Lithium battery certifications and rules. - Page 1
Forum section: electronics / general

author: Simon
author_rank: Unknown
timestamp: June 22, 2021, 02:51:36 pm
content: Is there anything stopping me from taking 2 off the shelf UN certified battery packs and putting them into one box (in series) and calling it my own battery? I am being told that to transport this new pack we would have to get it recertified as a new battery. This seems a bit extreme considering someone would have shipped a box full of these certified packs where I want to ship just 2 at a time and can put each in it's own little compartment. The new pack is for use with one specific product and would not be sold for use with anything else, it can in fact be locked to that product so that it cannot be used elsewhere although each battery coms with it's own BMS anyway.

author: sandalcandal
author_rank: Unknown
timestamp: June 23, 2021, 09:03:06 am
content: In my experience getting li-ion battery pack systems shipped, yes. Even if you are using already certified systems, you will need to retest. I guess the logic is if you integrated the packs poorly then they could internally short circuit in transit. Depending on capacity however, you can get reduced test schedules when using already certified components. Table 38.3.3 of the UN Manual of Tests and Criteria has a nice summary.https://unece.org/about-manual-tests-and-criteriaIn addition to a UN 38.3 test report you usually seem to need a MSDS to get shippers to agree. There are also special clauses and packing instruction to let you ship untested battery systems but that may or may not be worth the pain and additional cost of getting someone who to agree to ship untested batteries (see special provision 310).Ultimately the main challenge is finding someone willing to ship for you. One major German logistics company didn't seem interested in helping even with all the paper work available...

author: Psi
author_rank: Super Contributor
timestamp: June 23, 2021, 09:08:35 am
content: Better off having your system accept two separate off-the-shelf certified battery packs, rather than trying to combine them into a single module yourself.Yes, it's stupid, but meh, pick your battles.

author: sandalcandal
author_rank: Unknown
timestamp: June 23, 2021, 09:14:06 am
content: You can even just ship the two off the shelf batteries packaged separately i.e. not in the custom box as long as you have the paper work for the off the shelf batteries and that'll be fine.

author: Psi
author_rank: Super Contributor
timestamp: June 23, 2021, 09:32:29 am
content: hehe, his battery pack would have its own battery packs.

author: Simon
author_rank: Unknown
timestamp: June 23, 2021, 09:36:21 am
content: The problem is that we want to make sure we get to sell the spare batteries so want to put additional circuitry with the battery. This is not to screw the customer over but it's hard to support someone half way around the world over the phone who may be making the problem for themselves by not using a correct battery and support costs money so you buy from us, we support you. It also opens up other possibilities in the product eco system. If even putting the UN certified battery in a box with a connector is an issue then it's getting rather difficult to do anything.

author: f4eru
author_rank: Super Contributor
timestamp: June 23, 2021, 11:21:56 am
content: Quote from: Simon on June 22, 2021, 02:51:36 pmNot the same thing. Shipping separate batteries and batteries connected together is a different animal. Batteries are insulated and disconnected in shipping for this very reason.A BMS that can cutoff overcurrent short circuit for one battery may well fail when having to cut off 2 packs with double the voltage, for example. Same for thermal consideration.You absolutely have to certify your new product as soon as you ship the batteries in it (even if integrating only one pack into your product, and shipping itconnectedQuote from: Simon on June 23, 2021, 09:36:21 amYeah. right. We're generally immune to that kind of marketing statements here.Quote from: Simon on June 23, 2021, 09:36:21 amYep. Increasing cost just to block alternative options for your customer. They love antifeatures, right ?Quote from: Simon on June 22, 2021, 02:51:36 pmYou want to screw your customer over. Get over it, it's OK.Quote from: Simon on June 23, 2021, 09:36:21 amSure, but that fact does not require a lock. A question like "do you use an original battery? No? try again with an original one and call us back" is good enough.Quote from: Simon on June 23, 2021, 09:36:21 amMoar profits from DRM locks, good for management bonus eh ?My suggestion: Do a huge favor for yourself and your customers. Use standard batteries.You will have less cost, perhaps lower price and/or higher margin, and still sell spares to >2/3 of your customers.You'll have less development, certification, paperwork effort.Most pros don't want to fumble with different batteries because of risks. The ones who do do it out of necessity and will do it no matter what locks you put in place.Yeah, you'll have to be a bit restrictive on support, and ask more questions.....Much better strategy on the long run. Especially for a small fish in the big pond.

author: Simon
author_rank: Unknown
timestamp: June 23, 2021, 12:25:18 pm
content: If they buy our batteries at the same price as anyone else's what is your problem? not that I care that you have a problem. I have several reasons and options to require a data link and to be sure they are not doing it wrong. Future projects for example require large batteries that need moving from location to location. Having a system that can be carried in parts may be desirable. But I damn well not going to have someone try to run the kit with less batteries or it will damage them and they will claim fault with the kit or battery.You know the first question they ask when some one calls in for support is "is it our equipment you have". Often it's not. Even using off the shelf batteries is requiring a lot of work to get this right for the price the customer wants.

