In this whitepaper, we address the Lithium ion battery safety guidelines for US imports, which affect many manufacturers who are producing their goods in China and Asia and seeking to ship them to the USA for sale.
- Product safety
A) Underwriters Laboratories (UL)
B) The International Electrotechnical Commission (IEC)
C) The Institute of Electrical and Electronics Engineers (IEEE)
D) Cellular Telephone Industries Association (CTIA)
E) SAE International
- Transport safety
- Compliance recommendations from US CPSC
- Lithium battery safety in practice
- Source documents
The use of batteries in consumer products continues to grow exponentially. As such, lithium ion battery safety has become an important topic for US importers to understand.
With this proliferation of batteries and the miniaturization of portable products, manufacturers have sought to increase battery operating times while reducing the size and weight of the battery and the battery-powered product.
This has led to battery chemistries that pack higher energy in smaller packages. High-energy chemistry batteries include lithium ion, lithium ion polymer, and lithium metal batteries that are thinner, smaller, and lighter weight and contain more energy than traditional rechargeable and non-rechargeable batteries.
Although conventional battery chemistries, such as lead acid, pose fire and explosion hazards, the combination of high-energy volatile chemistry packed into a small volume requires special safeguards to minimize potential hazards.
High-energy density batteries need enhanced safety systems and additional care when using and handling, both in or when removed from the product; and batteries must be properly tested with the product, in its intended use and with the charger as a system.
CPSC Reports indicate incidents have occurred while the product is in use, in storage incl. transport, and during battery charging.
There have been a number of recalls involving lithium-ion batteries / battery packs / battery chargers used in cellular telephones, portable computing products, personal electronic products, and electric scooters (hoverboards).
There have also been a number of recalls involving other types of batteries used in products such as battery-powered ride-on toys and portable battery-powered tools.
Potential hazards include overheating, fire, electrical shock from battery chargers, thermal burns, exposure to alkaline battery electrolytes, and high-velocity ejected internal components of batteries.
3. Product safety
Other than the near universal standard industry practice and market-based demands for listing and recognition of cells and batteries as components and end-products, there are no mandatory requirements for lithium battery safety testing. This applies to UL, IEC, IEEC and the like.
Regardless, because product safety is important (brand image, liability, etc.) and because passing safety certifications are one means of assuring products are safe, the practice of testing to UL, IEC, IEEC etc. is both routine and assumed by most consumers.
International Organizations and their Battery Safety Standards
- Underwriters Laboratories (UL)
UL is an independent product safety certification organization which, in conjunction with other organizations and industry experts, publishes consensus-based safety standards. For lithium batteries, key standards are:
- UL 1642 (Lithium Batteries) – This standard is used for testing lithium cells. Battery level tests are covered by UL 2054.
- UL 2054 (Household and Commercial Batteries) – For lithium batteries, UL 2054 defers all component cell level testing to UL 1642.
- UL 2580 (Batteries for use in Electric Vehicles)
- The International Electrotechnical Commission (IEC)
IEC is a non-profit standards organization that writes International Standards for all electrical, electronic and related technologies. IEC standards address general, safety, and transportation specifications. For lithium batteries, key standards are:
- IEC 62133 (Secondary Cells and Batteries containing Alkaline or other Non-Acid Electrolytes – Safety Requirements for Portable Sealed Secondary Cells, and for Batteries made from them, for use in Portable Applications)
- IEC 60086-4 (Primary Batteries – Safety of Lithium Batteries)
- IEC 61960 (Secondary Cells and Batteries containing Alkaline or other Non-Acid Electrolytes – Secondary Lithium Cells and Batteries for Portable Applications)
- IEC 62281 (Safety of primary and secondary lithium cells and batteries during transport) This standard is similar to UN/DOT 38.3.
- The Institute of Electrical and Electronics Engineers (IEEE)
IEEE is an international non-profit organization covering technologies related to electricity and develops safety standards for the industry, including batteries. For lithium batteries, key standards are IEEE 1725 and IEEE 1625 both of which are design guidelines, not pass/fail safety standards:
- IEEE 1725 (Rechargeable Batteries for Cellular Telephones)
- IEEE 1625 (Rechargeable Batteries for Multi-Cell Mobile Computing Devices)
The Cellular Telephone Industries Association (CTIA), also known as the Wireless Association, is an international trade group that certifies compliance with IEEE 1725 and IEEE 1625 standards.
CTIA has taken IEEE 1625 and 1725 standards and generated pass/fail criteria in order to convert IEEE’s safety guidelines into something quantifiable and certifiable. In addition, CTIA is currently developing an industry standard method for measuring battery life in smartphones.
Through their CATLs, the CTIA also manages a program to permit operators and their suppliers to validate Li-ion battery compliance with the IEEE Standards 1725 and 1625.
- SAE International
SAE International (Society of Automotive & Aerospace Engineers) is a professional organization for the aerospace, automotive, and commercial vehicle industries. SAE develops standards for engineering professionals. With hybrid and fully electric vehicles now entering the marketplace in large numbers, the need for battery standards is getting greater attention.
