AS/NZS 3001.2:2022 STANDARD

Lithium Batteries Update
Summary for Recreational Vehicle Installers and Manufacturers

PREFACE

The new AS/NZS 3001:2:2022 came into effect on the 20th of November 2023. All new recreational vehicles that the new standards apply to need to be compliant from this date. The major impact for users of Lithium batteries and associated electrical systems is the new rules about where lithium batteries can be installed within vehicles and transportable structures. Unfortunately, as is often the case with the release of major standards, there has been debate and conjecture about the standards, meaning some inaccurate misinterpretations have been widely spread. Amptron has been liaising with regulatory bodies across different states in Australia since the draft standards were released. We believe we are now in the position to advise our partners and customers, and we have summarised our take on the standards below.

SCOPE OF STANDARDS DIAGRAM:
 The scope diagram below gives the best overview of what recreational and not recreational vehicles the new standards apply to:

Amptron-diagram

List of applicable vehicles which need to conform with the new standards:
(a) Caravans
(b) Camper vans
(c) Motor homes
(d) Camper trailers
(e) Pop top caravans
(f) Tent trailers
(g) Fifth wheel caravans
(h) Slide on campers
(i) Converted buses or trailers

OUR TAKE ON INCLUDED RECREATIONAL VEHICLES:
We have used the following common vehicle examples to further explain what needs to comply with the standard.

  • Caravan, camper trailer or similar with a separate axle that is towed behind a vehicle. All installations must comply with AS/NZS 3001.2:2022.
  • Motorhome based on Mercedes Sprinter, Fiat Ducatto or similar with internal habitable space/ bedding/ bunks. All installations must comply with AS/NZS 3001.2:2022.
  • Landcruiser ‘Troopy’ or modified 4WD where ‘habitable’ space has been created within the vehicle for sleeping and / or other activities. Vehicle also has an AC input ‘inlet plug’ for power supply/ battery charging. All installations must comply with AS/NZS 3001.2:2022.

NOTABLE EXCEPTIONS:

  • 4×4 or Australian Road Compliant vehicle which has on board LV outlet, without the provision for connecting to an external supply. For example a dual cab ute with a canopy install, however all ‘habitable space’ is external to the vehicle. Does not need to comply with AS/NZS 3001.2:2022.
  • Boats – not applicable to this standard.

ALTERATIONS AND REPAIRS

How the new standard deals with alterations and repairs to in-scope vehicles will have a large impact on the industry. See below the phrases from the standards below which relates to alteration and repair requirements:

1.5.1 Alterations
1.5.1.1 General

Alterations to electrical installations in connectable electrical installations shall comply with AS/NZS 3000, except as varied herein, and with the additional requirements of this Standard.

Alterations to connectable electrical installations shall not cause any portion of the original electrical installation, or electrical equipment connected thereto, to –
   (a) carry currents or sustain voltages in excess of those permitted by this Standard; or
   (b) be used in any manner that is not in accordance with this Standard. 

1.5.2 Repairs
1.5.2.1 General

Repairs to existing electrical installations in connectable electrical installations or parts thereof may be effected using methods, fixtures and fittings that were acceptable when that part of the electrical installation was originally installed or with methods, fixtures and fittings currently available as a direct replacement, provided that the methods satisfy the fundamental safety principles of AS/NZS 3000. 

OUR TAKE ON ALTERATIONS AND REPAIRS

When you are replacing a component within the system with a like for like replacement (eg replacing and AGM / Lead Acid battery with another AGM / Lead Acid Battery) then it is acceptable that the installation complies with the original standard that was applicable at the time of the install. As per Clause 1.5.2.1 the terminology of this is a ‘direct replacement’. However, if you are for example upgrading the system to a Lithium battery based system, you are essentially moving away from the notion of a ‘direct replacement’. Therefore all aspects of the electrical installation should be brought ‘up to spec’ to comply with 3001.2:2022.

As far as we are aware in most cases, adding new batteries ‘as an upgrade’ to an existing system would be considered an alteration. We have sought clarification from state regulators [Appendix 1] on this issue.

LITHIUM BATTERY TESTING COMPLIANCE

See below the phrase from the standard below which relates to key safety standard compliance requirements:

5.4.12.3.1 Requirements

Each lithium ion battery shall be provided with a battery management safety system either integrated into a battery pack or as a separate component. All lithium ion batteries shall comply with AS IEC 62619.

