signs for recharging stations.
1.5 Stations for quick change of vehicle batteries
1.5.1 Europe and Germany
In the EU there are no regulations regarding the quick change of vehicle batteries, or
those that there are have draft status.
In Germany as well there are no regulations. German vehicle OEMs do consider this
will be the case in future. There are too many vehicles and vehicle sizes on the
market. Regulations or standards for battery design are therefore not possible or
useful.
1.5.2 China
In China there are no regulations regarding the quick change of vehicle batteries, or
those that exist have draft status.
1.6 Information concerning the Energy Market
1.6.1 European and German Law
Regulations regarding the electric transmission network are not covered by one main
transmission law. Mention should also be made of EnWG and the Transmission
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Development Law (EnLAG)113 for grids with ≥ 380 kV. This wide field can be only
reviewed in extract form. A lot of work is to be done by the parties involved. No
guidelines for process control exist and just little standardization.
§ 43 EnWG regulates transmission lines ≥ 110 kV and certain underground
transmission cabling (coastal area, some cross-border HVDC transmission lines,
network connections offshore). In some kinds of transmission line underground
cabling may need to be planned for certain projects.
Approval is split into regional planning procedure and preliminary examination
relating to regional planning policy as a first step. Then follows the planning
assessment
and
approval
procedure.
The
regional
planning
procedure
(Raumordnungsverfahren – ROV, based on § 15 Regional Planning Act – ROG)114 is
one of the traditional instruments of regional planning and takes up to one year.
Based on the Energy Concept of the Federal Government of 28 September 2010
nationwide network expansions must be backed by a network expansion plan. The
Federal Network Agency will be granted special powers to make investment
decisions (Art. 22 of 2009/72/EC)115 concerning common rules for the internal market
in electricity. The Federal Government must implement a Federal Transmission Plan
and sample planning guidelines to speed up and standardize the approval process.
1.6.2 Chinese Law
In China there are no special regulations regarding electric mobility from an electric
transmission network, or those that exist have draft status.
113
114
115
Law on Development of Transmission Grids (Energieleitungsausbaugesetz - EnLAG) of 21 August 2009
Regional Planning Act - Raumordnungsgesetz (ROG) of 22 December 2008
Directive 2009/72/EC of the European Parliament and of the Council of 13 July 2009 concerning common rules for
the internal market in electricity and repealing Directive 2003/54/EC
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2
Results, Conclusions and Recommendations
2.1 Results and Conclusions
The study ―Analysis of European/German and Chinese Regulations regarding electric
vehicle infrastructure for road traffic‖ was divided into six work packages. Each
package examines and compares European/German and Chinese laws and
regulations.
Accepted
Chinese
national
standards
are
published
by
the
Standardization Administration of the People's Republic of China (SAC), which was
formed under the Standardization Law in 2001 to execute the standardization work in
China on a national level. For this reason the standards GB (Guóbiāo – mandatory
national standards) and GB/T (Guóbiāo tuījiàn – voluntary national standards) are
also part of this study on regulations. European Regulations are published by the
European Parliament and of the Council. The main results are as follows:
- With respect to climate change, regulative rules will force industry to place more
new-energy vehicles on the market with appropriate market shares. The European
Framework Directive (Directive 2007/46/EC) on vehicle type approval includes the
mandatory application of certain UNECE Regulations, especially UNECE-R 100.
The Administrative Rules on Access for New-energy Vehicle Manufacturers and
Products in China have a similar function. Relevant National Standards are named
explicitly by these Framework Rules.
- Product liability is similar and established for products for end customers. EV
vehicles recently obtained a single or small-series approval, which is an
exceptional approval as an experimental development. New regulations will
amend this procedure. The European type approval regulation including the
subsequent implementing measures is unique at present. With respect to climate
change, regulative rules will force the industry to place more new-energy vehicles
onto the market with appropriate market shares.
- Users of an EV may benefit from reduced tax for vehicles and electric energy as
an aid to market introduction in China and in many European countries but up to
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now in Germany only for vehicle user tax. Permissions for high-pollution vehicles
in urban areas, for example, will give backing to the use of green vehicles.
- The battery classification in Germany/EU assigned the traction battery to industrial
batteries. In China this classification to distinguish them from automotive batteries
is different, however, and the EV battery is defined as battery which supplies
power to the powertrain of the EV. Both sides have similar regulations for battery
producers and dealers. Labeling of batteries is seen as important.
- In the field of road and rail transport for batteries, the ADR and RID agreements in
the EU are guidelines for national legislation. There are also regulations for the
transport of dangerous goods in China. A similarity with ADR and RID is evident.
