# UK IVA October 2016 update now includes EV



## jacksdad (Apr 13, 2015)

The IVA now has section for EV within M1 that states requirement for certificate to ECE R100.01 this is going to cost me to get 😔


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## Tomdb (Jan 28, 2013)

Dont get your panties in a twist.

Updated manual https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/556944/m1-iva-inspection-manual.pdf

You need to get an apporved agency/service to look at your car and say it complies with R100. 

r100:

No exposed or reachable highvoltage
Isolated HV bus
Isolation monitoring (should be implementable, if the isolation between HV and 12 volts system is to low contactors have to open)

Inspection is done by:

1. The vehicle as presented must be accompanied by satisfactory
documentary evidence of compliance with the required standard for
(electric vehicles)

*Visual Inspection*
2. All high voltage cable terminations must be suitably protected, these
protections (solid insulator , barrier, enclosure, etc.) shall not be able to
be opened, disassembled or removed without the use of tools
(see Note 1)

3. Vehicles fitted with an external charging point shall be clearly marked
on or near the connection point with an indelible label (see Figure 1)
affixed in a visible location.

4. Any enclosure carrying high voltage shall be clearly marked with an
indelible label (see Figure 1) affixed in a visible location.

5. All visible high voltage cables must be orange in colour.

6. All metal enclosures with internal high voltage must have an earth path
for protection against electrical shock (this may be a separate bonding
or the mounting arrangement where it does not isolate the enclosure)

So until the bastards slap you with a requirement to produce the R10 (emc) documentation for all components you are fine.

I am very happy the UK decided on this, it keeps the deathtraps some people build off the road however in Holland they went overboard and required everything to be certified for EMC (including the install in the car).


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## jacksdad (Apr 13, 2015)

Yep i agree with the standard and am happy to comply and is all very sensible my problem is when i have contacted the approved centres that can give me the certificate they said it would be £6K which is a lot for a single car builder like me.


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## jacksdad (Apr 13, 2015)

Isolation monitoring (should be implementable, if the isolation between HV and 12 volts system is to low contactors have to open)

I'm pretty sure the Curtis controller has this built in ??

"6. All metal enclosures with internal high voltage must have an earth path
for protection against electrical shock (this may be a separate bonding
or the mounting arrangement where it does not isolate the enclosure"

I'm not sure i undertand this, as what is earth in an EV is it the negative earth of the 12V battery in which case if there is an earth fault the whole chassis will be at pack voltage and the -ve of the 12v battery?? does it mean that you connect the -ve pack terminal to the chassis - i thought this was not advisable as sets up the potential for nasty short circuits during a crash, maybe its just ensuring equipotential of all metal parts ?? - any clarification would be helpful


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## Tomdb (Jan 28, 2013)

6K sounds very excessive that kind of money is what you pay for emc testing. Probally did not ask the 100% correct question, plus those centers have no experience yet with this requirement.

Earth is the low voltage negative, which during charging get referenced to ground. 

The whole of the HV bus has to float, this does mean however when there is a short or capacitance buildup/resistance then it should be contained to the car, so metal to metal. Instead of being in the part/casing because it is not grounded to the car body (12v negative).

Isolation checks are done to keep the HV negative nice and floating compared to the Ground or 12v negative. And when there are faults it opens the contactors.


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## Kevin Sharpe (Jul 4, 2011)

I would recommend consulting with Mike at Indra. They have recently completed this process and have a new vehicle registered


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## jacksdad (Apr 13, 2015)

Thanks Kevin 

I have emailed them to see if they are interested in helping me with certification so thats great - no reply as yet though  emailed wednesday


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## Kevin Sharpe (Jul 4, 2011)

jacksdad said:


> no reply as yet though  emailed wednesday


I do know they are very busy  You could also try a PM here if they don't respond in a few days...


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## jacksdad (Apr 13, 2015)

Kevin Sharpe said:


> I do know they are very busy  You could also try a PM here if they don't respond in a few days...


there's no rush


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## favguy (May 2, 2008)

This actually sounds quite reasonable and should be easy to achieve, especially if using a donor package such as the Leaf. 

The bugbear would seem to be the ludicrous testing fee. I can't imagine it being feasible for most conversions, whether done by individual hobbyists or conversion businesses to have an additional £6k added to the cost of a conversion! 

