Supporting presentation for proposals to remove para. 6.2. and Annex 9A, remove para. 6.3. and Annex 9B, remove para. 6.5. and Annex 9E including Appendix 1, remove para. 6.10. and Annex 9J, exempt from isolation resistance measurements after each test, allow sequential execution of over-discharge and overcharge tests, remove standard cycle after each test, unify thermal event warning requirement by removing para. 6.14., and allow alternative conditions for ambient temperature for SOC adjustment. The document also proposes guidance on REESS type definition.

Proposal to streamline the Regulation by eliminating redundant requirements and their test procedures as well as to clarify the possible alternative methods to improve the efficiency of the tests: Delete paragraphs 6.2. and 6.3., delete paragraph 6.5., delete paragraph 6.10., reserve paragraphs 9A, 9B, and 9E, delete paragraph 6.14., amend paragraph 6.15. to add comprehensive thermal propagation verification procedures including risk management analysis alternatives, add paragraph 6.16. for REESS and vehicle communication compatibility, add new Part III (para. 7.) for approved REESS installation requirements, renumber existing paragraphs 8.–13. as paragraphs 8.–13. and add corresponding section numbering, amend scope provisions to clarify application to vehicles of categories M, N, and O with specified e-axle battery provisions, add vehicle category O definitions including “e-axle” and “trailer load compartment,” amend various paragraphs to reference vehicles of categories O₃ and O₄, amend protection requirements to include trailer load compartments, amend over-discharge and overcharge test procedures to permit sequential execution, amend isolation resistance measurement requirements to exempt measurement when isolation resistance monitoring systems are installed and confirmed functional, clarify SOC adjustment procedures to permit alternative ambient temperatures when highest SOC is achievable independently, add labelling requirements for vehicles of categories M₂/N₂ and M₃/N₃ in accordance with ISO 17840-4:2018, add provisions for Automated Driving System (ADS) features and warnings, add provisions for vehicles of category Y regarding mechanical integrity validation at component level, amend Annex 1 Part 2 to revise installation restriction references, add Annex 9K describing four thermal propagation trigger methods with four appendices, and add Annex 10 specifying label provisions for electric power train vehicles.

Proposal to provide guidance for interpretation of “Type of REESS” (Rechargeable Electrical Energy Storage System) as defined in UN R100 para. 2.48. The document establishes that differences in REESS should be evaluated from the perspective of substantial impact on safety performance. It describes key elements for assessing impact on safety within each essential aspect: manufacturer responsibility, cell chemistry/capacity/physical dimensions, cell number/connection/support, casing construction/materials/dimensions, and ancillary devices. The guidance provides examples of changes not causing or potentially causing significant differences, including production location changes, multi-sourcing of cells, and process improvements.