International Compliance for Portable Device Batteries ...cii-resource.com/cet/FBC-05-04/Presentations/BTS/Millsaps_Cynthia.pdfBatteries –What the heck do I have to do to ship my

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International Compliance for Portable Device Batteries – What the heck do I have to do to ship my battery to…

Cynthia Millsaps

Energy Assurance, LLC

March 21, 2017


What are we going to cover?

• Small

• Li Ion (including Lithium Polymer)/rechargeable

• Batteries and their component cells

• For use in portable devices/applications

• Safety - Not covering recycling, chemical content, EMC/EMI

• Touch on industry specific items


Normal End Device ICM path

• Test to existing IEC standards with internationally harmonized country deviations

IEC standard

• Receive a single CB Scheme certificate with specified national deviations included

CB report and

certificate

• Use CB report to obtain various national certifications

National certifications


Why this doesn’t work with batteries

• Batteries are relatively young technology– Standards are not yet fully harmonized

– Standards are rapidly changing

– Knowledge is sketchy

• Batteries are usually a component of a larger product– End device standards can drive confusion

– End device use can drive component battery and cell requirements

– Shipping/packaging of system can affect requirements

• Highly publicized issues with Li ion batteries– Fear leads many countries to develop their own requirements

– In country testing


What Happens with Batteries

IEC/CB

Non-harmonized

In country –non-

harmonized

In country -harmonized

Shipping regulations


What is required?

Shipping/Transport

Mandatory

Voluntary or End Device Driven

• Transportation regulations

• UN 38.3

• IEC 62281

• India

• Korea

• Thailand

• Japan

• European Union

• USA/Canada

• Russia

• China??

• Taiwan


Shipping regulations – UN 38.3

Li Ion cells and batteries are Dangerous Goods/Hazardous Materials

• Shipped alone

• Shipped with equipment

• Shipped contained in equipment

Controlled by international, regional, and carrier regulations

Regulations require UN 38.3 testing prior to shipping

UN 38.3 battery testing:

• Requires 8 or 16 batteries

• Cells must be separately tested

• Includes 50X cycling and sequential testing

• 5-7 weeks

• Self declaration


Shipping regulations IEC 62281

IEC 62281 - IEC version of the UN 38.3 manual of tests for Lithium batteries.

IEC attempts to keep it harmonize, but it has differences:

• Component cell testing

• Package drop testing– May not be consistent with

shipping methods under new regulations

IEC 62281:2016 battery testing:

• UN testing can be reused

• Component cell testing must be completed

• 5-7 weeks

• For a CB report/certificate, – The cells must have a separate CB

report and certificate and

– Complete component cell testing; or

– Be fully tested when the battery is tested


Shipping regulations

Things to be aware of:

Testing is only 1 piece of the equation

• Air transport – IATA DGR- IATA annually

• Vessel shipments – IMDG Code – IMO – 2 years

• Ground – each country/region – on-going (US DoT 49 CFR…)

• Carriers – may have specific limitations

Packaging, markings, labels, documentation

China is a subject all its own –

• Regional and very fragmented

• May require IEC 62281

• Can vary by carrier within each region

Lithium Ion batteries shipped alone are forbidden on passenger aircraft


What is required?

Shipping

Mandatory



• UN 38.3

• IEC 62281

• India

• Korea

• Thailand

• Japan

• European Union

• USA/Canada

• Russia

• China??

• Taiwan


Mandatory

In country testing required Yes

Standard applied IS 16046 (based on IEC 62133) Second edition

Component cell compliance method

Separate Registration required prior to battery report

In country representative required For registration process

Mark required Yes

Samples and timeline 25 batteries – up to 5 months

Other notes Factory based – no factory inspectionAuthorized India Representative required

India Registration

Test and Issue Report

Submit to BIS for

Registration

Add additional models –

renew 2 years


India Registration


• Every factory/manufacturer/brand name is a new submittal (manufacturer=factory=applicant)

• Very detailed factory information required

• Branding matters

• Limits on allowed models by similarity without testing

• AIR – Authorized India Rep – Factory Rep or Brand Holder Rep

• Limited test labs in country – limited battery knowledge

• EVER CHANGING…

• Communication is difficult


Mandatory


Standard applied KC 62133 (based on IEC 62133 second edition)

Cell compliance method CBseparate certification or testing with battery

In country representative required No

Mark required Yes

Samples and timeline 21 batteries 10-12 weeks

Other notes No factory inspectionDetailed Korean marking requirements

South Korean KC Certification

Complete in country testing

Submit report for certification


South Korean KC Certification


• Label will need specific details in Korean language

– Product name

– Model name

– Designation (IEC designation)

– Nominal voltage

– Rated Capacity

– Manufacturer (factory)