So does anyone have anymore feedback/experience regarding this at all at this point? 

Mike, (Skooler) if you read this thread, would you like to comment on your experience regarding any post November registrations you've done and how your business is dealing with them?


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## jacksdad (Apr 13, 2015)

So I spoke to Mike from Indra at length a very helpful guy. However i ended up more confused. Mike seems to have been told that for conversions he needs to comply with ece100 rev 2 which is much more stringent than rev 01 and requires destruction testing and fire testing vibration testing temperature testing etc. However for me with a kit car not a conversion the IVA test seems to me to state ECE 100.01 :

https://www.gov.uk/government/publications/iva-manual-for-vehicle-category-m1

page 267:


This section should be read in conjunction with the required standards
set out in General Construction.
Ensure the vehicle or system as presented is accompanied by
satisfactory evidence in the form of:
Original mass produced vehicle approval to ECE R100,
or
 A test report to ECE R100.01 witnessed by the Approval
Authority (VCA) or Authorised Technical Service
 Model Report created by Technical & Support Services, Ellipse
Swansea (TaSS)
and in these cases a Visual Inspection is required






which i think then means compliance with 01 which is these things:

5. SPECIFICATIONS AND TESTS 
5.1. Protection against Electrical Shock 
These electrical safety requirements apply to high voltage buses under conditions where they are not connected to external high voltage power supplies. 
5.1.1. Protection against Direct Contact 
The protection against direct contact with live parts shall comply with Paragraphs 5.1.1.1. and 5.1.1.2. These protections (solid insulator, barrier, enclosure, etc.) shall not be able to be opened, disassembled or removed without the use of tools. 
5.1.1.1. For protection of live parts inside the passenger compartment or luggage compartment, the protection degree IPXXD shall be provided. 


this is a long this pin i'm hoping anderson connectors will meet this ??

5.1.1.2. For protection of live parts in areas other than the passenger compartment or luggage compartment, the protection degree IPXXB shall be satisfied. 

this is a mechanical finger should be ok



5.1.1.3. Connectors 
Connectors (including vehicle inlet) are deemed to meet this requirement if: 
(a) They comply with 5.1.1.1. and 5.1.1.2. when separated without the use of tools, or 

? i need to lock my anderson connectors ??


(b) They are located underneath the floor and are provided with a locking mechanism, or 
(c) They are provided with a locking mechanism and other components shall be removed with the use of tools in order to separate the connector, or 
(d) The voltage of the live parts becomes equal or below dc 60V or equal or below ac 30V (rms) within 1s after the connector is separated. 

5.1.1.4. Service Disconnect 
For a service disconnect which can be opened, disassembled or removed without tools, it is acceptable if protection degree IPXXB is satisfied under a condition where it is opened, disassembled or removed without tools. 

5.1.1.5. Marking 

5.1.1.5.1. The symbol shown in Figure 1 shall appear on or near the REESS. The symbol background shall be yellow, the bordering and the arrow shall be black. 
Figure 1 
Marking of High Voltage Equipment 
5.1.1.5.2. The symbol shall also be visible on enclosures and barriers, which, when removed expose live parts of high voltage circuits. This provision is optional to any connector for high voltage buses. This provision shall not apply to any of the following cases: 
(a) Where barriers or enclosures cannot be physically accessed, opened, or removed; unless other vehicle components are removed with the use of tools; 
(b) Where barriers or enclosures are located underneath the vehicle floor. 
5.1.1.5.3. Cables for high voltage buses which are not located within enclosures shall be identified by having an outer covering with the colour orange. 

5.1.2. Protection against Indirect Contact 
5.1.2.1. For protection against electrical shock which could arise from indirect contact, the exposed conductive parts, such as the conductive barrier and enclosure, shall be galvanically connected securely to the electrical chassis by connection with electrical wire or ground cable, or by welding, or by connection using bolts, etc. so that no dangerous potentials are produced.

