Electric Vehicle Traction Battery E-Mark Certification: UN R100.03 REESS

Traction Battery E-Mark Certification: The Full UN R100.03 REESS Test Programme

Standfirst: E-Mark is the type approval mark issued under the United Nations Economic Commission for Europe (UNECE) system, mutually recognised across roughly 60 countries and regions - one certificate opens access to most major markets. For traction batteries the core reference is UN ECE R100.03 Part II, where the subject of approval is the Rechargeable Electrical Energy Storage System (REESS). This guide breaks down all ten mandatory tests, the four design requirements, sample limits and the certification procedure, and clarifies where R136 and UN 38.3 apply.

1. What E-Mark Is and Which Regulations Govern Traction Batteries

The origin of E-Mark. E-Mark certification is implemented under the ECE regulations signed and published by the UNECE in Geneva, and constitutes an approval system for vehicle components, including automotive electronic products. The UNECE is a branch of the United Nations whose members are European countries, alongside a number of non-European countries. Around 60 countries or regions worldwide currently accept and recognise E-Mark certification, and a certificate issued by any one member is mutually recognised by the others. For this reason E-Mark is also referred to as ECE certification. Regulatory mapping for traction batteries. The same battery faces different regulations at different stages and in different markets. Conflating them is the single most common cause of certification rework:

Key point: these are parallel requirements, not substitutes. A traction battery destined for the EU market typically has to satisfy R100 or R136 (market access), UN 38.3 (transport) and EN 50604-1 (product safety) independently. The most frequent mistake in practice is assuming that a completed GB 38031 inspection means the battery can be declared for the EU, or that holding an E-Mark settles transport compliance. Neither is correct. Vehicle category definitions (R.E.3 Annex 7):

Scope and exclusions for R100 Part II:

• Applies to REESS in M and N category road vehicles with at least one electric power train motor, a maximum electric power train speed above 25 km/h, and not permanently connected to the charging system.
• This Regulation does not include safety requirements following a road vehicle collision.
• Does not apply to REESS supplying power to the generator, lighting and/or other vehicle auxiliary equipment.

Scope and exclusions for R136 Part II:

• Applies to REESS in L category road vehicles with a maximum electric power train speed above 6 km/h, not permanently connected to the charging system.
• Does not apply to REESS supplying power to the generator, lighting and/or other vehicle auxiliary equipment.
• Covers L1e through L7e: L1e two-wheeled mopeds, L2e three-wheeled mopeds, L3e two-wheeled motorcycles, L4e motorcycles with sidecar, L5e three-wheeled motor vehicles of higher performance, L6e light quadricycles (maximum 45 km/h, unladen mass up to 425 kg excluding batteries) and L7e heavy quadricycles.

2. The 10 Mandatory Tests Explained

Overview

Three key changes introduced by Revision 3 (confirm the applicable version at planning stage):

1. The over-current protection test (9J) was added, raising the number of mandatory tests from nine to ten.
2. The battery must be fully charged at the start of testing for vibration, thermal shock and cycling, mechanical shock, mechanical integrity, external short circuit and overcharge, and a new acceptance criterion of “no venting” was added.
3. Fire resistance gained an LPG burner test method, allowing a choice of gasoline or LPG as the fire source. The LPG method requires additional flame temperature measurement, does not include an indirect exposure phase, and extends the direct exposure time to two minutes.

Common test conditions (applicable to most items): ambient temperature 20 ± 10°C; SOC at the start of testing at 50% or above; all protection devices that affect the function of the DUT and are relevant to the test result shall be operational (except in the over-temperature test, where the cooling system is disabled). Evidence of electrolyte leakage shall be verified by visual inspection without dismantling any part of the DUT. 1. Vibration (Annex 9A / 6.2) The DUT is subjected to sinusoidal vibration swept logarithmically between 7 Hz and 50 Hz and back to 7 Hz in a span of 15 minutes. This cycle shall be repeated 12 times in the vertical direction relative to the mounting orientation specified by the manufacturer, for a total of three hours. Acceleration sweeps from 10 m/s² to 2 m/s²; ambient temperature 22 ± 5°C. Higher acceleration and higher maximum frequency may be used at the manufacturer’s request.

