Brian, I do not remember having to put labels on a product. Just detailing
the batteries in the manual. Depending on the product we had primary or
secondary cells in the products.
A safety agency won't address the shipping boxes, which will need labels
and proper documents. Most shipping companies divirt some amount of cargo
through passenger airplanes. That is one of the reasons for the shipping
boxes to be labeled.
Back when the issue arose the FAA paid me a visit to make sure we
understood the shipping requirements. Shortly after that I had to educate
one of shipping companies on the requirements.
I haven't had to deal with batteries for over 10 years. So I could be out
of date.
Jim Bacher, WB8VSU
[email protected]
JBRC Consulting LLC
Product EMC & Regulatory Consultant
https://www.trc.guru/ business email:[email protected]
IEEE Life Senior Member
On January 21, 2025 11:05:11 PM Brian Gregory <[email protected]>
wrote:
Hi Jim,
Yes, we're getting UL approval for the product, but these cells are too
small to qualify for UL 1642, and we kind of need to know (about packaging,
labeling) before UL will have time to Opine.
We're pinging the battery vendor for UN 38.3 testing, just to be sure. The
quote was quite respectable.
Brian
---------- Original Message ----------
From: Jim Bacher <[email protected]>
To: [email protected]
Subject: Re: [PSES] Lithium battery [ in equipment ] Requirements
Date: Tue, 21 Jan 2025 18:31:56 -0500
Brian, if you will be getting a NRTL on the final product the agency will
require the batteries to have a 3rd party test report regardless of any
regulation requirements. It’s highly likely the battery company already has
a third part test report available. Just ask them for it.
Jim Bacher, WB8VSU
[email protected] or [email protected]
JBRC Consulting LLC
Product EMC & Regulatory Consultant
https://www.trc.guru/ email:[email protected]
IEEE Life Senior Member
From: Brian Gregory <[email protected]>
Sent: Tuesday, January 21, 2025 3:30 PM
To: [email protected]
Subject: [PSES] Lithium battery [ in equipment ] Requirements
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, � 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
[email protected]
All emc-pstc postings are archived and searchable on the web at:
https://www.mail-archive.com/[email protected]/
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: [email protected]
Rick Linford at: [email protected]
For policy questions, send mail to:
Jim Bacher at: [email protected]
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
[email protected]
All emc-pstc postings are archived and searchable on the web at:
https://www.mail-archive.com/[email protected]/
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: [email protected]
Rick Linford at: [email protected]
For policy questions, send mail to:
Jim Bacher at: [email protected]
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
[email protected]
All emc-pstc postings are archived and searchable on the web at:
https://www.mail-archive.com/[email protected]/
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: [email protected]
Rick Linford at: [email protected]
For policy questions, send mail to:
Jim Bacher at: [email protected]
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
[email protected]
All emc-pstc postings are archived and searchable on the web at:
https://www.mail-archive.com/[email protected]/
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: [email protected]
Rick Linford at: [email protected]
For policy questions, send mail to:
Jim Bacher: <[email protected]>
_________________________________________________
To unsubscribe from the EMC-PSTC list, click the following link:
https://listserv.ieee.org/cgi-bin/wa?SUBED1=EMC-PSTC&A=1