Need to bond all metal parts tegether 

5.1.2.2. The resistance between all exposed conductive parts and the electrical chassis shall be lower than 0.1 ohm when there is current flow of at least 0.2 amperes. 
This requirement is satisfied if the galvanic connection has been established by welding. 
5.1.2.3. In the case of motor vehicles which are intended to be connected to the grounded external electric power supply through the conductive connection, a device to enable the galvanical connection of the electrical chassis to the earth ground shall be provided. 
The device should enable connection to the earth ground before exterior voltage is applied to the vehicle and retain the connection until after the exterior voltage is removed from the vehicle. 
Compliance to this requirement may be demonstrated either by using the connector specified by the car manufacturer, or by analysis. 

I'm planning on doing test with an off board charger so i'm guessing the above does not apply to me 

5.1.3. Isolation Resistance 
This Paragraph shall not apply to chassis connected electrical circuits where the maximum voltage between any live part and the electrical chassis or any exposed conductive part does not exceed 30Vac (rms) or 60Vdc. 

5.1.3.1. Electric Power train consisting of Separate Direct Current- or Alternating Current-buses 
If ac high voltage buses and dc high voltage buses are galvanically isolated from each other, isolation resistance between the high voltage bus and the electrical chassis shall have a minimum value of 100Ω/V of the working voltage for dc buses, and a minimum value of 500Ω/V of the working voltage for ac buses. 

I dont know what it means by AC and DC buses unless its talking about DC before controllers and AC (PWM) after controllers in which case they are isolated so i need a 100 x144 =14400 Ohm resitance between live cables and chassis - this should be ok im assuming


The measurement shall be conducted according to Annex 4 "Isolation resistance measurement method". 


5.1.3.2. Electric power train consisting of combined dc- and ac-buses If ac high voltage buses and dc high voltage buses are galvanically connected isolation resistance between the high voltage bus and the electrical chassis shall have a minimum value of 500Ω/V of the working voltage. 


However, if all ac high voltage buses are protected by one of the 2 following measures, isolation resistance between the high voltage bus and the electrical chassis shall have a minimum value of 100Ω/V of the working voltage: 
(a) Double or more layers of solid insulators, barriers or enclosures that meet the requirement in Paragraph 5.1.1. independently, for example wiring harness; 
(b) Mechanically robust protections that have sufficient durability over vehicle service life such as motor housings, electronic converter cases or connectors; 
The isolation resistance between the high voltage bus and the electrical chassis may be demonstrated by calculation, measurement or a combination of both. 
The measurement shall be conducted according to Annex 4 "Isolation resistance measurement method". 


5.1.3.3. Fuel Cell Vehicles 
If the minimum isolation resistance requirement cannot be maintained over time, then protection shall be achieved by any of the following: 


(a) Double or more layers of solid insulators, barriers or enclosures that meet the requirement in Paragraph 5.1.1. independently; 
(b) On-board isolation resistance monitoring system together with a warning to the driver if the isolation resistance drops below the minimum required value. The isolation resistance between the high voltage bus of the coupling system for charging the REESS, which is not energized besides during charging the REESS, and the electrical chassis need not be monitored. The function of the on-board isolation resistance monitoring system shall be confirmed as described in Annex 5. 

I think this exists within the curtis controller so i assume this will be enough if i can program a warning from this although will only be on when controller is on ??


5.1.3.4. Isolation Resistance Requirement for the Coupling System for Charging the REESS 
For the vehicle inlet intended to be conductively connected to the grounded external ac power supply and the electrical circuit that is galvanically connected to the vehicle inlet during charging of the REESS, the isolation resistance between the high voltage bus and the electrical chassis shall be at least 1MΩ when the charger coupler is disconnected. During the measurement, the traction battery may be disconnected.


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## jacksdad (Apr 13, 2015)

5.2. Rechargeable Energy Storage System (REESS) 
5.2.1. Protection against Excessive Current 

The REESS shall not overheat. 
If the REESS is subject to overheating due to excessive current, it shall be equipped with a protective device such as fuses, circuit breakers or main contactors. 
However, the requirement may not apply if the manufacturer supplies data that ensure that overheating from excessive current is prevented without the protective device. 

this is a function of the elektromotus BMS so i think ok also i have a 800 amp fuse so i assume this covers this 

5.2.2. Accumulation of Gas 
Places for containing open type traction battery that may produce hydrogen gas shall be provided with a ventilation fan or a ventilation duct to prevent the accumulation of hydrogen gas. 

I'm assuming my lipo batteries dont need this ??