• Acceptance: no electrolyte leakage, no rupture (high voltage REESS only), no fire, no explosion.
• Insulation resistance of high voltage REESS shall be not less than 100 Ω/V after testing.
• After testing, a standard discharge followed by a standard charge shall be performed (unless prevented by the DUT), with a rest period of at least 30 minutes after discharge, and an observation period of one hour at the test ambient temperature.

2. Thermal shock and cycling (Annex 9B / 6.3) The DUT shall first be stored for at least six hours at a test temperature of 60 ± 2°C, or higher where the manufacturer requires it, then for at least six hours at a test temperature of −40 ± 2°C, or lower where the manufacturer requires it. The maximum time interval between the two test temperature extremes shall be 30 minutes - this places a significant demand on the chamber’s ramp capability and is often the first real limit on laboratory capability. The procedure is repeated until at least five cycles are completed, after which the DUT is stored at 20 ± 10°C for 24 hours.

• Acceptance: no electrolyte leakage, no rupture (high voltage REESS only), no fire, no explosion.
• After 24 hours of storage at 22 ± 5°C, a standard discharge and standard charge shall be performed, ending with a one-hour observation period.

3. Mechanical shock (Annex 9C / 6.4.1.2) At the manufacturer’s choice, vehicle-based testing, component-based testing, or any combination of the two may be performed for the different direction of travel. Component-based testing: the DUT is decelerated or accelerated according to the acceleration profiles in Tables 1 to 3 of the regulation (up to approximately 28 g, with an actuation time of 100 to 120 ms). The technical service shall agree with the manufacturer whether to test in the positive direction, the negative direction or both. A separate DUT may be used for each individual test pulse, and the pulse shall fall within the minimum and maximum values given in Tables 1 to 3; at the manufacturer’s recommendation, higher shock levels and/or longer durations from the maxima of those tables may be used. Testing ends with a one-hour observation period at the test ambient temperature. After component-based testing, the DUT shall be secured by brackets and its components shall remain within its boundaries. Vehicle-based testing: a REESS installed in a vehicle subjected to vehicle collision testing may be verified this way, per R12 Annex 3 or R94 Annex 3 (frontal impact) and R95 Annex 4 (side impact). A REESS located in the passenger compartment must remain in position and its components shall remain within the REESS boundaries. During and after the collision test, no part of any REESS located outside the passenger compartment may enter the passenger compartment. Where necessary, a suitable coating shall be applied to the physical protective device (enclosure) to confirm whether the collision caused electrolyte leakage. Unless the manufacturer provides a means of distinguishing between different liquids, all liquid leakage shall be treated as electrolyte.

• Acceptance: no fire, no explosion, no electrolyte leakage. For vehicle-based testing, no electrolyte shall leak from the REESS into the passenger compartment from the moment of impact until 30 minutes after impact. For component-based testing, electrolyte leaking from the REESS to the exterior of the passenger compartment shall not exceed 7% of volume (and not more than 5 litres for open traction batteries). Insulation resistance of high voltage REESS after testing shall be not less than 100 Ω/V, or the test device shall satisfy IPXXB.

