Are lithium batteries actually allowed to be installed in the engine compartment of a car or camper? This question has occupied me a lot in the last few days and I have not found a proper answer on the Internet either.
In many forums it is written that it is forbidden to mount a lithium battery in a non-crash-proof area, for example in the engine compartment. Thus, in the event of an accident, it should come to a significantly higher risk. But is that really the case, or is it really forbidden and can even void the insurance coverage or the operating license?
First port of call KBA
I have contacted the Federal Motor Transport Authority in Flensburg with an inquiry to clarify the above facts. To my amazement, I received a concrete statement about my request after only a few hours:
Dear Mr. Rauschenberg,
Your inquiry has been forwarded to the Division for Basic Questions of Type Approval at the Federal Motor Transport Authority (Kraftfahrt-Bundesamt) for reply.
forwarded to the Therefore, I can provide you with the following information regarding the background
LET…..
For the framework of the type-approval procedure for recognized manufacturers, UN Regulation No. 100 contains the requirements for vehicles with regard to electrical safety. Only components or systems that are part of the vehicle’s electric drive system are taken into account there. Therefore, so-called “REESS” (accumulators for electric drive) are defined there. Starter batteries and other batteries/accumulators for other purposes do not fall within this definition and are therefore not covered in this framework. Thus, analogous to the gas-powered systems in the living area of motor homes, such parts are outside the type approval regulations and ultimately within the scope of the product responsibility of the vehicle manufacturer as the overall product responsible party, who to this extent must ensure a safe and compliant design of any systems also with regard to other regulations outside the type approval procedure.
However, since periodic inspections on such vehicles are intended for operation on public roads, you should contact a recognized technical inspection agency for specific information regarding such modifications to your vehicle.
So there’s the first clue, in general it’s already not forbidden for crash safety reasons. The corresponding regulation does not refer to starter or body batteries, but only applies to those batteries that are used for electric propulsion. Of course, the KBA is not responsible in our case, because technical modifications must be approved by the TÜV, for example, as also described in the KBA’s response.
Is the TÜV now the right contact?
So my next stop was the TÜV, but a call there didn’t really get me anywhere. I must have been the first person to register a battery 😩. I was referred to the website with the advice that IEC 62133 applies to batteries. Ahja.
IEC 62133
Here we are again in the land of standards and rules. IEC 62133 regulates the safety requirements for a battery. A battery must comply with IEC 62133 to obtain a CE marking.
So what does this mean for our battery under the hood?
Of course, the whole thing is an interpretation of standards and regulations on my part, but I could not find any reference in the relevant bodies to the fact that the subsequent installation of a lithium battery in the engine compartment is prohibited and the operating license of a vehicle expires. Always provided that the battery complies with the rules and standards applicable in the EU.
Then why not from the factory?
Vehicle manufacturers must comply with thousands of laws and standards as part of the various approval processes. In addition, warranty and guarantee requirements also apply. But it’s the thermal conditions that make it complicated with the lithium battery under the hood. I also do not want to rule out the possibility that other regulations may additionally take effect precisely because of the standards in the approval process.
Before anyone takes my text as legal advice, it is my own interpretation of the standards and regulations, as described above. In no way is this a recommendation for which I take responsibility in any form. Why am I writing this? Unfortunately, the Internet is full of muzzlers who are just waiting for us to make a mistake so they can use it to pillory us. All texts reflect our opinion, no more and no less.
Make Love, not War ☮️