author: voltsandjolts
author_rank: Unknown
timestamp: June 23, 2021, 12:54:15 pm
content: Quote from: Simon on June 22, 2021, 02:51:36 pmIn my view, that would be fine, as two certified batteries.It's no different to using two certified cells in series (which I would not define as a battery pack if they were individually removable).Two seperate battery packs are just that, two battery packs, not one.But we are at the mercy of the couriers, they may have restrictions that go beyond general shipping regulations, particularly when it comes to air freight / IATA.Pick your courier and see what their rules are.DHL guidance is quite good, if a little overwhelming initially.http://www.dhl.co.uk.origin.dhl.com/en/express/shipping/shipping_advice/lithium_batteries.html#guides_materialsNotice that DHL have a category for an item that contains up to 4cells.So, if you can live with that limit then you might have an easier time with shipping.

author: penfold
author_rank: Frequent Contributor
timestamp: June 23, 2021, 01:34:29 pm
content: I believe UN38.3 contains a nasty little clause regarding the use of previously certified cells and that batteries constructed from them must be recertified. I'm honestly not certain where the boundary falls between "battery constructed of cells and some electronics" and "product which contains a cell, cells or battery". But it may be that UL 1642 with its "their use in a complete product" would suggest re-certing of the complete sub-assembly is a must.What kind of size battery are we talking about here? Is the system otherwise CE tested (or on the path to be)? Though I forget which manufacturers, there are some OEM packs available with a built-in EPROM for identification. You're totally within your rights and discretion as a designer to prevent users from using the wrong battery, the immoral part is when you charge them £££ for that privilege or design it so it bricks the system.

author: tszaboo
author_rank: Super Contributor
timestamp: June 23, 2021, 01:35:47 pm
content: If you put "small' batteries into a product, it is relatively simple to do. Small meaning less than 20Wh per cell and less than X lithium content. With 18650s or small pouch cells your are fine. You will need to make some technical specification and shipping needs some declarations.You should absolutely use batteries that are UN certified, but most companies will have that now, and its not that hard to do. I am not sure if I would use batteries though, but cells, and build my own battery. Or ask a company specializing in this, they would label it as your product.Shipping batteries separate is much bigger PITA to do.

author: Simon
author_rank: Unknown
timestamp: June 23, 2021, 02:06:10 pm
content: The batteries go with the original machine. We then supply replacements when required. Some customers will run straight off the mains. I suspect that the machine itself will need certifying if we put the battery into it and we need to have the option for them to carry spare batteries.

author: mc172
author_rank: Frequent Contributor
timestamp: June 23, 2021, 04:27:51 pm
content: I just had a chat with DHL about this as I'm curious about this myself.They told me that this:Quote from: voltsandjolts on June 23, 2021, 12:54:15 pm... only applies to international postage and not UK postage. They said I cannot post any lithium cells internationally but I can send them within the UK and asked how many I wanted to send, so I looked at the international guidance and said between one and eight (based on what it said).The guidance linked above says that I need to put a certain comment in the handling instructions, however when you go to book delivery there is nowhere to put that information. I originally asked for some clarification on this and the answer was "that document is for international postage" and "we have customers sending batteries in the UK". I asked for some documents/guidance to support this but most of my questions were deflected or walked around by repeating that they have customers sending lithium cells within the UK.I even plainly asked for the steps I'd need to carry out in order to go about sending lithium cells within the UK and I couldn't get anything other than "we have customers sending lithium cells in the UK".They say that they can't provide any guidance on sending lithium batteries within the UK, other than "it depends on how big they are, small mobile phone batteries are OK". I asked for specifics but couldn't get anything.I went back and asked why they wanted to know how many cells I wanted to send, and was told that it depends on how many I wanted to send. So I asked how many mobile phone batteries I could send since they mentioned those specifically themselves, and the answer was two. They couldn't provide any documentation to back this up. I asked how many 18650s I could send and couldn't even get an answer, no documentation, no guidance.I asked about how I'd have to package them, how I'd have to label the box, basically everything in the linked document above, nothing.They then told me to go to FedEx.It's all a bit of a shambles and to be honest I find it all quite strange like something's not quite right. The law says that you pretty much cannot send lithium batteries in the post unless it's with original equipment. So then how do you buy lithium cells, which is something that I can do even from RS and the like?

author: Simon
author_rank: Unknown
timestamp: June 23, 2021, 06:46:52 pm
content: You can send 100Wh total with no more than 20Wh per cell. I can imagine that it is a mess as it's all about liability and finger pointing and no one wants to be the one with a finger pointing at them.