- For air transport of Li-batteries both sides accepted the dangerous goods rules of
the International Civil Aviation Organization (ICAO) and the International Aviation
Association (IATA), which have been transposed into national rules. The most
important ICAO rule is UN 38.3, which also fixes the maximum Li-content of cells
and batteries. In sea transport similar restrictions exist pursuant to the
International Sea Transport Dangerous Goods Rules (IMDG).
- Hazardous materials in batteries like cadmium and mercury have been reduced by
regulations. In China the critical concentration for mercury is 0.0001 % of the
battery weight, which is five times lower than in Germany/EU.
- Safety tests related to transportation, especially to air transportation are accepted
by both countries. Safety tests related to operation and storage have the same
structure in both countries but differ in detail. Here a joint discussion about
possible harmonization would be helpful.
- There are as yet no fire safety regulations for EVs with Li-Ion batteries.
Nevertheless there are general regulations which apply to cars.
- Regulations for the collection of used batteries exist on the part of both parties as
general regulations for the reuse, recycling, treatment and disposal of used
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batteries. In China there are as yet no relevant national regulations governing the
recycling of EV cells.
- At this moment during the stage of standardization, mandatory regulations for the
implementation recharging stations like plugs and billing do not exist. Both the
station and the parking lot have to be taken into consideration for the effective
implementation of recharging stations.
2.2 Recommendations
In the conduct of this study it was possible to achieve a multifaceted understanding of
the respective status and process of regulations.
With the current situation at the end of 2010 there is no urgent need for action
regarding harmonization of most regulations for EVs or batteries in road traffic. The
regulations in force cover the implementation of EV production. The latest regulations
are very similar in Europe and China. The main fields where regulations are
implemented are certification of EV, drive trains and batteries. An open point,
however, is the lack of special fire safety regulations for EVs.
Electric propulsion technology requires special attention from a regulatory
perspective. The elements of a European harmonized legislative framework for the
approval of electric vehicles are electric safety, amendment to the Framework
Directive and the review of other type approval acts.
In view of this, on the one hand existing vehicle type approval requirements should
be reviewed to take account of the specific characteristics of electric propulsion and,
on the other, there could be potential issues associated with this technology that are
not relevant for conventional vehicles. As a result alternative propulsion technologies
should be subject to separate type approval operations so that test requirements take
full account of the specific technologies and potential risks that are not yet covered.
Furthermore the ELSA group at UNECE will continue its work on considering postcrash safety requirements to be included in UNECE Regulations. Battery safety test
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problems reflecting operation and storage differ in detail, which is known by experts.
Endeavours by the authorities to review and adapt test conditions bilaterally and on
an international level would be very important with respect to the market introduction
of EVs on both sides.
Work must also be done with regard to standardization of the charging system of the
batteries used in electric vehicles. The aim is to mandate the European
standardization bodies to recharge all types of batteries of electric vehicles operating
in all EU States. For this issue no legal approach is recommended.
Federal regulations and rules have to be implemented to obtain common approval
rules and signs for recharging stations.
In view of the very similar state of the art, new regulations are being developed
similarly, and some are still drafts. It is therefore recommended that the adoption of
new laws and standards in China and the EU and Germany be pursued. Each field
should be monitored, but the main focus should be on the approval of EVs, batteries
and legal benefits for users. The Ministries involved in the partnership should ensure
a mutual communication arrangement to exchange new legal developments. This
should proceed in the early stages in order to provide an opportunity to support the
laws and standards drafted in the form of comments of technical nature by experts
involved. Joint workshops would be a good way of doing this. This idea is also behind
the recommendation to prepare together for meetings in international working groups.
With this preliminary coordination on the part of both parties it would be very helpful
to work out a mutual point-of-view which they will jointly represent in the working
groups. The aim to push the respective national interests should be supported by the
discussion and sizing up of a common denominator.
Furthermore the standardization of key components is an important factor for efficient
production in the electric mobility market. Legal requirements can support
standardization endeavours, if safety issues are regulated by law for example.
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The experience thus gained can also foster future collaboration regarding EVs and
vehicle batteries.
Working Party on the GCSFP Study
―Analysis of European/German and Chinese Regulations regarding electric vehicle
infrastructure for road traffic‖:
Stefan GARCHE, Fuel Cell and Hydrogen Network NRW
Alexandra WOLFF, Fuel Cell and Hydrogen Network NRW
Jonathan GUO, CATARC
Jingjing LIANG, CATARC
Ping YAN, CATARC
Dr. Harry DÖRING, Centre for Solar Energy and Hydrogen Research (ZSW)
Special thanks to:
Walter Pütz, Hilde Bonsu, Daimler AG
Christian Förster, Christian Kolf, TÜV Nord Mobilität GmbH & Co. KG
Dr. Christian Kessel, Bird & Bird
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Annex 1 - Overview on the Legal Systems116
Europe
The beginnings of the European Union (EU) were the European Coal and Steel
Community and the European Economic Community (EEC) founded in 1951 and
1957. The founding members were Belgium, France, Italy, Luxembourg, the
Netherlands and West Germany. The today´s EU was formally in 1993 by the Treaty
of Maastricht. In order to harmonize the European Community (EC) domestic market,
the EC build up some collective goals. Among other things, the collective economic
policy is one major issue. To fulfil the idea of an integrative development, the EC
enacts directives, regarding issues of a free visible trade, environment and energy
policy as well as the traffic policy. In 2009, the European Union consists of 27 MSs.
