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Regulation Changes Q&A for Lithium Ion Battery Manufacturers

Anton Beck
Written by Anton Beck
Posted on July 11, 2016 at 11:36 AM

We're very proud to report that our product webinar, Lithium Battery Regulations and How They Affect OEMs, had the most viewer responses ever for a webinar hosted here at Epec! Over 300 registered for the event, confirming that these latest changes to shipping lithium battery are of real concern amongst some of the industry’s leading Original Equipment Manufacturers (OEMs).

Q&A From Our Live Battery Webinar

During our Q&A portion of the live webinar, we only had time to answer two questions. Since the opic of regulation changes for lithium batteries has so much buzz right now, we felt it was important to give answers to all the questions everyone submitted.

Watch the Recording Below:

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Question: I have never been given a straight answer as to what regulations we need to follow. A typical shipment for us might include 10 battery powered temperature sensors. The sensors are shipped fully assembled with an AA size battery (TLH5903 from Tadiran; Lithium/Thionyl chloride). Each battery is fit with a custom cable and connector. The entire battery is then shrink wrapped before being installed into our product. Lithium content is 0.65g/cell.

Answer: Any shipments of lithium batteries fall under the category of Dangerous Goods. Each person that offers Dangerous Goods needs to be trained and certified to do so by a recognized entity. In order to offer the Dangerous Goods to the carriers (UPS, FedEx, etc.) you will have to contract with them to ship Dangerous Goods. You will need to show them the training certifications from the recognized entity.

The cell in question has 0.65grams of Lithium content. This size of cell falls under Small Category. The regulations for shipping lithium batteries are:

  • 49CFR 173.185 for shipping within the United States
  • ICAO (IATA) for ship International by Air
  • IMDG for shipping by Ocean

Question: During the webinar I think you mentioned that the regulations indicated that a charge on a battery back had to be at or below 30%. However you also mentioned that the 30% did not apply if shipping with let’s say a computer. Given a computer that ships with 2 battery packs at 7800mA each what would be the acceptable charge % then? Where can I find that written in a regulation?

Answer: The 30% charge rule applies to lithium batteries shipped alone (UN3480). It does not apply if the batteries are packed with or contained in equipment (UN3481).

There are no other regulations about the state of charge for shipping that we are aware of. Cell manufacturers used to ship somewhere around 50% charged because that was the best way for a lithium battery to be stored. This was only a rule of thumb, and not a regulation.

Question: A metal or ion button cell in equipment that is under 1g or 20Wh respectfully would not require the shipping labels due to the exemption. Is this true if you had 10 components, each with the button cell packed within the component, packed in the same box? That would mean 10 small metal or ion button cells in one box. Is this still exempt? We currently believe this box would need to be marked even though each is under and they are installed within equipment.

Answer: Currently button cells are exempted from the hazard communication requirements if they are installed in equipment. We are not aware of a quantity limit listed in the regulations for the number of button cells per package when they are installed in equipment. Quantities generally start coming into play for cells that are either > 0.3 Lithium content or > 2.7Wh.

Question: If the final battery pack is UL approved, does that negate all the testing, or is there any difference. Does a battery pack have to be UL approved?

Answer: The UL testing covers some of the same parameters as the UN38.3, but if the battery is Lithium, it must pass the UN38.3 certification before it is UL tested and approved. In regards the 2nd question. No, that is dictated by the application and requirement of the device. If it is lithium, it will require the UN38.3 cert mandatory, but not necessarily UL.

Question: Does the vibration test requirement for the cell/battery only or is the terminal or external connector exempt from this requirement?

Answer: Generally the complete pack would be required to pass testing since the terminal or connector would be shipping with it. However if there is a special circumstance, that would have to be negotiated on a case by case basis with the agency doing the test.

Question: Are the training and certifications required for shipping even when the dangerous goods label is not required?

Answer: Yes, since all Lithium Batteries are considered Dangerous Goods the carriers require that you contract with them to offer shipments of this kind.

Question: Does 38.3 apply to battery packs shipped inside equipment?

Answer: 38.3 testing generally just involve the pack. Once the pack is tested it should be able to be shipped alone, or packed with or contained in equipment. However if there is an exception or special circumstance this should be negotiated with the agency that will do the 38.3 testing.

Question: Is there something similar for UN 38.3 certification for IMDG?

Answer: IMDG (International Maritime Dangerous Goods) code covers the specific packing instructions for shipping Dangerous Goods by ocean. 38.3 certifications covers cells and battery packs that will be shipped by air, ground, and ocean. This can be confirmed with the agency doing the testing.

Question: Do these requirements impact the final user flying with battery packs and the final device/product?

Answer: Usually the end user will only be able to purchase batteries or cells that have already been 38.3 tested. The airlines do have criteria on what passengers can bring aboard the airplanes and pack in their baggage. We would advise checking with the airlines that you are traveling with for their recommendations.

Question: If you have a button cell under 1g (metal) or 20Wh (ion) do you need to mark with labels?

Answer: Currently that is only correct if the button cells are installed in equipment. If you are shipping them standalone or just packed with equipment you would need to label the packages. However the rules have been somewhat fluid and are changing with increasing frequency. In the end it is up to the shipper that offers the shipment to the carrier to be up to date on how to prepare the shipment.

Topics: Battery Packs

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