author: Simon
author_rank: Unknown
timestamp: June 23, 2021, 06:48:31 pm
content: trying to send stuff in the mail was a mess as post office workers just say no batteries. I just say that all multimeters have batteries fitted and that shuts them up. They are not even lithium.....

author: sandalcandal
author_rank: Unknown
timestamp: June 23, 2021, 09:06:07 pm
content: Quote from: mc172 on June 23, 2021, 04:27:51 pmSounds similar to my experience. They initially make it sound like they can but if you actually want it done then they can't. My guess is that for small customers they don't want to bother with the work or the liability involved in battery transport. I had to use an independent, local logistics broker.

author: Siwastaja
author_rank: Super Contributor
timestamp: June 24, 2021, 08:43:17 am
content: This thread mixes up lithium batteries and lithium ion batteries which is utterly critical especially if communicating with couriers or authorities because the two are completely different animals and different rules govern the shipment of them.Be careful, it's a rookie mistake and there just is no place in professional work for mixing these terms up IMHO.

author: mc172
author_rank: Frequent Contributor
timestamp: June 24, 2021, 11:05:06 am
content: Quote from: Siwastaja on June 24, 2021, 08:43:17 amAlthough you're technically correct, most couriers in the UK don't let you post either, so it makes no difference whether someone mixes them up or not within the context of this thread. In fact a lot of UK couriers including the venerable Royal Mail forbid batteries full stop, regardless of chemistry.As far as I can tell, they have the same shipping restrictions whether they're lithium metal or lithium ion:https://www.iata.org/contentassets/05e6d8742b0047259bf3a700bc9d42b9/lithium-battery-guidance-document-2020.pdfThere is one difference that I can see in the requirements of the sender and it makes sense - you don't have to ensure that lithium metal batteries are at a 30% maximum state of charge.Maybe you can enlighten me on the differences?

author: Siwastaja
author_rank: Super Contributor
timestamp: June 24, 2021, 11:58:25 am
content: Thevery linkyou posted shows completely different criteria and flowcharts, completely confirming my point.You need to get labelling right, fill the forms right, certify with the correct information according to the correct standards.If you don't even get the basic type of the battery correctly, that's not just going to work. You have to be careful with such basics.Criteria for li-ion is in Wh and for lithium batteries in grams of lithium making mixup hopefully noticed early on when the unit doesn't match the title, but it's still a risk and wasted time. Be careful.And no, I'm not only "technically correct". Security on air transport especially has no place for language mixup. Wrong information is not only a security risk, it's also a risk of your package not getting delivered which can get expensive. Don't try to find excuses for poor behavior, just start doing it right instead.

author: mc172
author_rank: Frequent Contributor
timestamp: June 24, 2021, 01:07:16 pm
content: It's a moot point. Most couriers prohibit batteries full stop and if they do accept batteries, they just forbid lithium regardless of the next word. So who cares?As for the flowcharts they're largely the same, you need big flashing warning signs on the packaging, which are as far as I can see identical for both types and both are forbidden on passenger aircraft, so what's the point in all this? How do I even get to the point with a courier in the UK to tell them whether I've got lithium ion or lithium metal? Please let me know and at that point I'll care about what type of lithium batteries I've got.Quote from: Siwastaja on June 24, 2021, 11:58:25 amSo is that lithium ion or lithium metal?

author: tszaboo
author_rank: Super Contributor
timestamp: June 24, 2021, 01:46:42 pm
content: Quote from: Siwastaja on June 24, 2021, 08:43:17 amYou saw a lot of primary lithium batteries with a BMS?

author: Siwastaja
author_rank: Super Contributor
timestamp: June 24, 2021, 05:21:12 pm
content: No, I don't remember seeing primary lithium cells with BMSs. That doesn't matter; the shipping company won't be looking at the documentation of the product to find words "BMS" deducing "Ah! This has BMS! So itisn'tprimary lithium battery but lithium ion battery!"Also the claim that all shipping companies refuse to point blank ship all lithium and lithium ion cells, hence all this discussion if meaningless, is ridiculous. Of course batteries are shipped all the time, all sizes. You need to find one who does that and file the proper paperwork. Which involves knowing the battery type...Look, you can start a massive battle over some wording but think twice before doing that, it serves no purpose but to destroy the topic. I just made a quick remark about the importance of proper terminology in such regulated field. I don't understand why this generates totally unnecessary backlash from multiple posters. I'm correct on this trivial matter and you know it; try to live with it.

author: Simon
author_rank: Unknown
timestamp: June 24, 2021, 06:01:19 pm
content: Quote from: Siwastaja on June 24, 2021, 08:43:17 amYou mean like royal mail just going weak at the knees about any battery - but then they are not professionals. The rules I have read apply equally to everything that has the word "lithium" in it. Heck, I even had to take the CR2032 cells out of µCurrents once when shipping them as they would not take any batteries at all under any circumstances fitted or not. All these people are run by lawyers who just want to make money whilst not being sued.

