Hi Brian,

UN 38.3 applies to batteries shipped in products, shipped with products, and 
shipped alone. In other words, all batteries. There aren't size exceptions that 
I am aware of with the exception of button/coin cells shipped installed in 
equipment. IATA has a good summary of air shipping requirements.
lithium-battery-guidance-document.pdf 
(iata.org)<https://www.iata.org/contentassets/05e6d8742b0047259bf3a700bc9d42b9/lithium-battery-guidance-document.pdf>

Best regards,
Ted Eckert
The opinions expressed are my own and do not necessarily reflect those of my 
employer, IATA, or the UN.
________________________________
From: Brian Gregory <brian_greg...@netzero.net>
Sent: Friday, September 13, 2024 11:00 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG <EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [EXTERNAL] [PSES] UL 38.3 and Li-On batteries

You don't often get email from brian_greg...@netzero.net. Learn why this is 
important<https://aka.ms/LearnAboutSenderIdentification>
 Hello fellow compliance colleagues,

Holy smokes but UL 38.3 is poorly written.

Can someone confirm that the scope only applies to batteries sold and shipped 
separately, and do not apply to those installed in an appliance-product?
Secondly, I can't find a size limit in the scope.  For instance, I can't 
believe it applies to lozenge batteries, but I cannot confirm that either.

Lastly, has anyone on this list heard of a "cold start battery" in the context 
of an residential or industrial appliance?
I'm familiar with automotive batteries that have cold-start or cranking 
ratings, and of utility-scale "grid" battery plants that can be black start 
qualified.  This is clearly different, yet I can't find bupkiss on it apart 
from mention by a buzzword-bombast who likes to throw fancy terms around, and 
now I'm stuck trying to justify or qualify the two 3V, 5 A-hr cells in our 
latest charger against this "cold start" metric.

thanks all,

Colorado Brian

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