4. Mechanical integrity (Annex 9D / 6.4.1.3) Applies only to REESS intended for mounting in M1 and N1 category vehicles. Vehicle-specific testing: where the REESS is mounted between a line perpendicular to the vehicle centreline at the rear edge of the vehicle and a line parallel to and forward of it by 300 mm, the manufacturer shall demonstrate to the technical service its mechanical integrity in the vehicle. This may be by vehicle-based dynamic testing (per R12/R94 Annex 3 and R95 Annex 4) or by vehicle-specific component testing, where the manufacturer may substitute crushing forces based on actual crash test results or simulation data. Vehicle-specific component testing / component-based testing: unless otherwise specified, the DUT shall be crushed between a resistance plate and a crush plate with a force of at least 100 kN and not more than 105 kN, with an onset time of less than three minutes and a hold time of at least 100 ms and not more than 10 s. At the manufacturer’s request, higher crushing forces, longer onset times, longer hold times or a combination may be applied. The application of force shall be agreed between the manufacturer and the technical service, taking into account the horizontal and vertical directions of the REESS relative to its direction of travel in the vehicle. Crush plate dimensions: 600 mm x 600 mm or smaller. The REESS shall be mounted between two planes: a plane perpendicular to the vehicle centreline, 420 mm rearward from the vehicle front edge; and a plane perpendicular to the vehicle centreline, 300 mm forward from the vehicle rear edge.

• Acceptance: no fire, no explosion, no electrolyte leakage. For vehicle-based testing, no electrolyte shall leak into the passenger compartment within 30 minutes of impact. For component-based testing, leaked electrolyte shall not exceed 7% of volume (5 litres for open batteries). Insulation resistance of high voltage REESS after testing shall be not less than 100 Ω/V, or IPXXB shall be satisfied.

5. Fire resistance (Annex 9E / 6.5) Applies to REESS containing flammable electrolyte. If the lower shell of the REESS is more than 1.5 m above ground, this test need not be performed. Test temperature at least 0°C; SOC at 50% or above; all relevant protection devices operational. Test arrangement: the DUT shall be placed on a grid table above the pan in accordance with the manufacturer’s design intent. The grid table shall be built from steel bars of 6 to 10 mm diameter spaced 4 to 6 cm apart, supported by flat steel sections where necessary. In component-based testing, the DUT shall be mounted in a fixture simulating the actual installation conditions as far as possible, and no flammable material other than materials forming part of the REESS may be used. The method of securing the DUT in the fixture shall comply with the relevant specifications for its in-vehicle mounting. In vehicle-based testing, the flame to which the REESS is exposed shall be produced by burning commercial fuel for positive ignition engines in the pan. The fuel quantity shall be sufficient for the flame to burn throughout the test under free-burning conditions, and the fire shall cover the entire area of the pan. The pan shall exceed the horizontal projection of the DUT by at least 20 cm but not more than 50 cm. At the start of testing, the pan side wall shall not project more than 8 cm above the liquid level. The fuel pan shall be placed below the DUT such that the distance between the fuel level in the pan and the bottom of the DUT is approximately 50 cm. Four phases:

If the fuel temperature is at least 20°C, the test includes Phases B to D; otherwise Phases A to D. Where the new Rev.3 LPG burner method is used, flame temperature shall additionally be measured, there is no indirect exposure phase, and the direct exposure time extends to two minutes.

• Acceptance: the DUT shall not explode. Note that the criterion here is “no explosion”, which differs from the “no fire, no explosion” wording used for the other items.

6. External short circuit protection (Annex 9F / 6.6) At the start of testing, all main contactors used for charging and discharging shall be closed, representing the possible active drive mode as well as the external charging mode. If a test cannot be completed in one go, two or more tests shall be performed. The positive and negative terminals of the DUT shall be connected to create a short circuit, using a connection resistance of not more than 5 mΩ (the short circuit resistance shall be recorded). The short circuit condition shall be maintained until it is confirmed that the protection function interrupting or limiting the short circuit current has operated, or for at least one hour after the temperature measured on the DUT casing has stabilised (temperature change of less than 4°C in one hour).

• Acceptance: no electrolyte leakage, no rupture (high voltage REESS only), no fire, no explosion. Insulation resistance of high voltage REESS after testing shall be not less than 100 Ω/V.
• After short circuit termination, a standard discharge and standard charge shall be performed (unless prevented by the DUT), ending with a one-hour observation period.

