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://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
