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Re-certification timeline

Clause 10 sets two dates: one for new type approvals, one for vehicles already in production under GB 38031-2020.

Clause 10 verbatim

  1. Implementation of the Standard For new vehicle models applying for type approval, the standard shall be implemented from the date of implementation of this document; for vehicle models that have already obtained type approval, the standard shall be implemented starting from the 13th month after the implementation of this document.

Source: clause 10 (PDF page 29).

Calendar

Date Event
2025-03-28 Document released
2026-07-01 Standard takes effect
2026-07-01 New vehicle type approvals must comply
2027-08-01 Already-approved vehicle models must comply (13 months after effective date)

Strategic implications

Engineering note (non-normative): the 13-month grandfather window for already-approved models is a clean strategic decision point for OEMs with 2025–2027 product roadmaps:

  • Certify under GB 38031-2020 and re-certify by 2027-08-01. Viable for vehicles whose pack architecture is close to passing the 2025 thermal-propagation criterion (5.2.7) without major BOM change. Buys ~13 months of production under known requirements.
  • Skip directly to GB 38031-2025. The right call for any vehicle whose pack needs a structural redesign to meet "no fire, no explosion" pack-level after thermal propagation. A 2026-Q1 launch under 2020 then a forced re-pull and re-cert in 2027 is more disruptive than launching to the new standard from the start.
  • Bottom impact (8.2.16) is the cheapest 2025 delta to engineer in late. A pack passing 2020 may pass 8.2.16 with a localised under-floor reinforcement — more tractable than a full thermal-propagation rebuild.
  • Type-approval supplements via Table 7 apply only to changes within the same standard edition. Re-certifying from 2020 to 2025 is not a "partial change"; it is a new certification under a new standard, so the Table 7 retest matrix does not provide relief here.

Cross-reference

Source

Clause 10 (PDF page 29).