– Customer service number

– Country of manufacture

• Shipping units for testing can be tricky

• Alternate factories = new submittal

• CB reports are accepted to reduce testing, but not cost

• Changes are coming


Mandatory


Standard applied TIS 2217-2548 (based on IEC 62133:2002)

Cell compliance method N/A

In country representative required Yes – can be provided by test lab

Mark required Yes

Samples and timeline 31 batteries 10-12 weeks

Other notes Factory inspection requiredIn country representative is required

Thailand Certification

Complete factory audit

Complete in country testing

Grant Certification


Thailand Certification


• Factory inspection – Required prior to any work starting on testing typically

– Expensive – 1 week with up to 4 people traveling from Asia for the inspection

• Shipping of batteries into Thailand for certification will require coordination with local authority

• VERY slow process


Mandatory

In country testing required No – self certification with registration

Standard applied Revision of the Ministerial Ordinance for Determining Technical Standards for Electrical Appliances (Lithium Ion Secondary Batteries)”

Cell compliance method C of C or tested with battery

In country representative required Registration by in country rep required

Mark required Yes

Samples and timeline 33 batteries, 1 host device, 6-8 weeks

Other notes Not harmonized with IEC 62133 even with national deviationsNot required for embedded batteries or <400Wh/l

Japan (DENAN) Certification

Complete testing and report

In country importer or end

device registration

No renewal period or expiration


Japan (DENAN) Certification


• Label will need specific details in Japanese language (can be applied in country by importer)– Importer in Japan

– Electrical ratings

– Label can be affixed in Japan – not a customs clearance concern

• Japanese deviations in the IEC standard do not equal compliance with DENAN regulations.


Mandatory

In country testing required

No – self declared

Standard applied Typically EN 62133 (can include end device specific requirement)

Cell compliance method EN 62133

Mark required Yes

Samples and timeline 21 samples, 6 weeks

Other notes End device standards may have additional requirementsNational Deviations for France and Switzerland required at the cell level

European Union

Complete testing

Generate Declaration of

Compliance


European Union


• Cell level - Forced Internal Short Circuit (FISC)– France

– Switzerland

• Other directives/standard may need to be applied– Battery Directive (chemical content, recycling, capacity rating)

– EMC directive (smart batteries)

– End device directives may apply to the component cell or battery

– End device standards may have additional battery requirements (ITE, power tools)


Mandatory Summary

India South Korea

ThailandJapan

European Union


Shipping

Mandatory



• UN 38.3

• IEC 62281

• India

• Korea

• Thailand

• Japan

• European Union

• USA/Canada

• Russia

• China??

• Taiwan

What is required?


Voluntary or end device driven

Standard applied End device determined – typically UL 2054 or UL /CSA 62133

Cell compliance method UL 1642 or UL 62133

Mark required Varies

Samples and timeline UL 2054 – 55 samples, 12 weeksUL 62133 – 21 samples, 6 weeks

Other notes End device standards may have additional requirements

United States and Canada


United States and Canada

Things to be aware of:– UL 2054 versus UL 62133

UL 2054• Well established standard • No Canadian equivalent (60950)• Referenced in many US device

standards • VERY stringent standard

• Faulting of batteries• Run below trip point of the

batteries• Cells tested to UL 1642• Expensive and potentially long

process• 12+ weeks in some cases

UL 62133• Very new standard (01-2015)• Referenced in some US standards

(ITE and ProAV)• Harmonized with IEC 62133:2012• Cells tested to UL 1642 or UL 62133• Batteries tested as received• Limited test program• Less expensive• Shorter process• Fewer samples required


Voluntary Required by large retail chains and most companies doing business in Russia

In country testing required No

Standard applied GOST 62133-2004 (based on IEC 62133:2002)

Component Cell compliance method

N/A

In country representative required If battery will be imported and sold stand alone in Russia

Mark required Yes

Samples and timeline No samples – 2 weeks to 1 month

Other notes Based on HS code

Russian GOST Certification

Provide CB report

Provide in country agent

and agreement if required

1 or 3 year certificate can

be issued


Russian GOST Certification


• Russia typically works like a normal CB Scheme certification

• If you are shipping a stand alone battery into Russia, you will need evidence of in country importer with a signed agreement

• Safety standard based – EAC certificate and mark covers Russia, Belarus and Kazakhstan, but currently is end device specific and does not include batteries as a covered product.

• Medical devices must be registered in Russia and GOST on the battery can support this registration.


