Regulatory Update: New Safety Standard for REESS Systems

Effective July 1, 2025, the European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR) 2025 has officially incorporated ISO 6469-1:2019/A1:2022 as a mandatory technical requirement for electric trucks transporting hazardous materials . This marks a critical shift from traditional "test-pass" certification to a comprehensive "system-compliance" approach for battery safety.

Core Regulatory Changes

The new standard introduces a complete safety management system rather than just requiring isolated tests (like needle penetration or fire tests under UNECE R100). Companies must now implement a closed-loop safety process:

Risk Assessment → Design Mitigation → Verification → Manufacturing Control → Reporting → Certification

This approach requires creating traceable, auditable documentation to prove that battery systems maintain "inherent safety" under real-world complex operating conditions .

Key Safety Objectives

When a thermal runaway occurs in any single battery cell, the system must achieve three core safety goals:

1. Timely Warning

• Battery Management System (BMS) must precisely and quickly identify early signs of thermal runaway
• Real-time monitoring of critical parameters (temperature, voltage, current) with multi-level alarm thresholds

2. Effective Containment

• Thermal insulation design to prevent heat propagation
• Directed venting channels to safely release pressure and gasses
• Emergency cooling systems to suppress thermal spread
• Fire barriers between battery compartments and cargo areas containing hazardous materials

3. Personnel Protection

• Clear, immediate alarms providing sufficient response time
• Escape route illumination and emergency communication systems
• Driver training protocols for battery-related emergencies

Legal Basis and Compliance Requirements

Impact on Businesses and Action Plan

This regulatory upgrade means traditional battery certification is no longer sufficient for market access. Companies must:

1. Systematically Review and Upgrade Battery Systems

• Re-evaluate thermal management designs with focus on propagation prevention
• Implement enhanced BMS with advanced thermal runaway detection algorithms
• Redesign battery compartment structures for better isolation and venting

2. Establish ISO 6469-1/A1-Compliant Management Systems

• Develop comprehensive risk assessment methodologies specific to hazardous cargo operations
• Create verification protocols that simulate worst-case scenarios
• Implement manufacturing process controls with traceability
• Design documentation systems that satisfy audit requirements

3. Prepare for Certification

• Engage notified bodies early for gap analysis
• Conduct pre-compliance testing to identify and address issues proactively
• Develop staff training programs on the new safety protocols

Business Implications

Next Steps for Manufacturers

1. Immediate Assessment (within 30 days):

   • Identify all electric truck models used for hazardous material transport
   • Map current battery systems against ISO 6469-1/A1 requirements
   • Contact a notified body for preliminary consultation

2. Technical Upgrades (6-9 months):

   • Redesign battery thermal management and containment systems
   • Implement advanced BMS with thermal runaway prediction
   • Test prototypes under worst-case conditions

3. System Implementation (3-6 months):

   • Develop safety management documentation
   • Train production and quality teams
   • Conduct internal audits to verify compliance

Note: Non-compliance after July 1, 2025 will result in:

• Denial of road transport permits
• Border rejections
• Potential fines up to 4% of annual turnover
• Product recalls at manufacturer's expense

The shift to system-based safety compliance represents a fundamental change in how electric trucks for hazardous goods are designed, manufactured, and certified. Companies that proactively embrace this transition will not only meet regulatory requirements but also gain a competitive edge through enhanced safety performance and market trust.