author: Simon
author_rank: Unknown
timestamp: June 24, 2021, 06:07:52 pm
content: Today I got to see the Ansmann batteries we got from RS. Hm just carboard boxes in a cardboard box. Loose wires that were pre-strippedwith rubber caps pushed over the wires. The day someone slips up with the size of the rubber caps or the wire outer diameter - fire waiting to happen. But it's OK, they are approved batteries. But then I have not forgotten the carefully packed box of batteries I once got from hobby king where one of the batteries boxes was crushed and that was before putting them in a box and putting a label on that said that if the out box was damaged it should not be carriedthe world is full of idiots that have just not been caught out yet.

author: nctnico
author_rank: Super Contributor
timestamp: June 24, 2021, 06:32:13 pm
content: Quote from: Siwastaja on June 24, 2021, 05:21:12 pmIMHO the best way forward is to have the battery pack UN38.3 certified and have a notice on the outside of the pack which says so. Using words like lithium or lithium-ion rings no bell with anyone working at a transport company. They don't know and/or don't care. They only look for the certification sticker. IOW: a transporting company is the worst party to ask technical questions.Whether or not having two batteries in a seperate box needs recertication; I don't know. The best starting point is probably to look at laptops with two batteries inside and see what kind of approvals these are subject to. Then talk to a notified body (certification company) which deals with batteries and see what they think. However the easiest way out is to use a single battery pack with the right size. There are so many battery packs on the market that it seems odd to me that there isn't a single one which just fits the bill.

author: Simon
author_rank: Unknown
timestamp: June 24, 2021, 06:33:47 pm
content: Yea that is probably why the post office won't even take NiCD or NiMH, it has no certificate and without one they won't ship it

author: Simon
author_rank: Unknown
timestamp: July 05, 2021, 10:37:25 am
content: I can't actually find any regulations on incorporating a battery into equipment. I think the difference here is around what I call my device. If I call it a battery then um, it probably wants looking at. If I call it a power station because it has a removable battery and other circuitry then it's not a battery. But I have to make the battery removable. UK law states that:QuoteSo who get's to arbitrate on paragraph 2? that looks like an open invitation to ignore the clause. We would be taking the devices back in any case and possibly recycling components and enclosures and then return the batteries to their source for recycling which is already paid for. You pay £1/kg in the price of lithium batteries for recycling when you send them back "for free".

author: f4eru
author_rank: Super Contributor
timestamp: July 05, 2021, 08:14:50 pm
content: Translation:MAKE THE BATTERY REMOVABLE(when possible)

author: penfold
author_rank: Frequent Contributor
timestamp: July 06, 2021, 05:55:58 pm
content: Whether it's called a "power station" or a "battery" it sounds like it's removable. Though I do wonder how much electronics you could put in it before it stops being a battery. Can you still get away with sticking "return to the manufacturer for safe disposal" or did they put a stop to it?Considering UN38.3 is self certifiable, then back to the original question, I'd be surprised if you couldn't get away with certifying a battery pack on the basis of pre-certified cells. Apart from operating thermals, I don't see many of the original tests being invalidated by being in an enclosure so long as the method of securing was appropriately considered.

author: Simon
author_rank: Unknown
timestamp: July 06, 2021, 06:09:21 pm
content: Quote from: f4eru on July 05, 2021, 08:14:50 pmConsidering the batteries are supplied with flying leads, the last thing we need is people cutting the wires off and having a short. We as the manufacturer are dutybound to take the batteries back so would rather do it safely in their enclosure.

author: nctnico
author_rank: Super Contributor
timestamp: July 08, 2021, 09:01:13 am
content: No, choose a battery pack with connectors (like a laptop has). There are so many standard form-factor battery packs you can buy. Extra bonus is that you are not bound to a single supplier.

author: Simon
author_rank: Unknown
timestamp: July 08, 2021, 06:02:49 pm
content: Quote from: nctnico on July 08, 2021, 09:01:13 amcare to share some examples? There is an abundance of preapproved modules that come with just flying leads. As for something standard like what laptops have, I was never aware of any such standard, I thought it was war among the titans and my current laptop has a single large pouch cell inside it. I'd also like my battery to have a very specific odd ball voltage. this is high enough to allow the equipment to work without an 85% efficient boost converter that diminishes capacity but not too high that the machine becomes inefficient anyway.

author: Simon
author_rank: Unknown
timestamp: July 11, 2021, 08:37:51 am
content: As it happens reading the actual testing requirements if I was to produce a battery "of UN38.3 approved batteries" no testing is required..... I can do that up to 6.2kWh of battery or a battery with up to 500g of lithium.