The battery management safety system is designed to protect the lithium ion battery from potentially damaging situations.

OUR TAKE ON LITHIUM BATTERY ‘COMPLIANCE AND SAFETY FUNCTIONS’:

The standard IEC 62619 is a widely used international standard. There is some confusion in the market, as this standard can be applied to individual cells or a finished battery product. Only certifying the cell which the battery uses ignores the function of the battery management system (BMS) and the reaction of the battery as a whole under adverse conditions such as short circuit, high temperature or significant mechanical damage. Users should be cautious of battery manufacturers only citing cell compliance/ certification rather than complete battery pack compliance.

Amptron will be testing complete battery packs to IEC 62619 moving forward as per our interpretation, also confirmed by government standards bodies. Test reports which apply to our batteries will be available for viewing. Amptron will do this testing in addition to using high quality cells that have also been tested to IEC 62619. Given the costs and rigorous requirements of this test, we believe that only a select number of manufacturers in Australia will have fully tested batteries available.

LITHIUM BATTERY MANAGEMENT SYSTEM

ELECTRICAL PROTECTION

See the phrase from the standard below which relates to safety requirements of the battery safety management system:

5.4.12.3.3 Electrical Protection

The battery management safety system shall continuously monitor the voltage, current and temperature of the battery and protect the following by automatic disconnection. Over and under-voltage, over and under temperature, and over current. The battery management system should be as per the cell manufacturer’s recommendation or designed and supplied by the same manufacturer.

OUR TAKE ON SYSTEM ‘BMS’ PROTECTION

The above considerations should be standardised functions of any single lithium battery. Amptron uses advanced, safe and reliable battery management systems. We take great care in the setting of the BMS parameters in line with our manufacturing, and communicating these parameters to the user through our datasheets and user manuals. In addition, for the BluEdge series, it is possible to adjust the parameters through software if needed, which Amptron can make available to qualified and professional users.

MONITORING AND COMMUNICATION

See the phrase from the standard below which relates to battery system monitoring and communication

5.4.12.3.4 Monitoring device

Each battery (or bank of batteries) shall be monitored via a battery monitor designed for managing lithium ion batteries. The monitor shall display the state of charge (SoC) and may display voltage.

Communications with the monitor may be by wired or wireless connection direct to the battery management safety system.

OUR TAKE ON ‘MONITORING AND COMMUNICATION’

Amptron raised several questions regarding the monitoring of the battery with Standards Australia, as well as state based regulatory bodies. We confirmed the following:

  1. A smartphone application communicating with the battery is not considered adequate, as the phone may run out of battery, may not be present, or may not be able to be accessed in case of emergency.
  2. Wireless communication between the monitor and the BMS is OK, however the wireless display/ visualisation device should be permanently mounted within the recreational vehicle. The wireless protocol should connect directly to the BMS.
  3. Traditional shunt monitoring devices may not be considered compliant because they are not connected directly to the battery as per 5.4.12.3.4. Also, if the battery system has parallel or series connected batteries, the shunt cannot display individual critical battery information.In our opinion the best practice is a permanently connected monitor that communicates directly to the battery (or batteries if multiple in series/ parallel) BMS. In addition, this monitor should also report critical faults along with SOC and voltage. Amptron has updated its range to now include communication ports and Bluetooth modules, which connect directly to the battery management system. In addition, for most of the BluEdge series, if you are using multiple batteries connected in series or parallel, you able to communicate with one of the batteries allocated as the Master/Host, which will consolidate and communicate the information from all of the individual batteries. We have sought clarification from state regulators [Appendix 2] on this issue.

LITHIUM BATTERIES INSTALLATION LOCATION

See the phrase from the standard below that relates to install locations:

5.4.12.2 Location. Lithium ion batteries shall –

  1. Be installed externally, i.e. behind a wall, compartment or barrier that prevents the egress of gases into the habitable area; and
  2. Not enter the habitable area of the structure; and
  3. Be installed to operate within the manufacturer’s defined operating temperatures, including IP rating; and 4. Be installed in a suitable battery container where the battery manufacturer has not provided encapsulated cells.