The EU is often described as being divided into three areas of responsibility, called
pillars. The original European Community policies form the first pillar, while the
second consists of Common Foreign and Security Policy. The third pillar originally
consisted of Justice and Home Affairs, however owing to changes introduced by the
Amsterdam and Nice treaties, it currently only consists of Police and Judicial Cooperation in Criminal Matters.
Institutions of the European Union are the European Commission, the European
Parliament, the Council of the European Union and the European Court of Justice.
The Commission is the executive arm and responsible for initiating legislation. The
Parliament forms one half of the legislature and the Council the other half. It is an
organised platform where national ministers responsible for the area of policy being
addressed, meet. The Council also has some executive functions in relation to the
Common Foreign and Security Policy. The European Court of Justice is the highest
court of the Union. His function is to interpret and apply the Treaties and the law of
the EU.
116
From GCSFP-study „Analysis of European/German and Chinese Regulations regarding a hydrogen infrastructure for
road traffic―, September 3 2009, Dusseldorf
I
GCSFP Study - Regulations on a electric vehicle infrastructure for road traffic
The central sources of European law are the Treaties, negotiated by the MSs. The
articles of agreement in particular are called primary law. These treaties accredit the
European Community to make their own legal acts, called the secondary law.
The main legislative acts of the EC come in two forms: Regulations and Directives.
Regulations become law in all MSs the moment they come into force, without the
requirement for any implementing measures, and automatically override conflicting
domestic provisions.
Directives require MSs to achieve a certain result while leaving them a certain scope
in how they want to process and achieve the result. When the time limit for
implementing directives passes, they may, under certain conditions, have direct effect
in national law against MS.
Decisions offer an alternative to the two above modes of legislation. They are legal
acts which only apply to specified individuals or companies. They are often used in
Competition Law, or on rulings on State Aid, but are also frequently used for
procedural or administrative matters within the institutions.
As a result, the EC Regulations and directives need to be considered as a kind of
supranational law, which has to be regarded by every MS.
However, a common feature of the EU's legislative procedures is that almost all
legislation must be initiated by the Commission, rather than MSs or European
parliamentarians. The two most common procedures are co-decision, under which
the European Parliament can veto proposed legislation, and consultation, under
which Parliament is only permitted to give an opinion which can be ignored by
European leaders. In most cases legislation must be agreed by the council.
National courts within the MSs play a key role in the EU as enforcers of EU law, and
a "spirit of cooperation" between EU and national courts is laid down in the Treaties.
National courts can apply EU law in domestic cases, and if they require clarification
on the interpretation or validity of any EU legislation related to the case it may make a
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reference for a preliminary ruling to the European Court of justice. The right to
declare EU legislation invalid however is reserved to the EU courts.
In regards with the hydrogen infrastructure, the EC directives have to be considered
in nearly every aspect of fabrication, transportation, filling stations and the utilization
of hydrogen cars. In every part of these topics, directives of environment, such as
labour and health protection, tax law and authorization law, play an important role.
There is not much space for the national legislation, because most aspects are
already regulated by EC law. In fact there are EC directives that are classifying
hydrogen as a dangerous good, as well as there are regulations concerning packing
and identification. The security management and the engineering departments of the
factories that are in charge of the production and storage are entirely regulated by
the EC in their processes. In addition to that, the safety regulations for employees are
specified by EC law too. This also applies to freight and transportation where security
standards are highly determined by regulations. The approval of hydrogen cars for all
MSs is now regulated by EC type approval which is subject to ongoing
considerations. In accordance with that, the EC controls the advancement of
renewable energies.
Germany
The Federal Republic of Germany consists of 16 federal states. These have partsovereignty and can enact own laws in certain fields of legislation. The State‗s
authority can be subdivided into the legislative power, the judicial power and the
executive power. These powers are independent from each other and exist on the
level of the Federation and on the level of the States. The States basically have the
power of legislation, if there is no exclusive or additional power for the Federation.
This is mentioned in Art. 70 ff of the basic constitutional law. For example the
citizenship and the defence policy are subjects regulated by the federal government.
