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by Kon-Peki 1376 days ago
> S5.1 Service brake systems. Each vehicle must be equipped with a service brake system acting on all wheels.

What is a "service brake"? Notice that the regulation you linked to includes requirements for EVs that have braking regeneration as a component of their "service brake".

It turns out that the top-level of FVMSS [1] says that "service brake means the primary mechanism designed to stop a motor vehicle."

So I think you are exactly right. There is nothing in the law that says you can't use a 100% brake regen system in an EV. It just has to work and meet the performance standards (and perform regen on all wheels). But I'd guess that you aren't going to see the traditional brake system disappear unless it starts getting in the way. They don't cost a lot (relative to the price of the car), don't weigh a lot, are really reliable, and work really well.

[1] https://www.ecfr.gov/current/title-49/subtitle-B/chapter-V/p...