OUR TAKE ON ‘LITHIUM BATTERIES INSTALLATION LOCATION’

If the space within the vehicle is used for sleeping and other living activities that make it a ‘habitable space’ then Lithium batteries cannot be installed in this space.

  • Based on our research, any storage compartments for the batteries should be sealed from the ‘habitable space’ and not accessible from the ‘habitable space’ without using tools. EG: Under the bed of a caravan, in a cupboard in the same ‘habitable space’ where people may reside/ sleep, and where the battery bay is accessible from the habitable space and not fully sealed and vented to the outside. This should no longer be done.

OUR TAKE ON BEST PRACTICE

Treat the battery like an LPG tank. The battery compartment should be located external to the main habitable space of the recreational vehicle, e.g. in a sealed separated enclosure to the habitable area. If the battery compartment is within the space of the recreational vehicle (e.g. in a cavity below seating) then this cavity should be accessed via an external hatch, rather than from within the habitable area. In this case the access and venting is external, and any gas escaping should not enter the habitable area.

  • NON-BEST PRACTICE, BUT ACCEPTABLE – Electrical Standards Victoria noted in August 2023 that the battery could be installed within the habitable space of a caravan, noting that the barrier to the space would need to prevent gases from entering the habitable area. For example, an existing under seat battery hatch, is retrofitted with a sealable lid, which can be compressed down meaning no gas to escape. The venting of this hatch must be external, with sealed glands used on every cable that runs between the hatch and the habitable space.
  • While internally accessed battery hatches may be somewhat acceptable, (and definitely easier for builders and manufacturers), large access lids/ hatches have the potential to warp or bend over time meaning the seal will be compromised. The downside of this battery access method is that a compromised seal may lead to venting into the habitable space.
We have sought clarification from state regulators [Appendix 3] on this issue.

OTHER CONSIDERATIONS

REGARDING LITHIUM BATTERIES AND INSTALLATIONS

While above we describe specifics around Lithium batteries, the AS/NZS 3001.2:2022 standard covers all electrical aspects of in-scope vehicles. We suggest that the following sections are understood, as these items of an install interact directly with the battery/ batteries.

  • Section 5.6 Isolation Switching and Control – Always ensure a system uses appropriate fuses/ DC breakers for the battery bank.
  • Section 5.5.2.2 PV / Solar Panel Arrays – Further guidance is available on sizing and spec of solar systems to charge the battery.
  • Section 4.11 Earthing – Correct earthing prevents damage to batteries, but in addition connected inverters and charge supply systems need to ensure earthing compliance with the standard.
  • Section 2 External Supplies/ Generators/ Inverters – Whether it be a charger, connected for charging the batteries, or inverter connected to the DC output of the batteries to supply a recreational vehicle with AC power, considerable consideration should be given to section 2.

OBTAINING THE STANDARDS

Full copies of the standard can buy purchased from the Standards Australia Website. If you are a member of the Caravan Industry Association Australia, access to the standard is available through Caravan Industry Association of Australia portal. If you would like clarification on any part of the standard, we would be happy to discuss with you via phone or email.

APPENDIX (1) ALTERATION AND REPAIRS

Response from WA Department of Mines, Industry Regulation and Safety

AMPTRON QUESTION:
In regards to section 1.5 it is not quite clear what the difference between ‘alterations’ and repairs is. Eg – If a caravan has a lead-acid battery that is no longer working, and it is replaced with a lithium battery as a drop-in-replacement (no other modification to the installation) is this classified as an ‘alteration’ or ‘repair?’

RESPONSE:
“In my view your example below would be called an alteration for the purposes of compliance with the standard. I would suggest that simply replacing a lead acid battery with the equivalent lithium ion battery would not satisfy the requirements of 1.5.1.1 (b) as I would assume (without looking at specific details) that the requirements are vastly different between section 5.4.11 and 5.4.12.”

Response from NSW Department of Fair Trading

AMPTRON QUESTION:
In regards to section 1.5 it is not quite clear what the difference between ‘alterations’ and repairs is. Eg – If a caravan has a lead-acid battery that is no longer working, and it is replaced with a lithium battery as a drop-in-replacement (no other modification to the installation) is this classified as an ‘alteration’ or ‘repair?’

RESPONSE:
“Clause 1.5.2.1 of AS/NZS 3001.2 provides the definition to what a repair is. To correctly understand the
requirements, it is easier to break down the parts of the clause and look at their separate requirements. There are a number of items to consider.