There are also parts of the competing legislation, which means that the Federal
States are allowed to enact regulations unless the Federal Republic does not make
use of his legislation authority. If Federal States do not make use of their legislation
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power, the Bundestag is allowed to enact laws, which require approval of the
Bundesrat.
On the level of the Federation, the national parliament – the Bundestag (Federal Diet)
– decides about new legislation with a simple majority. New laws have to be accepted
by the Bundesrat (federal council), too, which is the representation of the states. The
Bundespraesident (President of Germany) afterwards signs the new law. He has the
right to refuse if in his opinion it is in conflict with the constitution. By publication in
the Bundesanzeiger (federal paper) the new law comes into force. For some laws it is
sufficient if there are no objections from the Bundesrat. Changes in the constitution
itself can only be obtained by a majority of two thirds of both Bundestag/parliament
and Bundesrat/council.
Regulations exist in law and ordinances. Laws were enacted by the parliament
(Federal law by the Bundestag and Federal States Law by the respective Landtag).
Ordinances were enacted directly from the government; empowerment therefore is
designated by law.
Law can determine, if approval to the ordinance of the respective parliament is
necessary. As a basic principle, law provides a framework, which has to be
specialized by ordinances. In regards with the hydrogen infrastructure, regulations
are distributed to the Federal States and the Federal Republic. Although main
subjects are matter of the Federal Republic legislation, the Federal States have the
legislative competence to regulate the detailed achievements. The Federal States
have also their own source of income, which is based on their own taxes like the
inheritance tax. Moreover, a part of the building law or environmental law is regulated
by the Federal States. In addition to that, the principle of local self-administration
allows the communities to legislate some of their own affairs. An example for this is
the industrial tax, whose amount is regulated by the communities.
The German law system is divided into the sections of private or civil law, public law
and criminal law.
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Private law and civil law are synonymous terms. This area deals with relations of
equal subjects, i.e. natural or legal persons. German civil law is codified in the Civil
Code (BGB) and in some special law codes. The BGB is subdivided into a Book of
General Provisions, the law of obligations, the law of property, the law of the family
and the law of succession. Trade law and corporate law (codified in the Commercial
Code (HGB), labour legislation and rental law (codified in the BGB) are also part of
civil law.
Public law includes constitutional law and administrative law. Administrative law is the
law of the executive. It covers federal regulations about the enactment of a formal
administrative action and possible legal actions against it. In case of administrative
inactivity the authority can be sentenced to act by a court for administrative affairs.
Administrative law covers – partly by laws of the Federal States – a multitude of
special sections, e.g. police, construction and building, environmental protection,
social affairs and taxes.
Federal administrative law is determined by the Administrative Courts Act (VwGO)
and the Administrative Procedure Act (VwVfG). The VwGO regulates different kinds
of legal actions by which the citizens can defend themselves against both
administrative action and –inactivity. Examples for important laws of the Federal
States are the laws covering the rules for the civil servants and duties and
organisation of the police of the states.
Sources of the criminal law are the Criminal Code (StGB) and the Criminal Procedure
Act (StPO). There are no regulations of the individual states in this branch of law, but
on the level of the executive, different interpretations of some national laws may
occur in the States.
Infringements of the public order, e.g. of the Road Traffic Regulations (StVO) are
punished in accordance with the Lesser Offences Act (OWiG). This law is in force
nationwide.
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Each of the sections of law mentioned above has its own rules of court procedure
described in individual procedural codes.
The basis of all sources of law is the German constitution, the Basic Law. The
structure of the German court system – stages of appeal, competences of courts, and
personnel of courts – is regulated by the Law on the Constitution of Courts (GVG) for
all branches of law.
The jurisdiction is divided into five different steps, the county court, the regional court,
the higher regional court, the federal court of justice and the federal constitutional
court. Besides there are also some special courts (e.g. labour court, social court). For
every kind of public law, the way to the administrative legal process is opened.
The federal court of justice is the final level of jurisdiction. In some infrequent cases
and principle questions, the federal constitution court reviewed the compatibility with
the basic constitution law.
In summary: Basic guidelines for the regulation of a hydrogen infrastructure are
already given by the EC. The national legislation also has a certain scope concerning
the detailed provisions. E.g. for the location of hydrogen filling stations the detailed
permission requirements, the issue of hydrogen self-service and the building law that
refers to regulations about how filling stations and garages for hydrogen vehicles
need to be constructed.
China
The structure of Chinese law is similar to parts of the German law, although the state
structure within the administration does also exist as different judicial authorities.
