OICA-CLEPA-EME comments on German proposal GRVA-25-07 to require the approval authority granting UN R155 or UN R156 type approvals to use CSMS or SUMS certificates signed by the same approval authority. OICA-CLEPA-EME identify that CSMS and SUMS are Management Systems covering entire manufacturer organizations, and mandating the same approval authority for Management Systems certificates and approvals will have significant consequences for original equipment manufacturers typically using multiple approval authorities in homologation. The submission proposes keeping text unchanged to allow different approval authorities for Management Systems certificates and type approval based on voluntary acceptance, implementing wording on information exchange if different approval authorities are involved, and establishing a horizontal approach for Management Systems with mutual recognition aspects considered.

The EV/HFCV Retrofit Systems IWG held three meetings since the last GRVA session and has compiled requirements for Electrical Safety (UN R100), Braking (UN R13/R13H), Cybersecurity (UN R155), and EMC (UN R10) with participation of respective GRs experts. Regulation drafting has started. Next activities include continuation of discussion on requirements, addressing net power and electric consumption determination, family and parent definition, and provisions for PTI, with regulation draft for EV retrofit to be delivered as informal document to the next GRPE session in October.

The Informal Working Group on EV/HFCV Retrofit Systems held its eighth meeting on 21 April 2026. The group discussed cybersecurity principles, requiring retrofitted vehicles not to reduce safety or cybersecurity performance compared with UN R155 requirements, with differentiated approaches for base vehicles approved or not approved to UN R155. Braking compliance, EMC testing references, and UN draft regulation changes including renaming to “vehicles intended to be transformed into pure electric vehicles” and introducing Electric Powertrain Retrofit Systems definitions were addressed. PTI-related aspects and the need for written contributions were highlighted before providing the draft regulation to GRPE in October.

The eighth meeting of the Informal Working Group on EV/HFCV Retrofit Systems is scheduled for Tuesday 21st April 2026. The agenda includes coordination and organization of work with reference to GRPE-92-14, EVHFCV-02-02, GRPE-93-22-Rev.1, GRSP-78-17, GRVA-24-07, and GRPE-94-06, electrical safety review, cybersecurity, braking, EMC, and UN draft documentation review. Future meetings are planned for 11th June, 2nd July, and 9th September, with hybrid and online formats.

The Informal Working Group on EV/HFCV Retrofit Systems held its seventh meeting on 5th March 2026. The group adopted the provisional agenda, approved minutes of the previous meeting, and acknowledged ongoing activities under GRPE, GRSP and GRVA. Electrical safety review will continue once clarification regarding UN R100 is available. Cybersecurity discussions covered very old vehicles, older vehicles without cybersecurity provisions, and modern vehicles compliant with UN R155. Braking aspects and the structure of the draft UN Regulation were discussed, including vehicle versus system approval approaches and minimum and maximum vehicle age within the regulation’s scope.

This Regulation provides uniform provisions for approval of vehicles of categories M₁–M₃ and N₁–N₃ equipped with electric traction chain powertrain retrofit systems to be converted into pure electric vehicles (EV) or Hydrogen Fuel Cell Vehicles (HFCV). Retrofit system manufacturers must submit applications including descriptions of the retrofit system, original parent vehicle, modifications, compliance verification, application range, installed samples, authorized installers, and conversion plates. Type approval requires meeting general requirements for design, construction, durability, and failure communication, plus specific requirements in Annexes 5A for EVs and 5B for HFCVs. Only authorized installers may perform conversions, and manufacturers must provide installation documents and end-user manuals.

This commented working draft establishes uniform provisions for approving vehicles of categories M and N intended to be converted into pure electric vehicles (EV) or Hydrogen Fuel Cell Vehicles (HFCV) with electric powertrain retrofit systems. The regulation covers retrofit system approval, vehicle approval, application range, installer authorization, and conformity of production. Requirements address electromagnetic compatibility, braking, power measurement, rechargeable energy storage systems, mass and dimensions, and compliance with relevant UN Regulations including UN R10, UN R13, UN R85, and UN R100. The documents includes comments from France and RME.

RME views: Vehicles were on the road before UN R155 came into force. Retrofitting extends vehicle life in line with climate action and circular economy objectives. Retrofitters must be responsible only for components involved in the transformation and any parts they add or modify, not for original vehicle components. A risk management demonstration dossier limited to the transformed system must be included in transformation approval applications. If the origin vehicle is not R155-approved, retrofitters may provide the dossier without laboratory tests. If R155-approved, authorities decide on compliance, requiring laboratory tests if needed. Manufacturers’ data are not accessible to retrofitters. The application of cyber security provisions (i.e., UN R155 compliance) should be delayed by two years from the entry-into-force of the new regulation for the approval of EC/HFCV retrofit systems and revisions to UN R155 should also provide two-year transitional provisions before the application to the retrofit regulation.

Proposal to create a new Informal Working Group on harmonized technical regulatory frameworks for Electric Vehicles (EV) / Hydrogen Fuel Cell Vehicles (HFCV) retrofit systems.