5.3. Functional Safety 
At least a momentary indication shall be given to the driver when the vehicle is in "active driving possible mode''. 


this is ok a light on dash when curtis is ready to go (live at the interloc on accelerator pedal) 


However, this provision does not apply under conditions where an internal combustion engine provides directly or indirectly the vehicle's propulsion power. 


When leaving the vehicle, the driver shall be informed by a signal (e.g. optical or audible signal) if the vehicle is still in the active driving possible mode. 

not sure about this has anyone else ever complied with this im guessing some kind on pressure pad on driving seat i think they have these on fork lifts ??

If the on-board REESS can be externally charged by the user, vehicle movement by its own propulsion system shall be impossible as long as the connector of the external electric power supply is physically connected to the vehicle inlet. 

Not sure if this applies to off-board charging but some kind of interloc on the charging circuit i guess 

This requirement shall be demonstrated by using the connector specified by the car manufacturer. 
The state of the drive direction control unit shall be identified to the driver. 
5.4. Determination of Hydrogen Emissions 
5.4.1. This test shall be carried out on all vehicles equipped with open type traction batteries. 

so i guess does not apply to me 


5.4.2. The test shall be conducted following the method described in Annex 7 to the present Regulation. The hydrogen sampling and analysis shall be the ones prescribed. Other analysis methods can be approved if it is proven that they give equivalent results. 
5.4.3. During a normal charge procedure in the conditions given in Annex 7, hydrogen emissions shall be below 125g during 5h, or below 25 × t2g during t2 (in h). 
5.4.4. During a charge carried out by an on-board charger presenting a failure (conditions given in Annex 7), hydrogen emissions shall be below 42g. Furthermore the on-board charger shall limit this possible failure to 30min. 


5.4.5. All the operations linked to the battery charging are controlled automatically, included the stop for charging. 

Covered by BMS i guess ?? 


5.4.6. It shall not be possible to take a manual control of the charging phases. 
5.4.7. Normal operations of connection and disconnection to the mains or power cuts shall not affect the control system of the charging phases. 
5.4.8. Important charging failures shall be permanently signalled to the driver. An important failure is a failure that can lead to a disfunctioning of the on-board charger during charging later on. 
5.4.9. The manufacturer has to indicate in the owner's manual, the conformity of the vehicle to these requirements. 
5.4.10. The approval granted to a vehicle type relative to hydrogen emissions can be extended to different vehicle types belonging to the same family, in accordance with the definition of the family given in Annex 7, Appendix 2.



I would be really grateful for any input into the above


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## favguy (May 2, 2008)

Hi Guys,

Just wanted to post an update to this topic for the UK guys.

Regarding ICE to EV conversions. From feedback I've received from recent conversions over on the speakev forum, it would appear there is no IVA or further testing requirements in place (or being enforced) for conversions from ICE to EV. The procedure remains pretty much as it was prior to November last year. 

New build/Kit cars obviously will have to undergo the IVA and I suspect the EV aspects of this will have to be complied with, but I cant comment further on this.


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## skooler (Mar 26, 2011)

Thats what we are finding too. Meet reg100 r1 and all is ok.

Sent from my SM-N9005 using Tapatalk


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## tom3141 (Jul 2, 2016)

Does anyone have any recent updates on this? The IVA manual was updated yesterday but there doesn't appear to be any major changes within the EV section.

I'm considering a scratch built EV and I'm trying to find out if I'd need to pass any tests other than the IVA. I've emailed the DVSA but not had a response yet. The ECE R100.01 standard doesn't seem to be too hard to meet but I'm unsure whether a separate test is required or whether I can just state it meets the regulations.


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## tom3141 (Jul 2, 2016)

I've heard back from DVSA:

"_At present DVSA will carry out a visual inspection only as per the General Construction section of the manual for Electric/Hybrid vehicles, you will not need to provide documentary evidence of compliance to ECE R100_"

I asked for further clarification on this and basically the Department for Transport are currently looking at changing the requirements so that to pass an IVA you must first have documentary evidence of compliance with ECE R100. This would have to be done through an approved technical service and would be "very costly indeed". 

However, at the moment it appears that an IVA test can be passed without the need for documentary evidence of ECE R100 compliance. They expect it to remain this way for vehicles with battery voltages under 48V but there is the possibility this will change for all other electric vehicles.