Higher-ranking law is enacted by the National Peoples‘ Congress (NPC). It is the
single chamber Parliament of a unitary (non-federal) state and ―the highest organ of
state power‖. The Constitution provides that the NPC (constitution Art. 62 no.1), inter
alia, enacts and amends basic laws or statutes (falu) concerning criminal offences,
civil affairs, the state organs ―and other matters‖ (in no way specified or
characterised), that it elects and has power to recall the President of the Supreme
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People‘s Court and the Procurator-General, that it decides on the establishment of
special administrative regions and the system to be instituted there and that it
exercises ―such other functions and powers as the highest organ of state power
should exercise. The NPC is new appointed every five years. It contains a permanent
Standing Committee, which meets more times due to fewer members. The Standing
Committee of the NPC has power to enact laws or statutes ―with the exception of
those that should be enacted by the NPC‖ and to enact, when the NPC is not in
session, partial supplements and amendments to statutes enacted by the NPC
provided the basic principles of the statutes are not contravened. The Standing
Committee also has power to interpret statutes and to annul various administrative
rules, orders, regulations and decisions that contravene the Constitution or the
statutes.
The State Council (or Central People‘s Government, in effect a Council of Ministers
and those having the status of Ministers) has power to adopt administrative
measures (banfa), to enact administrative rules and regulations (guiding) and to
issue decisions (jueding), resolutions (jueyi) and orders (mingling) that are in
accordance with the Constitution and the statutes. It also directs and administers civil
affairs, public security, judicial administration, supervision and other matters. On 10
January 1985, the Standing Committee of the NPC entrusted the State Council with
the power to enact provisional rules and regulations in respect of the reform of
China‘s economic structure and matters of opening up to the outside world. The fact,
that the government is empowered to enact regulations is a restriction of the principle
of the division of powers from the view of a western constitutional state.
The Ministers in charge of Ministries or Commissions of the State Council issue
orders, directives and regulations under the Constitution and within the jurisdiction of
their departments. All normative acts issued by the State Council and its Ministries
and Commissions, like those of the NPC and its Standing Committee, have the force
of law and must be enforced throughout the country (Constitution Art. 100). In
addition to that, the official interpretations of the Highest Peoples‘ Court as well as the
regional legislation acts belong to that.
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Although China is a central state, it has local legislation. The People‘s Congresses of
Provinces, Autonomous Regions and the Municipalities directly under the Central
Government (the major cities of Beijing, Shanghai, Tianjin and Chongqing since
1997) and their standing committees may, in accordance with their authority as
prescribed by law, adopt local regulations which prevail within their local districts.
These should be reported to the State Council for their approval and recording.
There are, in China, 23 provinces (including Hainan Island since December 1987)
varying in population from 20 to over 100 million per province, four municipalities
directly under the Central Government (i.e. cities having the status of provinces) and
five autonomous regions peopled by non-Han minorities. At a lower level, there are
125 prefectures and 40 autonomous or administrative regions and at a still lower
level, nearly 2,000 counties, banners and autonomous banners, special regions and
a forest region.
Justice is based on two systems, the People´s Court and the People´s Procuratorate.
According to Art. 129 of the constitution, people`s procuratories are ―The State
Organs for Legal Supervision‖. Their functions are defined by the Organic Law of the
People´s Procuratorates. Two instances are designated for the civil and criminal trial.
Second trial judgments and orders as well as those of the Supremes Peoples‘ Court
in first instance, enfold legal effect.
Besides the system of ordinary courts, there are special courts like the Military
Courts, Maritime Courts, Forest Courts and Railway Courts. In the area of criminal
law, there are five main punishments, including death penalty or the deprivation of the
political rights (Art. 28, 45, 139, 155 I, 43 I, 29 of the constitution). Regarding
administrative law, a comprehensive violation of law does not exist. In fact, the
administrative law consists out of several single enactments, affecting different fields
of administration.
Concerning a hydrogen infrastructure, Environmental Law, Dangerous Goods Law
and the respective Standards are mostly relevant for the legal framework. National
laws basically contain general provisions, responsibilities and legal liabilities.
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In contrary to German legislation, China established national standards, which have
legal effects. Based on the Standardization Law of the P.R.C., the Standardization
Administration of the P.R.C. (SAC) is empowered to set up national guidelines.
Another important constitution establishing national standards in the field of
environmental law is the State Environmental Protection Administration (SEPA).
Responsible for standards concerning hydrogen is the National Hydrogen
Standardization Technical Committee (SAC/TC309). It was established in March
2008 as a part of the SAC. The secretariat works at the China National Institute of
Standardisation. The SAC/TC309 is mainly responsible for hydrogen production,
storage and transportation. The Counterpart is the International Organisation for
Standardisation Committee of hydrogen (ISO/TC197).
