Hi Mike, Secondary batteries, but small enough that I keep thinking they'll qualify for an exception.AA-size, with a small, built-in protective circuit, 3.6V, 12 W-hr. I do see 173.185, (c)(1) "Size limit" but it's not clear to what to clauses a < 20 W-hr cell earns exception, nor if two 12W-hr cells next to each other invalidate any or all.I can see with air shipment, with 20 of our units, there's more lithium, but each meets 173.185, (b) "Packaging" in spades. We're talking ~ 7g of Lithium per charger. Puzzled, after blowing way too many hours on this.... thanks, all. Brian
---------- Original Message ---------- From: MIKE SHERMAN <0000347e8d192c85-dmarc-requ...@listserv.ieee.org> To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Lithium battery [ in equipment ] Requirements Date: Tue, 21 Jan 2025 16:57:05 -0600 <!doctype html> Brian -- It's unclear to me from your questions whether these are primary (non-rechargeable) or secondary (rechargeable) batteries that you are using. In my experience, this distinction can have a huge impact the risk and therefore on which regulations apply and what your customers might expect. Mike ShermanSherman PSC LLCOn 01/21/2025 2:29 PM CST Brian Gregory <brian_greg...@netzero.net> wrote: 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 This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to EMC-PSTC@LISTSERV.IEEE.ORG All emc-pstc postings are archived and searchable on the web at: https://www.mail-archive.com/emc-pstc@listserv.ieee.org/ Website: https://ewh.ieee.org/soc/pses/ Instructions: https://ewh.ieee.org/soc/pses/list.html (including how to unsubscribe) List rules: https://ewh.ieee.org/soc/pses/listrules.html For help, send mail to the list administrators: Mike Sherman at: msherma...@comcast.net Rick Linford at: linf...@ieee.org For policy questions, send mail to: Jim Bacher at: j.bac...@ieee.org To unsubscribe from the EMC-PSTC list, click the following link: https://listserv.ieee.org/cgi-bin/wa?SUBED1=EMC-PSTC&A=1 This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to EMC-PSTC@LISTSERV.IEEE.ORG All emc-pstc postings are archived and searchable on the web at: https://www.mail-archive.com/emc-pstc@listserv.ieee.org/ Website: https://ewh.ieee.org/soc/pses/ Instructions: https://ewh.ieee.org/soc/pses/list.html (including how to unsubscribe) List rules: https://ewh.ieee.org/soc/pses/listrules.html For help, send mail to the list administrators: Mike Sherman at: msherma...@comcast.net Rick Linford at: linf...@ieee.org For policy questions, send mail to: Jim Bacher at: j.bac...@ieee.org To unsubscribe from the EMC-PSTC list, click the following link: https://listserv.ieee.org/cgi-bin/wa?SUBED1=EMC-PSTC&A=1 - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to EMC-PSTC@LISTSERV.IEEE.ORG All emc-pstc postings are archived and searchable on the web at: https://www.mail-archive.com/emc-pstc@listserv.ieee.org/ Website: https://ewh.ieee.org/soc/pses/ Instructions: https://ewh.ieee.org/soc/pses/list.html (including how to unsubscribe) List rules: https://pses.ieee.org/wp-content/uploads/2024/12/EM-PSTC-List-Rules.pdf For help, send mail to the list administrators: Mike Sherman at: msherma...@comcast.net Rick Linford at: linf...@ieee.org For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> _________________________________________________ To unsubscribe from the EMC-PSTC list, click the following link: https://listserv.ieee.org/cgi-bin/wa?SUBED1=EMC-PSTC&A=1
