There are two reasons that the export of NEV (New Energy Vehicles) has become a trend. First, after the baptism of the domestic market, China’s NEV enterprises have established product advantages and stepped out of the country to seize the international market. Second, under the appeal of the international climate organization, more and more countries have begun to formulate carbon emission policies. The export of vehicles used to be the common mode of transport by sea, but now the use of railway transport is increasingly favored by shippers. This is because of the sudden change of the international situation and the maturity of the Sino-European train transport. This article will analyze the requirements of railway transport based on the domestic policy and the documents of the Railway Cooperation Organization.

In April 2023, the National Railway Administration, the Ministry of Industry and Information Technology, and the National Railway Group jointly issued opinions on supporting NEV railway transport and serving the NEV industry. For plug-in hybrid or pure electric new energy commodity vehicles that are driven by lithium ion batteries and are included in the scope of the Road Motor Vehicle Manufacturers and Product Announcement of the Ministry of Industry and Information Technology (export new energy suppliers are not subject to this restriction), NEV railway transport is not managed as dangerous goods, and the carrier parties handle the transportation. This is in accordance with the requirements of the Railway Safety Management Regulations, Table of Safety Supervision and Management of Dangerous Goods Railway Transport (GB 12268) and other laws, regulations and relevant standards.

This shows that: First, new energy transport in the domestic railway system does not belong to dangerous goods. Second, if NEV needs an international combined transport, in addition to meet the domestic requirements, the relevant provisions of the Railway Cooperation Organization shall be complied too.

Domestic Transport

Although transport in the domestic railway system can be transported as non-dangerous goods, it is necessary to pay attention to:

1、In the course of consignment of new energy commodity vehicles, the shipper should provide the factory certificates of new energy commodity vehicles (export of new energy commodity vehicles are not subject to this restriction). The certificates should be consistent with the actual consignment of commodity automobile products.

2、 Battery charging state and fuel tank state. The charging state of the power battery of the new energy commodity vehicle shall not exceed 65%. There is no leakage and other problems when the tank hole cover of the plug-in hybrid electric vehicle is closed. The oil shall not be filled or extracted during railway transportation.

3、In addition to assembled batteries, no spare batteries and other batteries in the course of consignment of new energy commodity vehicles. In addition to the necessary items equipped at the factory, no other items shall be carried inside the new energy commodity vehicle and in the trunk.

International Combined Transport

It shall also comply with the requirements of the Rules for the Transport of Dangerous Goods, Annex No. 2 to the Agreement on the International Movement of Goods by Rail of Railway Cooperation Organization (hereinafter referred to as Annex No. 2). The Railway Cooperation Organization is an intergovernmental organization. There are 27 member States (as of August 2011): Azerbaijan, Albania, Belarus, Bulgaria, Hungary, Viet Nam, Georgia, Iran, Kazakhstan, China, North Korea, Cuba, Kyrgyzstan, Latvia, Lithuania, Moldova, Mongolia, Poland, Russia, Romania, Slovakia, Tajikistan, Turkey Turkmenistan, Uzbekistan, Ukraine, Czech Republic and Estonia. In addition, as observers to join the Railway Cooperation Organization are Germany (German railway), France (French railway), Greece (Greek railway), Finland (Finnish railway), Serbia (Serbia railway) and other national railways, as well as the Gier-Choppron-Ebinfuerte Railway Company (Gieschofu railway). Railway Cooperation Organization almost covers the Central Europe train through the countries.

In the List of Dangerous Goods, Part 3 of Annex 2, Special Provisions - exemptions for limited quantities and exceptional quantities: battery-powered vehicles or battery-powered equipment, with UN number UN 3171, are not subject to the restrictions of Annex 2 of the Agreement on the International Movement of Goods by Rail. Please refer to Special Article 240 of Chapter 3.3. The main requirements of Special Article 240 are:

1、The battery or battery pack meets the requirements of all tests in Part III, 38.3 of the Manual of Tests and Criteria;

2、Batteries and battery packs shall be produced according to the following quality control system;

3、UN3171 battery-powered vehicles, vehicles only include the use of liquid battery packs and sodium batteries, lithium metal battery packs or lithium-ion battery packs powered vehicles, can be transported after installing these batteries.

Conclusion

Integrated with the transportation requirements of the domestic railway system and the Railway Cooperation Organization, the NEV railway transport needs to meet the following requirements:

1、The battery pack meets the requirements of UN38.3.

2、The battery factory should obtain the quality system certificate.

3、Before transportation, the battery load should not exceed 65%.

4、When transporting and packaging, spare batteries or other batteries should not be included in the package.

5、The shipper should provide factory certificates of new energy commodity automobiles (export of new energy commodity automobiles are not subject to this restriction).

In addition, if the destination country is not in the Railway Cooperation Organization, such as Spain. In addition to meeting the above requirements, the requirements of the RID shall also be considered.

For more information about railway transport, please contact MCM.