Standards are divided into mandatory and voluntary ones. The mandatory standards
are comparable with a legal ordinance and have legal effects. Voluntary standards
are guidelines for the industry and comparable with the European and German
Standards. Chinese Standards, enacted by the SAC are GB for mandatory and GB/T
for voluntary standards. GB stands for Guojia Biaozhun, the phonetic transcription of
the word ―national standard‖. The standards often include technical requirements as
well as safety and environmental provisions and aspects of health protection.
Comparison
Influences of the German legal system are visible in the Chinese Legal System,
especially in the field of the German civil law. Although several structures are similar,
the final legal practice is different due to the way the law is applied. As similar to
European Countries, International Agreements have priority in Chinese legislation.
Like in European and German Law, main provisions for the hydrogen infrastructure
are listed in the Environmental Law, including permitted emissions and Labour and
Safety Law. Both systems also have several provisions for the handling with
dangerous goods and their classification. Characteristic for China law is the
Standardisation Law and it´s Detailed Implementing Rules. They include different
areas, wherefore national standards are designated. Standards shall be enacted to
provide industrial standard collisions. The Standardisation Law differs between
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voluntary and mandatory standards. The classification depends on issues the
standards are established for, e.g. product safety. This is a disparity to European and
German Law, where standards are voluntary and indirectly mandatory by
implementation or reference through existing regulations.
Furthermore, differences are visible in the field of substantiation of legislation. Chinas
laws and regulations are mostly diversified, which can be publicly displayed by case
law, for example by the Supremes Peoples‘ Court or the National Peoples‘ Congress.
Chinese Law including national standards leaves a certain scope regarding the
application of them. Chinese law functions more as a guideline in general. Concrete
provisions could be found in national standards and in several regulations or orders.
Like Europe and Germany, China emphasizes the development of renewable energy
technologies. Hydrogen and fuel-cells are listed in national energy programmes and
shall be encouraged. Administration in China is mainly unknown, but due to same
targets in regard of the introduction of hydrogen and fuel cells, great administrative
barriers are not expected.
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Annex 2 – The status quo of the standard system of Chinese electric vehicles
1. So far, Chinese government has promulgated 36 standard items of electric vehicles (excluding 6 items of electric motorcycles)
Including:
 35 items of national standards, and 7 items of standards of auto industry;
 11 items for purely electric autos, 6 for hybrid power autos, 4 for fuel battery autos, 8 for power battery, and 2 for electric autos
and controllers;
 4 items for energy supply and charging.
2. 12 items having passed the review of the Standard Committee and waiting for application and promulgation (see Schedule 2)
Including:
 6 items of national standards, and 6 of auto industry standards;
 1 item of modification standard, and 11 items of newly-formulated standards;
3. 37 items being planned which need to be modified urgently in the same industry (see Schedule 3)
Chiefly including the safety requirements for low-speed electric autos and electric autos (modified), hybrid power auto discharge and
energy consumption (formulation and modification), hybrid power system assembly, the modification of QC/T 741-744 power battery
standards (or transferred to international ones), the series standards of power battery system grades (performance, safety, reliability,
etc.), and the relevant charging standards.
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Table 1: The List of Published Standards of Electric Automobiles—36 Items
Category
Purely
electric
(chapter 1.1)
Standard
number
Standard name
State
GB/T 18384.12001
Part One of Safety Requirements of Electric
Automobiles: Vehicle-borne Energy Storing Device
Modification, draft, having not
yet been approved
GB/T 18384.22001
Part Two of Safety Requirements of Electric
Automobiles: Function Safety and Failure Emergency
Protection
Modification, draft, having not
yet been approved
GB/T 18384.32001
Part Three of Safety Requirements of Electric
Automobiles: Personnel Electric Shock Emergency
Protection
Modification, draft, having not
yet been approved
GB/T 4094.22005
Marks of Controllers, Indicators and Signal Devices of
Electric Automobiles
Presently in force
GB/T 195962004
Terminology of electric automobiles
Presently in force; to be
modified
GB/T 183852005
The Test Methods of the Power Performance of
Electric Automobiles