7. Overcharge protection (Annex 9G / 6.7) At the start of testing, all main contactors used for charging shall be closed. The charge control limits of the test equipment shall be disabled. The DUT shall be charged at a current of at least 1/3C, but not exceeding the maximum current within the manufacturer’s specified normal operating range. Charging shall continue until the DUT interrupts or limits charging automatically. If the automatic interruption function cannot operate, or does not exist, charging shall continue until the DUT is charged to twice its rated capacity.

• Acceptance: no electrolyte leakage, no rupture (high voltage REESS only), no fire, no explosion. Insulation resistance of high voltage REESS after testing shall be not less than 100 Ω/V.
• After charge termination, a standard discharge and standard charge shall be performed (unless prevented by the DUT), ending with a one-hour observation period.

8. Over-discharge protection (Annex 9H / 6.8) At the start of testing, all relevant main contactors shall be closed. Discharge shall be performed at a rate of at least 1/3C, but not exceeding the maximum current within the manufacturer’s specified normal operating range. Discharge shall continue until the DUT interrupts or limits discharge automatically. If the automatic interruption function cannot operate, or does not exist, discharge shall continue until the DUT is discharged to 25% of its rated voltage.

• Acceptance: no electrolyte leakage, no rupture (high voltage REESS only), no fire, no explosion. Insulation resistance of high voltage REESS after testing shall be not less than 100 Ω/V.
• After discharge termination, a standard charge shall be performed (unless prevented by the DUT), ending with a one-hour observation period.

9. Over-temperature protection (Annex 9I / 6.9) Critical precondition: if the REESS is equipped with a cooling function and can still operate normally with the cooling system inoperative, the cooling system shall be disabled during the test. During the test, temperature shall be measured continuously inside the enclosure near the battery to monitor temperature changes. Vehicle-mounted sensors may be used, and their position shall be agreed between the manufacturer and the technical service. At the start of testing, all protection devices shall be operational except the disabled cooling system. A stabilised current shall be used to continuously charge and discharge the DUT so that the battery temperature rises as quickly as possible within the manufacturer’s specified normal operating range. The DUT shall be placed in a convection oven or environmental test chamber, and the chamber temperature shall be raised gradually until the conditions below are met. 10. Over-current protection (Annex 9J / 6.10) Newly introduced in Revision 3. The system shall trigger effective protective measures under abnormal high current conditions (such as fuse interruption or BMS current limiting), verifying protection effectiveness under fast charging conditions, particularly ultra-fast charging scenarios.

• Acceptance: no electrolyte leakage, no rupture, no fire, no explosion, and effective operation of the protection function.

Definition of the standard cycle (referenced across multiple tests):

3. The Four Design Requirements

Unlike GB 38031, which focuses on test items, R100.03 imposes requirements at the design level. Technical documentation must demonstrate that the pack incorporates the following, and these are verified before testing begins:

These four items are hard gates at the documentation review stage. Before submission, prepare: the REESS specification, the BMS and its protection function description, charge and discharge limits, and the mounting method and orientation in the vehicle. The first two are where most first-time applicants get stuck - all tests may pass, yet the submission is returned for supplementary documentation or further remediation, which directly extends the overall schedule. A document pre-review before submission is strongly recommended.

4. Samples and Test Planning

Sample size and mass limits

Technical inputs that must be confirmed before submission:

• REESS specification (rated capacity, rated voltage, SOC definition, charge and discharge limits)
• BMS and protection function description (overcharge, overdischarge, over-temperature, over-current and short circuit protection logic and thresholds)
• Charge and discharge limit parameters (termination voltage, termination current, maximum charge rate)
• Mounting method and orientation in the vehicle, which determine the vibration and mechanical shock directions
• Where applying for R136 with a removable battery, the specific requirements for removable packs
• Where the battery is mounted in an M1 or N1 vehicle, the vehicle-specific parameters for mechanical integrity verification

5. Certification Procedure and Lead Time

Standard six-step process

1. Application - submit the certification application, specifying the product model, the regulation version and the intended scope of approval.
2. Documentation - provide product technical files including the REESS specification, the BMS and protection function description, charge and discharge limits, mounting method and orientation, and the documentation for the four design requirements.
3. Sample testing - the laboratory executes the agreed test programme and outputs raw data, photographs and video records.
4. Report preparation - the test report is compiled from the specification and the passing test data.
5. Report review - the report is submitted to the technical service of the issuing country (such as KBA in Germany or RDW in the Netherlands) for review.
6. Certificate issuance - the E-Mark certificate is issued by the approving authority once the review passes.

