This consolidated draft text proposes uniform provisions for approving vehicles transformed into electric vehicles (EV) or hydrogen fuel cell vehicles (HFCV) with electric powertrain retrofit systems. The regulation defines retrofit systems as all devices and components necessary to operate vehicles in electric mode, including powertrains, energy storage systems, management systems, and vehicle inlets. It specifies application procedures, marking and approval requirements, technical specifications for retrofit systems, installer qualifications and authorization, conformity of production procedures, modification and extension of approvals, and penalties for non-compliance. The regulation applies to vehicles of categories M and N and requires compliance with relevant UN Regulations including those addressing electromagnetic compatibility, braking, power measurement, and electric powertrains. Specific technical requirements address surveillance systems, anti-tampering provisions, performance parameters, dimensional and mass tolerances, and acoustic devices.
The provisional agenda for the tenth meeting of the Informal Working Group on EV/HFCV Retrofit Systems on Thursday 2nd July 2026 includes adoption of the agenda, approval of minutes, coordination and organization of work with reference to GRPE-92-14, EV/HFCV-02-02, GRPE-93-22/Rev.1, GRSP-78-17, GRVA-25-19, and WP.29-199-16, electrical safety review, braking, EMC, power determination and battery range, UN Draft, and any other business, with subsequent meetings scheduled for 9th September online and 8th October online.
The Informal Working Group on EV/HFCV Retrofit Systems held its ninth meeting on 11th June 2026. The group discussed electrical safety, cybersecurity, braking, EMC, power determination, battery range, and the overall approval concept for retrofit systems. Discussions covered UN Regulations 100, 155, 13/13-H, 10, 85, 177, 154, and 138. The group agreed to approve retrofit systems together with compatible vehicle families and to exclude hydrogen fuel cell provisions pending further technical input. RME agreed to coordinate benchmarking exercises on power thresholds and range/durability requirements. Future meetings were scheduled for 2 July 2026, 9 September 2026, and 8–9 October 2026.
Proposal to add para. 6.2.1.3 defining method of measurement in the frequency range 1 GHz to 6 GHz, add para. 6.2.2.5 establishing limits of disturbance with peak detector at vehicle-to-antenna spacings of 3.0 ± 0.05 m and 10.0 ± 0.2 m, add para. 6.3.2.5 establishing limits of disturbance with average detector at vehicle-to-antenna spacings of 3.0 ± 0.05 m and 10.0 ± 0.2 m, rename para. 6.5.2 to specify frequency range 30 MHz to 1000 MHz, add para. 6.5.3 establishing ESA broadband type approval limits in the frequency range 1 GHz to 6 GHz with measurement frequency requirements based on highest internal frequency, add para. 7.3 establishing specifications concerning narrowband electromagnetic radiation from vehicles with method of measurement and type approval limits, rename para. 7.10.2 to specify frequency range 30 MHz to 1000 MHz, add para. 7.10.3 establishing ESA broadband type approval limits in the frequency range 1 GHz to 6 GHz with measurement frequency requirements, add Annex XY defining method of measurement of radiated broadband and narrowband electromagnetic emissions from vehicles in the frequency range 1 GHz to 6 GHz, add Annex XZ defining method of measurement of radiated broadband electromagnetic emissions from electrical/electronic sub-assemblies with test setup figures, and add Appendices z1 and z2 establishing vehicle reference limits at 10 m and 3 m antenna-vehicle separation respectively.
The European Commission presents prioritized proposals toward updating UN R10 to address transformative vehicle technologies including electrification, automated systems, steer-by-wire, V2X communication, and software-defined vehicles. Current interpretation does not guarantee safety and environmental protection under real road conditions. Proposals include assessing radiated emissions from four vehicle sides rather than two, testing under normal driving conditions, and establishing agreement on drive cycles and transients. These proposals align with WP.29 guidance, improve safety, ensure reproducibility, and represent adaptation to technological progress, based on follow-up of EMC-46-04 and EMC-49-09.
The Netherlands proposes introducing a separate part 2 addressing immunity-related functionality on lateral movement for steer-by-wire and automated driving systems. Harmonics should be tested when issues are observed; in the cited example, step sizes above and below 745–755 MHz and harmonic frequencies at 1500 MHz and 375 MHz require testing. UN R10 should address specific immunity features across multiple UN Regulations, or references should be moved to individual regulations. Test procedures for complex systems like steer-by-wire and brake-by-wire require improvement, including clearer protocols and discussion of specialized technical units. Dwell time must be sufficient to observe all potential fail criteria in agreement between manufacturer and technical service. Antenna switching during testing at 3m versus 10m positions should be forbidden. EMC shielding must be robust and durable, excluding non-integral ferrite blocks and loose components, with critical details recorded in test reports.
Amend para. AI to replace the heading “Examples of documents/evidence that could be provided” with “Explanation of the requirement” and insert text stating that Part C of this document provides further guidance on the application of the Regulation to vehicles which have been modified by carrying out a transformation of the vehicle.
CLEPA welcomes questions raised by Japanese experts under doc TFCS-37-06 and identifies points requiring further clarification regarding component and STU type approval scope, technical integration, STU definition, implementation, risk assessment, impact and benefit, and post-market monitoring. CLEPA proposes that components or STUs required for initial vehicle type approval under Part I should not be subject to separate approval under Part II, noting that vehicle cybersecurity depends on vehicle-level system interactions and E/E architecture, the OEM has full visibility of system architecture, and Part I approval ensures integrated assessment.