The consultation on this has recently finished: https://www.gov.uk/government/consultations/road-vehicles-improving-air-quality-and-safety. 

Section 5.11 states:

"_Electric vehicle sales are increasing rapidly so it seems appropriate to ensure that those built in low volumes are as safe as those built and approved by the major manufacturers. UNECE Regulation 100 covers a range of electric safety__ issues, for example ensuring that the unwary are unlikely to electrocute themselves while poking around under a car bonnet. This Regulation is compulsory for EU type approved vehicles so we are proposing to introduce this for NSSTA and IVA, at the ECE R100.01 level._"

This seems reasonable but it will be a shame if it means that it will be prohibitively expensive to pass the testing for a scratch built EV.


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## Kevin Sharpe (Jul 4, 2011)

tom3141 said:


> This seems reasonable but it will be a shame if it means that it will be prohibitively expensive to pass the testing for a scratch built EV[/SIZE].


The Netherlands already have much more stringent requirements than the UK and it's forced people to use approved components for their conversions. This is not necessarily prohibitive, for example New Electric had the Siemens/DMOC/GEVCU EMC tested/approved, but probably means that we will have to work together to finance testing of products like the Tesla controllers (for example) if we want to use them in the future.


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## tom3141 (Jul 2, 2016)

I think the test is more to do with the safety of the wiring in each individual vehicle than what components are used. It looks at things like cable colour, labelling, and connector suitability etc. I may be wrong but this is the impression that I got.

There’s no indication that this will be needed for a conversion either. It only applies to vehicles needing an IVA as far as I’m aware.


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## Kevin Sharpe (Jul 4, 2011)

tom3141 said:


> I think the test is more to do with the safety of the wiring in each individual vehicle than what components are used.


It's only a matter of time... I think the UK will eventually include EMC as they have done in The NL.


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## Emyr (Oct 27, 2016)

I haven't seen MSVA mentioned in any of the articles discussing this. A heavy quad would be an affordable first build made unviable by such a requirement.


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## tom3141 (Jul 2, 2016)

I was told if these regulations come in, vehicles with a battery voltage under 48V are likely to be exempt. I guess a heavy quad could fall into this category.


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## arundas1404 (Nov 11, 2019)

I have imported a Hyundai Ioniq Hybrid car in to UK. Now DVLA is asking for document to prove ECE R100.01. Do you have any ideas how to get one. Contacted Hyundai still waiting on response.


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## jacksdad (Apr 13, 2015)

I have an update i am closer to finishing now so looking at certification, so contacted MIRA and have had it confirmed a certifiacte of compliance with R100.01 will cost around £5K i and have been given a provisional form to fill then a phone call which has obviously moved on since i contacted them before - not sure I'm really ready yet but it seem a more formal process is in place. 

A few things i'm not really sure i understand - one question they ask is if the DC and AC bus are galvanically isolated - im note sure i know what that means firstly im assuming the ac bus is the 3 phase high voltage cables connected from the curtis controller to my AC motor i assume these are galvanically isolated from the HV DC supply inside the controllers - does anyone know if this is correct. ??

Thanks for input as always


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## skooler (Mar 26, 2011)

Its the charging side. So AC from House/charger to the DC battery side.



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## jacksdad (Apr 13, 2015)

Thanks Mike, i have an off board charger my plan is to charge up drive around a bit and come home so the house AC and car DC are connected through the elcon charger off board via DC HV lead - there is a Can connection and a contactor in the charging box controlled from BMS so the BMS controls the charging current and voltage and can disconnect the charge current using the contactor. 

So is the AC and DC galvanically isolated through the charger i assume so due to induction isolation that i assume occurs ? and the House ac earth and the chassis earth are not connected as there is no AC connected to the car so it is not earthed. This only relevant as the R100.01 talks about insulation resistance with an alarm set for 100ohms/volt so 14.4 Kohm for galvanically isolated and 300ohm/volt for non isolated so 45Kohm - i am just about to purchase an insulation testing board from Bender that needs the insulation resistance value that will trigger an alarm to be factory set so wanted to know what to set this at- Mike what do you do for your conversions and IVA ??

Jon


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## SOL EV (Oct 27, 2021)

@jacksdad How did you get on with your IVA requirements?


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