In 2023, with the EU’s comprehensive upgrade of safety requirements for L-category electric vehicles, a new mandatory test—the Overcurrent Test—was introduced into the ECE R136 regulation. This test is directly tied to whether products can be sold in the European market.

The regulation clearly defines key timelines: the transition period runs from January 4, 2023, to September 1, 2025, during which applications for both old and new versions are accepted. However, starting from September 1, 2025, new certificate applications based on the old version will no longer be accepted.

01 Strategic Forecasting: Deciphering Regulatory Core & Planning Timelines

Any successful certification project starts with in-depth regulatory understanding and forward-looking planning. The Revision 01 update to ECE R136 is not a minor revision, but a set of stricter technical requirements for the Rechargeable Energy Storage Systems (REESS) of L-category electric vehicles (e-bikes, electric motorcycles, etc.).

It applies to the electric drive systems and REESS of L-category vehicles with a speed exceeding 6 km/h. The core regulatory change is the addition of the Overcurrent Test requirement.

Enterprises must immediately establish a clear reverse timeline plan. Considering product design adjustments, sample production, testing cycles, and potential rectification time, it is recommended to initiate certification projects at least 9–12 months in advance.

During this phase, the preparatory work enterprises need to complete includes: determining target markets (selecting E-mark certification country codes), studying the specific requirements of the R136 regulation, evaluating the gap between current product status and regulatory requirements, and selecting suitable certification partners.

When choosing a certification body, enterprises should prioritize professional laboratories that offer pre-testing services—this can reduce the failure rate of formal testing by approximately 65%.

02 In-Depth Preparation: Sorting Technical Details & Preparing Certification Materials

The key to passing certification successfully lies in adequate technical preparation and documentation. ECE R136 sets comprehensive testing requirements for REESS, mainly covering the following 10 items:Vibration Test, Thermal Shock & Temperature Cycling Test, Drop Test, Mechanical Shock Test, Fire Resistance Test, External Short Circuit Protection Test, Overcharge Protection Test, Overdischarge Protection Test, Over-temperature Protection Test, and the newly added Overcurrent Test.

In particular, the newly added Overcurrent Test requires the system to trigger effective protective measures promptly when subjected to abnormal high-current impacts. This imposes higher requirements on the current monitoring accuracy and protection logic of the Battery Management System (BMS).

Beyond battery safety, the regulation also specifies detailed requirements for the high-voltage electrical safety of the entire vehicle, including protection against electric shock, insulation resistance, and waterproof performance.

Enterprises need to provide detailed certification materials during the preparation phase. Core materials for certification applications include:

• Manufacturer information (business license, ISO 9001 or IATF 16949 system certificate)
• Product technical documents (specifications, CAD drawings, electrical parameters, BMS descriptions)
• 4 complete battery pack samples

03 Efficient Execution: Managing Testing Processes & Obtaining Certificates

With all preparations in place, efficient execution becomes the key to obtaining certificates. The entire certification process can be summarized into the following six standardized steps:

1. Submit application and prepare materials
2. Send samples to authorized laboratories for testing
3. Compile test reports
4. Submit reports to the transport department of the certification-issuing country for review
5. Obtain E-mark certificate upon successful review

The certification cycle typically takes 6–8 weeks, with the exact duration depending on product complexity, one-time test pass rate, and the review efficiency of the certification body.

During the testing phase, enterprise technical personnel should maintain close communication with laboratory engineers to stay updated on testing progress and potential issues. If any non-conformities are identified, the root causes should be analyzed promptly and rectification plans formulated.

After passing the review, enterprises will receive a certificate with the E-mark logo. For example, "E4 R136" indicates that the product has been certified by the Dutch Ministry of Transport in accordance with R136 regulations. During the certificate validity period, enterprises must print the logo containing the certification country code and regulation number in a prominent position on the product.

Faced with opportunities and challenges in the European market, electric vehicle enterprises must proactively respond to regulatory updates. The certification process is a continuous systematic project, and sustained attention to and updates on regulations are the inexhaustible driving force for maintaining product market competitiveness.

As global attention to electric vehicle safety grows, the R136 regulation may be further upgraded in the future, adding more safety requirements.

Whether it is the rugged road conditions simulated in the vibration test or the extreme temperature differences experienced in the thermal shock test, each test serves as a solid foundation for the product’s long journey in the European market.