Presently in force
GB/T 183862005
The Test Methods of Energy Consumption Rate and
Driving Range of Electric Automobiles
Presently in force
GB/T 183872008
The Limit Value and Measurement Methods of the
Electromagnetic Field Radiation Strength of Electric
Vehicles Broadband 9kHz～30MHz
Presently in force
GB/T 183882005
The Type Approval Test Procedures of Electric
Automobiles
Presently in force
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Hybrid power
(chapter 1.1)
Fuel battery
automobiles
(chapter 1.3)
GB/T 245522009
The Performance Requirements and Test Methods of
Defrost and Defog System of Wind Window Glass of
Electric Automobiles
Presently in force
GB/T 198362005
Instruments for Electric Automobiles
Presently in force
GB/T 197512005
The Safety Requirements of Hybrid Power Electric
Automobiles
Presently in force
GB/T 197502005
Type Approval Test Procedures of Hybrid Power
Electric Automobiles
Presently in force
GB/T 197522005
The Testing Method of Power Performance of Hybrid
Power Electric Automobiles
Presently in force
GB/T 197532005
The Testing Methods of the Energy Consumption of
Light-duty Hybrid Power Electric Automobiles
Modified, having passed the
review; 20091183-T-339
GB/T 197542005
The Testing Methods of the Energy Consumption of
Heavy-duty Hybrid Power Electric Automobiles
Modified; draft; 20083094-T339
GB/T 197552005
The Measuring Methods of Pollutant Emission of
Light-duty Hybrid Power Electric Automobiles
Modified; draft; plan approved
by Environmental Protection
Bureau
GB/T 245542009
Performance Test Methods of Fuel Battery Engine
Presently in force
GB/T 245492009
Safety Requirements of Fuel Battery Automobiles
Presently in force
GB/T 245482009
Terminology of Finished Fuel Battery Automobiles
Presently in force
QC/T 816-2009 Hydrogenation Automobile Technical Conditions
Presently in force
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Storing
energy
devices
(chapter 1.3)
Motor and
control
system
(chapter 1.1)
GB/T 18332.12009
Lead-acid Battery for Electric Road Vehicles
Presently in force
GB/T 18332.22001
Metal Hydride Nickel Battery for Electric Road
Vehicles
Presently in force
GB/Z 18333.12001
Li-ion Battery for Electric Road Vehicles
Presently in force
GB/Z 18333.22001
Zinc Air Batteries for Electric Road Vehicles
Presently in force
QC/T 741-2006 Electrical Double-layer Capacitor for Vehicles
Presently in force; to be
modified
QC/T 742-2006 Lead-acid Battery for Electric Automobiles
Presently in force
QC/T 743-2006 Li-ion Battery for Electric Automobiles
Presently in force; to be
modified
QC/T 744-2006 Metal Hydride Nickel Battery for Electric Automobiles
Presently in force; to be
modified
GB/T 18488.12006
Part One of Motors and Controllers of Electric
Automobiles: Technical Conditions
Modified; draft
GB/T 18488.22006
Part Two of Motors and Controllers of Electric
Automobiles: Testing Methods
Modified, draft
GB/T 243472009
Electric Automobiles DC/DC Convertors
Presently in force
General Requirements of Electric Vehicles
Transmission Charging System
Presently in force
GB/T 18487.1Power supply 2001
and charging
(chapter 1.4) GB/T 18487.22001
The Connection Requirements of Electric Vehicles and
AC/DC Power Supply of Electric Vehicles
Presently in force
Transmission Charging System
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GB/T 18487.32001
Electric Vehicles AC/DC Charging Machine (Station) of
Electric Vehicles Transmission Charging System
Presently in force
GB/T 202342006
Universal Requirements of Plugs, Sockets, Vehicle
Coupler and Vehicle Jack for Electric Vehicles
Transmission Charging
Presently in force
Table 2: 12 Items of Standards Having Passed the Review of the Standard Committee and Waiting for
Approval and Promulgation
Category
Purely
electric
(chapter 1.1)
Hybrid power
(chapter 1.1)
Fuel battery
(chapter 1.3)
Standard
nature
Standard name
Formulation and
modification
Industrial
Standard
Double-layer Capacitor of Electric Urban Buses
Formulation
National
Standard
Technical Conditions for Purely Electric Passenger Cars
Formulation
Industrial
Standard
The Definition of the Types of Hybrid Power Automobiles
Formulation
National
Standard
Test Methods of the Energy Consumption of Light-duty Hybrid
Power Electric Automobiles
National
Standard
Technical Requirements of the Vehicle-borne Hydrogen
System of Fuel Battery Electric Automobiles
Formulation
National
Standard
Hydrogenation Gates of Fuel Battery Electric Automobiles
Formulation
National
Standard
Test Methods of the Highest Speed of Fuel Battery Electric
Automobiles
Formulation
Modification GB/T 197532005
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Energy
storing
devices
(chapter 1.3)
Power
supply and
charging
(chapter 1.4)
Industrial
Standard
The Specification and Dimension of the Power Battery
Products for Electric Automobiles
Formulation
Industrial
Standard
The Power Supply System for Double-layer Capacitor Electric
Urban Buses
Formulation
National
Standard
Universal Requirements for the Charging Stations of Electric
Automobiles
Formulation