Lead time

Note: where vehicle-based testing is used (Annex 9C/9D vehicle-specific tests), the schedule depends on the vehicle crash test programme and is usually significantly longer than component-level testing. Agree the test route with the technical service at the planning stage.

Mutual recognition scope: the E-Mark is issued within the UNECE system, and a certificate granted by any Contracting Party is mutually recognised by all of them. A single certification covers approximately 60 countries or regions, which substantially reduces multi-country certification cost. R100.02 to R100.03 upgrade reminder

If a certified product still holds an R100.02 certificate, arrange an upgrade as soon as possible. The final transition period has already passed, so it is worth proactively identifying any models still carrying an old-version certificate.

6. R100, R136 and UN 38.3 Compared

Choosing a pathway

Clarifying common misconceptions

• Does an R100 E-Mark remove the need for UN 38.3? No. E-Mark addresses market access; UN 38.3 addresses transport compliance. They are independent, and a lithium battery shipped by sea or air must be accompanied by the UN 38.3 test summary (TDS).
• Can R100 and GB 38031 be mutually accepted? No. The frameworks are similar but belong to separate regimes, corresponding to EU/UNECE market access and to China’s announcement inspection respectively. Holding a GB 38031 report does not satisfy R100, and vice versa.
• Can an L category two-wheeler use R100? No. Part II of R100 explicitly applies to M and N category vehicles. L category must use R136. R136 has included the over-current protection test since Revision 1 Amendment 1 (February 2023), mandatory for new applications from 1 September 2025.
• Should certification cover only the pack, or cells as well? It depends on the target market and the OEM’s requirements. Some markets, such as China under GB 38031, require verification at cell, module and system level; EU R100 REESS certification is primarily system level. Confirm the level requirements with the target market’s technical service at the planning stage.

7. Why SRC-TEST

• Comprehensive accreditation. A laboratory accredited by CNAS, CMA and A2LA, holding the scope required to issue technical service reports for European type approval, able to interface directly with the technical services of issuing countries such as KBA and RDW and avoiding second-hand subcontracting.
• Full programme coverage. The ten tests of R100.03 Annex 9A-9J, UN 38.3 transport testing and the GB 38031 mandatory inspection items can all be completed in a single laboratory, resolving export and domestic requirements in one place and avoiding the time and sample loss caused by transferring between institutions.
• Equipment and environments. Vibration tables (sinusoidal sweep 7-50 Hz, three hours in the vertical direction), temperature chambers meeting the 60°C / −40°C rapid transition with a 30-minute maximum interval, a 100 kN crushing rig, mechanical shock equipment, a fire resistance laboratory (fuel pan with refractory brick screen arrangement, infrared temperature measurement and high-definition video), charge and discharge cycling systems up to 1000 V / 1000 A, and dedicated short circuit, overcharge and overdischarge protection test systems.
• Experienced engineers. Senior engineers with an average of more than ten years in the field, familiar with the decisive points such as BMS protection threshold validation, thermal runaway warning logic verification and evidence gathering for the no venting criterion, able to provide a design compliance and document pre-review before submission.
• End-to-end support. One-to-one support throughout: regulation version applicability assessment, test planning, sample preparation guidance, factory witness testing, report preparation and direct liaison with the approval authority, including handover to conformity of production (COP) assessment where required.

Note: The specific test programme depends on the target market (EU, other UNECE Contracting Parties or China), vehicle category (M, N or L), REESS form (fixed or removable) and the applicable regulation version. Contact an SRC-TEST engineer for a tailored certification plan and quotation.