Regulatory Framework for Retrofitting in India | Compiled by ARAI

In 2021, Delhi Government allowed the old diesel vehicles (10+ years) to continue and bypass the National Green Tribunal’s ban, if fitted with an electric vehicle kit. This announcement has paved the way for emergence of a parallel industry to convert old ICE vehicles to electric.

The testing agencies are going to play a crucial role in commercialisation of EV kits, enabling kit manufacturers to get on Govt’s approved list of vendors. ARAI has set out clear technical requirements for the approval of EV retrofitting kits. The Type Approvals for EV Retrofitting kits ensure performance and safety of the retrofitted electric vehicles across a wide range of 2W and 3W categories, in addition to LCV, Buses, Trucks, etc.

Type tests AIS123 - Part1, Part2, Part3, regulated by ARAI to approve the EV retrofitting kits.

Type Approval procedure

Type approval procedure has 2 steps –

  • Kit component level approval – All the component aggregates being added to the vehicle, that can include traction motor, battery, inverter, wiring harness, connectors, state of charge indicators, any other electronics such as vehicle control unit, on-board chargers, need to be approved first as a kit – for conversion into either a hybrid or pure electric vehicle.
  • Vehicle level approval – The applicant must submit a retrofitted electric vehicle, the target vehicle in-use, to ARAI for Type approval.

Once both the type tests are conducted successfully, Type Approval certificate is approved for the vehicle. Based on which, the kit manufacturer can appoint dealers to sell those kits for that particular vehicle. The dealer can retrofit on behalf of the kit manufacturer.

AIS 123-Part 1

CMVR Type Approval of Hybrid Electric System (HES) intended for retro-fitment on – (i) Vehicles of M & N Category with GVW <= 3500kg, (ii) L Category

Scope – This standard lays down the requirements specific to vehicles retrofitted with hybrid-electric system of L, M1, M2 and N1 categories which comply with BS-II or subsequent emission norms, operate on either petrol, diesel, bio-diesel or ethanol except gaseous fuels such as CNG, LPG and LNG, have GVW not exceeding 3500 kg, and not been retrofitted earlier.

Hybrid Electric System (HES) means the aggregate of components added by the manufacturer to the base vehicle for hybrid-electric operation. In the case of series hybrid retro-fitment, the kit manufacturer may modify the engine for operation or replace the engine.

Bi-Mode Hybrid Vehicle Configuration – In this configuration, after retro-fitment of the base vehicle with HES kit (without modification in fuel type of base vehicle), the user can operate independently either on IC Engine mode or Electric Powertrain mode by manually switching between the two modes of powertrain operation. Bi-mode configuration has recently been added to Part 1 and a number of companies are coming up with designs of such dual-mode powertrain systems.

AIS 123-Part 2

CMVR Type Approval of Hybrid Electric System (HES) intended for retro-fitment on vehicles of M & N Category with GVW > 3500kg

Scope – This standard lays down the requirements specific to Hybrid Electric System (HES) intended for retro-fitment on vehicles of M and N category having GVW >3500 kg, which comply to BS-II or subsequent emission norms, have not been retrofitted earlier (e.g CNG/LPG/Electric kits etc), which are not provided with permits for carrying dangerous or hazardous goods, as defined in CMVR.

It is the same hybrid conversion, as in Part 1, but for more than 3.5 Ton category vehicles, specially M2 and M3 categories, like smaller 12 meter standard buses as well as N2 / N3 categories, i.e the goods carrier vehicles.

AIS 123-Part 3

CMVR Type Approval of Electric Propulsion kit Intended for conversion of vehicles for pure electric operation

Scope – This standard lays down the requirements specific to Electric Propulsion kit intended for conversion of vehicles of L1, L2, L5, M, N1, N2 and N3 category for pure electric operation, which are manufactured on and after 1st January 1990 and not provided with permits for carrying dangerous or hazardous goods, as defined in CMVR.

Electric Propulsion Kit means the aggregate of components added by kit manufacturer/supplier to the base vehicle by replacing IC engine and associated accessories for pure electric operation. Here, the entire ICE powertrain is removed and replaced with the electric kit.

Tests to be performed

The approval process includes tests concerning vehicle weight changes, gradeability, brake performance, passerby noise level, motor power, EMC, requirements for constructional & functional safety, safety compliance of traction batteries, and mass emission (for hybrid vehicles). Additionally, the wiring harness & cable connectors are checked to ensure they can withstand voltage, low-temperature characteristics, heat ageing, thermal overload, have fluid compatibility, resistance to chemicals and flame propagation. ARAI has removed some environmental testing, and only high voltage safety requirements are checked as part of the functional safety. The rest of the environmental tests have been removed to reduce the cost of the Type Approval tests and the vehicle.

We would like to thank Mr Manoj Desai, General Manager at ARAI for providing above information on the current regulatory standards for retrofitting in India.


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