Industrial
Standard
The Transmission-style Charging Interface of Electric
Automobiles
Formulation
Industrial
Standard
The Telecommunication Protocol between Electric Automobile
Battery Management System and Non-Vehicle-Borne
Charging Machines
Formulation
Schedule 3: 37 Items of Standards Being Formulated or Modified or to be Formulated or Modified
Category
Purely
electric
automobiles
(chapter 1.1)
Standard
nature
Standard name
Formulation and
modification
Industrial
Standard
The Type Approval Test Procedures for Double-layer Capacitor Urban
Buses
Formulation
Industrial
Standard
Technical Conditions for Low-speed Purely Electric Automobiles
Formulation
National
Standard
Safety Requirements of Electric Automobiles Part One: Vehicle-borne
Rechargeable Energy Storing System
GB/T 18384.1-2001
Modification
National
Standard
Safety Requirements of Electric Automobiles Part Two: Operation
Safety and Emergency Protection
GB/T 18384.2-2001
Modification
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Hybrid power
(chapter 1.1)
Fuel battery
(chapter 1.3)
Energy
storing
National
Standard
Safety Requirements of Electric Automobiles Part Three: Personnel
Electric Shock Prevention
GB/T 18384.3-2001
Modification
National
Standard
Telecommunication Protocol of Local Area Network (CAN Bus) of Electric
Formulation
Vehicle Control System
National
Standard
Test Methods of Energy Consumption of Light-duty Hybrid Power Electric
Formulation
Automobiles
National
Standard
Test Methods of Energy Consumption of Heavy-duty Hybrid Power
Electric Automobiles
GB/T 19753-2005
Modification
Industrial
Standard
Vehicle-borne Measurement Methods of Pollutant Discharge of Heavyduty Hybrid Power Electric Automobiles
GB/T 19754-2005
Modification
Industrial
Standard
Test Methods of Power Assembly System Performance of Hybrid Power
Automobiles
Formulation
National
Standard
Measurement of Energy Consumption of Fuel Battery Hybrid Power
Electric Automobiles
Formulation
National
Standard
Technical Criteria of Demonstration Operation of Fuel Battery Electric
Automobiles
Formulation
National
Standard
Auxiliary Criteria of Demonstration Operation of Fuel Battery Electric
Automobiles
Formulation
National
Standard
Hydrogenation Guns of Fuel Battery Electric Automobiles
Formulation
National
Standard
Electric Pile Safety of Fuel Battery Electric Automobiles
Formulation
National
Standard
Test Procedures of Li-ion Battery for Electric Automobiles Part One:
High Power Application
Formulation
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devices
(chapter 1.3)
Motor and
control
system
(chapter 1.1)
National
Standard
Test Procedures of Li-Ion Power Battery System for Electric Automobiles
Part Two: High Energy Application
Formulation
Industrial
Standard
Technical Conditions of Battery Management System of Electric
Automobiles
Industrial
Standard
Cycling Performance Requirements of Power Battery for Electric
Automobiles
National
Standard
Safety Performance Requirements of Power Battery for Electric
Automobiles
Formulation
National
Standard
Universal Requirements of Power Battery for Electric Automobiles
Formulation
National
Standard
Universal Requirements of Battery Chambers of Power Battery System
for Electric Automobiles
Formulation
Industrial
Standard
Double-layer Capacitor for Vehicles
QC/T 741-2006
Modification
Industrial
Standard
Lead-acid Battery for Electric Automobiles
QC/T 742-2006
Modification
Industrial
Standard
Li-ion Battery for Electric Automobiles
QC/T 743-2006
Modification
Industrial
Standard
Metal Hydride Nickel Battery for Electric Automobiles
QC/T 744-2006
Modification
National
Standard
Technical Conditions of Motor and its Controller for Electric Automobiles
GB/T 18488.1-2006
Modification
National
Standard
Test Methods of Motor and its Controller for Electric Automobiles
GB/T 18488.2-2006
Modification
Formulation
Formulation
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Energy
supply and
charging
(chapter 1.4)
National
Standard
Test Methods of the Reliability of Driving Motor System for Electric
Automobiles
Formulation
Industrial
Standard
Failure Models and Classification of Driving Motor and its Control
System for Electric Automobiles
Formulation
Industrial
Standard
Interfaces of Driving Motor and its Control System for Electric
Automobiles
Formulation
Industrial
Standard
The Power Supply System of Double-layer Capacitor Electric Urban
Buses
Formulation
National
Standard
Universal Requirements of Charging Stations of Electric Automobiles
Formulation
Industrial
Standard
Technical Criteria of Charging Piles for Electric Automobiles
Formulation
Industrial
Standard
Technical Conditions of Vehicle-borne Charging Machines for Electric
Automobiles
Formulation
Industrial
Standard
Technical Conditions of Non-vehicle-borne Charging Machines for
Electric Automobiles
Formulation
Industrial
Standard
Universal Technical Requirements of Monitoring Management System of
the Charging Stations for Electric Automobiles
Formulation
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