Key SAE standards for lithium batteries include:
- SAE J 2929 (Electric and Hybrid Vehicle Propulsion Battery System Safety Standard – Lithium -Based Rechargeable Cells)
- SAE J 2464 (Electric and Hybrid Electric Vehicle Rechargeable Energy Storage System (RESS) Safety and Abuse Testing)
4. Transport safety
The UN (United Nations) issues recommendations for the transport of dangerous goods worldwide, and the U.S. DOT (United States Department of Transportation) defines shipping regulations for the U.S. under 49 CFR, Sections 100 – 185. Section 173.185 specifically addresses specifications and exceptions and packaging for lithium ion batteries; section 172.101 covers shipping.
Together, the UN and DOT guidelines define test requirements for the safe packaging and shipment of lithium metal and lithium ion batteries. Safety test criteria are defined in the “Recommendations on the Transport of Dangerous Goods, Manual of Tests and Criteria, Part III, Section 38.3.”
- UN/DOT 38.3 (also known as the T1-T8 Tests and UN ST/SG/AC.10/11/Rev. 5). Covers transportation safety testing for all lithium metal and lithium ion cells and batteries. The test criteria span 8 different tests (T1 – T8) that are all focused on hazards associated with transportation.
- UN/DOT 38.3 is a self-certify standard. Independent third party test lab certification is not required. However, because of potential liability issues, most companies choose to use third-party test labs.
NOTE: unless a company intends to be extremely restricted in its options for transporting their lithium batteries (ground transport as Class 9 Hazardous Goods), they will need to certify that their batteries have passed UN/DOT 38.3.
There are several other international organizations serving the transportation industry which have their own lithium ion battery safety regulations. Although these regulations are based on UN/DOT 38.3 and rely heavily on packaging/shipping guidelines provided in 49 CFR sections 173.185 and 172.101, some differences regarding shipping/transportation exemptions and inclusions exist.
Listed here for reference are the major international transportation organizations:
- PHMSA (Pipeline and Hazardous Materials Safety Administration, U.S. DOT)
- IATA (International Air Transport Association)
- ICAO (International Civil Aviation Organization)
- IFALPA (International Federation of Air Line Pilots’ Associations)
- IMDG Code (International Maritime Dangerous Goods code)
5. Compliance recommendations from US CPSC
CPSC recommends that:
- Components and battery-powered products comply with applicable safety standards, be it voluntary or otherwise
- New components and products that are not yet subject to voluntary standards be designed considering the best practices from similar voluntary standards;
- Battery-powered products are designed with a system approach addressing thermal protection, charge and discharge protection, and use in the product, including:
- Cells suitable for intended loads and conditions and manufactured with good quality control
- Battery packs with proper Battery Management Systems, including charge control, short-circuit protection and cell balancing
- Chargers that comply with applicable voluntary standards and are suitable for product/fit for purpose
- End-product systems (including cells, batteries, chargers, and product) are tested together for safe function under all reasonably foreseeable use conditions
6. Lithium ion battery safety in practice following a 3-step decision-making process
Decision 1. – UN/DOT 38.3
Should you self-certify or use an independent third-party testing lab?
- Using a third-party lab helps to mitigate liability should an incident occur
- If using a third-party test lab, it is best if the lab is ISO/IEC 17025 accredited, and approved by OSHA as a Nationally Recognized Testing Laboratory (NRTL)
- Whichever option you choose, all levels must be tested – cells, modules, and packs
Decision 2. – Cell testing
Is cell testing necessary? If yes, which standard should you use?
NOTE: It is highly likely that cells are already tested to UL 1642 and certified/listed by a third-party laboratory. Typically, new cell designs are certified/listed by the cell manufacturer and battery certification is the responsibility of the end-user / application device manufacturer.
- Cell listing for U.S. markets typically use UL1642
- For Battery certification, UL 2054 applies
NOTE: For lithium batteries, UL 2054 Section 2.1 (Lithium Cells) internally references UL 1642 for the cell level test requirements.
- The European-based IEC 62133 is rapidly becoming a global standard
- IEC 62133 is required for battery certification through the CB Scheme
- Although ANSI C18 is U.S.-based, third-party certification/listing (i.e. ETL Certification) to UL standards is more universally applied for lithium battery safety.
Decision 3. – Battery certification
Depending on your market needs, consider one of the following:
- UL 2054 (for general battery safety certification; global recognition and acceptance)
- IEC 62133 (for Europe and CB Scheme certification)
- SAE J2464 / J2929 (for Electric and Hybrid Vehicles; other standards for Light Electric Vehicles)
NOTE: Consider using application specific standards where these exist i.e. for medical devices, power tools, etc.
7. Source documents
US CPSC brief on Batteries
United Nations recommendations on the transport of dangerous goods https://www.unece.org/fileadmin/DAM/trans/danger/ST_SG_AC.10_11_Rev6_E_WEB_-With_corrections_from_Corr.1.pdf
Title 49 of the Code of Federal Regulations – Wikipedia page https://en.wikipedia.org/wiki/Title_49_of_the_Code_of_Federal_Regulations
IATA 2018 Lithium Battery Guidance Document https://www.iata.org/whatwedo/cargo/dgr/Documents/lithium-battery-guidance-document-2017-en.pdf
FedEx guidelines on Lithium Ion batteries shipments https://www.fedex.com/content/dam/fedex/us-united-states/services/LithiumBattery_Overview_2018.pdf
Intertek brief “Navigating the regulatory maze of lithium battery safety” http://batterypoweronline.com/wp-content/uploads/2013/11/Intertek_Regulatory-Maze-WP.pdf
Do you need a consultation with a specialist in safety regulations?
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