  1. This clause is for repair only. It is for when an item of equipment or part of the installation has failed. It cannot be used as an easy requirement for an alteration because it allows the existing arrangements to go unaltered.
  2. The wording “using methods, fixtures and fittings that were acceptable when that part of the electrical installation was originally installed”. This part is I ooking at a direct like for like replacement. For example, replacing a fight switch with a fight switch or an outlet for an outlet.
  3. The wording for the next part is “originally installed or with methods, fixtures and fittings currently available as a direct replacement”. This is taken at replacing a failed item of equipment with a modern replacement. The major part to this is the words “direct replacement”. This means of the same type, rating, basic technology as the failed component. To go away from this is an alteration. 
In your example you have a failed lead-acid battery. Lead-acid batteries are stiff available. Therefore a repair would be replacing the failed lead-acid battery with another lead-acid battery of the same capacity. To replace the lead-acid battery with a lithium battery would be an alteration as the lithium battery is not a direct replacement as it has a different technology to the originally installed item.”

APPENDIX (2) MONITORING AND COMMUNICATION

Response from WA Department of Mines, Industry Regulation and Safety

AMPTRON QUESTION:
Is a battery with a management system connected to a smartphone with an app, using Bluetooth, is this considered a suitable ‘battery monitor’ or does it need to be a monitor that is located and fixed within the vehicle/ transportable structure?

RESPONSE:

“I would suggest the monitor needs to be fixed within the vehicle. Comms between the product can be wireless as per above.” Response from NSW Department of Fair Trading

AMPTRON QUESTION:
Is a battery with a management system connected to a smartphone with an app, using Bluetooth, is this considered a suitable ‘battery monitor’ or does it need to be a monitor that is located and fixed within the vehicle/ transportable structure?

RESPONSE:
The requirements of the monitoring device fall under the overall requirements of Clause 5.4.12.3 “Battery
management safety system” because it is a sub-clause of this section. Clause 5.4.12.3.2 “Location” requires that the battery management safety system is no greater than 600mm from the battery.

As the monitoring device is a part of this system it is also required to be located no more than 600mm from the battery. Therefore it must located within the vehicle/transportable structure and can not be via a smartphone app.

APPENDIX (3) LITHIUM BATTERIES INSTALLATION LOCATION

Response from WA Department of Mines, Industry Regulation and Safety

AMPTRON QUESTION:

  1. Is there further definitions and notes around “externally”, or should we use the previous definition defined in 5.4.11 (Lead acid battery requirements) which notes “”Externally” means open to the environment or not anywhere within the enclosed structure of the connectable electrical installation. For example, a wall, compartment or barrier that prevents the egress of gases into the habitable area.
  2. Our take on this for motorhomes and caravans is that batteries can no longer be stored under beds, under seating or under kitchen setups if these compartments are ventilated into the main ‘habitable’ area of the vehicle. Is this assumption correct? Do we need to consider a lithium battery now like an LPG cylinder, whereby any compartment for it cannot be accessed from the inside of the habitable space, and needs to be sealed from that space, and accessed externally?
  3. If a lithium battery is sealed (to an IP67 standard) in a plastic or aluminium enclosure, and has a engineered ‘vent’ which is connected via a hose to the outside environment is this considered compliant with the standard, and ok to install a in a compartment/area which is accessible/ ventilated from the main habitable space?

RESPONSE:

  1. Not that I am aware of. 5.4.11 is applicable to lead acid batteries only. If the placement of a lithium ion battery meets all 4 points in 5.4.12.2 I would suggest that it would be considered being installed “externally” for the purpose of compliance with the standard.
  2. I would agree with that view.
  3. I would say no based on the fact that it should not be accessible from within the habitable area. If its accessible from within the habitable area that access point would also allow the egress of gasses.

Response from NSW Department of Fair Trading

 


 

Response from NSW Department of Fair Trading

AMPTRON QUESTION:

Same as above

RESPONSE:

  1. Use the same requirements for externally as given with the lead acid battery.
  2. Yes. Your assumption is correct in regards to the storage of the batteries. They should be considered like the LPG Cylinder and only accessed from the outside.
  3. No. As stated, the battery needs to be external. 

*This guide may change without prior notice