China

• GB 31241 – Mandatory standard as of August 15, 2015

• Enforcement – Li ion batteries not on CCC Mandatory product list

Option Mark Validity

Type Testing only No Mark applied to product, only CQC certificate

Not defined, potential to be rejected at end device review

China Entrusted Test Report GB 31241-2014

No CQC Mark, No CQC certificate, test report only

1 year

Type testing + initial factory inspection + follow-up services

CQC mark and CQC certificate No expiration


China


– New shipping regulations – very difficult to ship to into China

• FedEx and UPS will not ship Fully Regulated DG into Mainland China

– All FedEx and UPS shipments of batteries alone are Fully Regulated DG as of January 1, 2017

• Coordinated effort with extensive documentation

– Specific marking requirements

• Product name and model

• Rated capacity , limited charge voltage

• Positive electrode and negative electrode, represented by “Positive, Negative”, “+, -” symbol or different colors (such as red and black)

• Manufacturer or brand

• Warnings – can be on smallest unit box

– EVERTHING MUST MATCH EXACTLY

– Standard is totally different from any other standard globally

– New factory = new submittal


End device driven 3C use Li Ion batteries and Power Banks

Standard applied 3C – CNS 15364 (IEC 62133) and CNS14857-2Power banks - CNS 14336-1 (IEC 60950-1 2nd) and CNS-13438 (CISPR 22:2005)

Cell compliance method Tested with batteries or separate certification

Mark required YES

Samples and timeline 16 batteries/50 cells/27 power banks 6-8 weeks

Other notes 3 year renewalNeed in country rep

Taiwan - BSMI


Taiwan


Includes capacity verifications

Must use an in country approved lab

3C – Computer, communication and consumer electronics

Product code based 3C 8507.80.00.10.3, 8507.80.00.90.6; power banks 8504.40.20.00.3, 8504.40.91.00.7, 8504.40.94.00.4, 8504.40.99.90.0, 8507.80.00.10.3, 8507.80.00.90.6

RPC mark (registration of product certification)

CB not accepted

No factory inspection


Other Considerations

USA – CTIA

• cellular use with Verizon and AT&T

Brazil – ANATEL

• Cellular applications

Australia and New Zealand - RCM

• Currently only EMC based

EAC Mark of Conformity (Russia, Kazakhstan and Belarus)

• Includes devices currently


IEC 62133 New Edition

IEC 62133-1 – Nickel based cells and batteries,

IEC 62133-2 – Li ion cells and batteries

• New edition set to be released in March 2017– Nickel – not much

– Li ion –

• Put back in some mechanical testing

• Added potential for single fault testing (should statements)

– Could lead to further country specific deviations/separate non-harmonized standards

Harmonization– UL 62133 and CSA/CAN E62133 – soon to be harmonized into UL/CSA

62133

– UL acceptance of either UL 1642 or UL 62133 Recognized cells for UL 62133 certification of a battery


End device driven Only required for batteries used in laptops, tablets and mobile phones – expanding in the near future to other communication device batteries

Standard applied IEC 62133:2012IEC 61960

Cell compliance method Cell level testing required, including FISC

Mark required No

Samples and timeline TBD

Other notes Currently appears that a CB report to IEC 62133 for the battery pack would be accepted

Vietnam – MIC – October 1, 2017


Vietnam


Requirements apply to the devices that contain the battery, not the stand alone battery

Stand alone battery certification cannot be obtained – however, seems that CB reports will be accepted

CB reports must be less than 2 years old

Existing devices are grandfathered until their expiration date


Mandatory Product Battery

Standard applied IEC 62133:2012IEC 61960:2011

Cell compliance method TBD

Mark required Yes

Samples and timeline TBD

Other notes Factory audit required – samples for testing gathered at factory auditIn country testing and representation required

Indonesia – SNI – October 1, 2017


Indonesia


• Still in socialization process

• Normally there is a 6 month implementation period

• Customs verification of compliance most likely with a Letter of Admission of Goods (SPB) that will contain a Registration Number Item (PIB)

• Letter of Admission will need to be held by the importer to address any questions at customs – SNI Mark on products

• Overseas companies must be represented by an Indonesian company to obtain SNI

• Certificate is specific to importer(s)

• Brand registration is required

• Factory audit required (samples for testing collected at FA)


What else is changing

• Korea is implementing stronger requirements with additional testing, factory inspections and cell verification requirements for cell phone, tablet and mobile computing devices.– Factory inspections expected

• Shipping regulations – packaging requirements are getting tougher – it is getting harder to ship Lithium ion batteries


Thank you!

Energy Assurance LLC

www.Energy-Assurance.com

Cindy Millsaps

[email protected]

http://www.energy-assurance.com/

mailto:[email protected]

Documents

International Compliance for Portable Device Batteries ...cii-resource.com/cet/FBC-05-04/Presentations/BTS/Millsaps_Cynthia.pdfBatteries –What the heck do I have to do to ship my