China lithium battery transportation requirements must be tested in-country by
authorized labs.
Sent from my iPhone
Peter S. Merguerian
pe...@goglobalcompliance.com
Go Global Compliance Inc.
www.goglobalcompliance.com
(408) 931-3303
On Nov 9, 2012, at 11:31 AM, Crane, Lauren lauren.cr...@kla-tencor.com
wrote:
Does anyone know what requirements apply to the transportation by air in
China of lithium button cells installed in equipment ?
I have one Chinese regulation à “Administrative Provisions on Transport of
Dangerous Goods by the Civil Aviation of China” (“中国民用航空危险品运输管理规定”), which
defines dangerous goods as
“articles or substances which possess danger to the health, safety, property
or environment, specified in the listing of dangerous goods of the Technical
Instructions, and classified pursuant to the Technical Instructions.
Technical Instructions refers to the current Technical Instructions for the
Safe Transport of Dangerous Goods by Air (Doc9284-AN/905) promulgated by the
International Civil Aviation Organization, including the supplements and any
appendix thereto approved and published by decision of the Council of the
International Civil Aviation Organization.”
According to the 2011 version of ICAO Doc 9284-AN/905 button cell batteries
in equipment (including on circuit boards) are excluded from the general
lithium battery transportation requirements in the document. Particularly
Packing Instruction 967 and 970.
Which seems to imply they are out of scope also of the Chinese regulation.
However, there is also the Chinese standard MH/T 1020-2009, “Standard for
transport of 1ithium batteries by air” (组电池航空运输规范) which does not acknowledge
any button cell exclusions.
Any ideas?
If in scope, the requirement would be for the button cell to be certified to
UN38.3. Is it even possible to buy a button cell these days that does not
meet this standard?
Regards,
Lauren Crane
KLA-Tencor
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