Hello Colleagues, We're packing two AA-sized (12 W-hr) Li-On batteries in our latest EV Charger for brains backup. Industrial partners have been flagging certain regulations (we have some very large, very conservative partners). The charger is for N. American residential applications, perhaps Mexico in the near future. Summarizing my findings after review of CFR Title 49, ยง 173.185 for shipping of hazardous materials. 1. 173.185, (a)(1) - all batteries must be proven proven to meet the criteria in, sub-section 38.3 of the UN Manual of Tests and Criteria (rev. 3, Amm 1). https://unece.org/fileadmin/DAM/trans/danger/publi/manual/Manual%20Rev5%20Section%2038-3.pdf 2. 173.185, (c)(1) Size limit exception - applies to “smaller” batteries where Watt-hour (Wh) rating may not exceed 20 Wh 3. 173.185, (c)(4) - air shipment packaging (and/or waybill) must be marked with the appropriate label/sticker and marked “UN 3481” ”[Lithium ion cells packaged in equipment] 4. The charger will comply with 173.185, (b) “Packaging” requirements by virtue of the cells being mounted on a PCB, which is in a metal enclosure. Here are my questions for any in the know:- per items 2. and 4., the charger itself does not need the Li-On label.- even given #2, it's a good idea to have the manufacturer test/certify their cells to 38.3, but is it required? thanks, and hope to see you at ISPCE in May! Colorado Brian
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