Making sense of complex global lithium-ion

battery regulations
Ilyas Ayub - June 19, 2017

Unfortunately, lithium batteries have made major headlines in past two decades regarding safety.
Many of these incidents have caused billions of dollars in brand and property damage. Some
incidents have also caused deaths and severe injuries. Some of the most notable incidents include
the following:

● UPS Cargo Airline Flight 6 crashed and killed both pilots in 2010; the root cause was traced to
lithium-ion batteries in the cargo hold.
● Sony batteries used primarily in Dell laptops started catching fire in 2006; the root cause was
traced to bad impurities within the cell causing a short (over 9 million batteries were recalled)
● Boeing Dreamliners were grounded due to battery fires in 2013; the root cause was an internal
short in the cell (over $600 million of damage for Boeing)
● Samsung Note 7 batteries started catching fire in 2016; multiple root causes traced to cell
manufacturing and multiple injuries reported. Samsung took a loss of over $5 billion due to the
recall.

Figure 1 UPS Flight 6 crashed due to lithium-ion batteries (Image courtesy of The Aviation Herald)
These examples just highlight some of the incidents with lithium-ion batteries and the potential
damage it could do. Due to its volatile nature, many organizations/countries have put regulations in
place to ensure the batteries they are getting are safe. We will look into which battery regulations
your battery may need and what they entail.

Which regulations do you need?

In order to determine which regulations your rechargeable lithium ion battery solution may need,
you need to ask yourself some questions. Are you going be shipping batteries by themselves? 99% of
the time, the answer will be yes. And if yes, then you will need to perform UN 38.3 testing (see
transportation regulations section.) Next, are you going to be shipping battery products into Europe
(EU)? If yes, then you will need to do IEC 62133 (see international regulations). Is your battery going
to be used in a device that complies to a UL end device spec that calls for the battery to be UL
certified? If yes, then you will need to do UL2054 (see US safety regulations). Is your battery going
to be shipped to China, Russia, Thailand, India, Korea, or Japan? If yes, then additional testing is
needed and is specific to the country (see other regulations).

Transportation regulations

The UN has listed lithium-ion batteries as a dangerous good and has provided recommendations on
how to transport it. Section 38.3 of the UN Manual Transport of Dangerous Goods provides a
detailed description of which lithium ion batteries qualify and how to test to insure it is safe for
transport. US DOT, ICAO, and IATA have made it mandatory for the batteries to be tested via section
38.3. Table 1 below lists the testing the battery and/or cells need to go through before they are
acceptable to be transported.

Table 1 Complete list of UN 38.3 tests

Test Name Description Pass Criteria Cells or

Batteries
T1: Altitude Simulate air transport under low- No leakage, no Cells and
pressure conditions. The samples venting, no rupture, batteries are
are subjected to 11.6 kPa or less no fire. Open circuit subjected to this
for 6 hours or more at room temp. voltage (OCV) not less test.
than 90% before
testing.
T2: Thermal Test Simulates the rapid and extreme No leakage, no Cells and
temperature changes during venting, no rupture, batteries are
transport. 10 cycles of oscillating no fire. Open circuit subjected to this
temperatures between −40C to voltage (OCV) not less test.
72C. than 90% before
testing.
T3: Vibration Simulates vibration during No leakage, no Cells and
Test transportation. Up to 8G from 7Hz venting, no rupture, batteries are
to 200Hz no fire. Open circuit subjected to this
voltage (OCV) not less test.
than 90% before
testing.
T4: Shock Test Simulates shock impacts during No leakage, no Cells and
shipping. Subjected to total of 18 venting, no rupture, batteries are
half-sine shock up to 150G in no fire. Open circuit subjected to this
positive and negative direction and voltage (OCV) not less test.
all 3 axes. than 90% before
testing.
 T5: Short Circuit Simulates short circuit External case Cells and
Test experienced during transport. A temperature shall not batteries are
short of less than .1 ohm is applied be above 170C. No subjected to this
at 55C. fire, no rupture, and test.
no disassembly within
6 hours after the test.
T6: Impact Test Simulates an impact during External case Only cells are
(cylindrical cells shipping. A 9.1Kg bar is dropped temperature shall not subjected to this
=> 18 mm onto the cell from 61 cm be above 170C. No test.
diameter) fire and no
disassembly within 6
hours after the test.
T6: Crush Test Simulates crushing during External case Only cells are
(prismatic, shipping. Crush the cell at temperature shall not subjected to this
pouch, 1.5cm/s until force reaches 13+/− be above 170C. No test.
coin/button and .78 kN or voltage drops by 100mV fire and no
cylindrical cells or cells deforms more than 50% of disassembly within 6
< 18mm its original thickness. hours after the test.
diameter)
T7: Overcharge Simulates the ability for battery to No fire, do Only batteries
withstand an overcharge condition disassembly within 7 are subjected to
during shipping. Overcharge the days after the test. this test.
battery pack 2× max continuous
charging current for 24 hours.
T8: Forced Simulates incorrect installation. No fire, no Only cells are
Discharged cell is connected to 12V power disassembly within 7 subjected to this
supply and current limited to days after the test. test.
manufacturer’s specified
maximum discharge current.

The testing can be self-certified. A test report with detailed test results data needs to be created.

US safety regulations
US safety regulations

In the US, there are two major battery standards that deal with cells and small portable batteries:
UL1642 and UL2054. UL1642 deals with individual cells while UL2054 is for small rechargeable
battery packs. UL2054 requires the cells to be certified UL1642. Although UL2054 is not a
mandated test for products shipped into the US, it is often mandated by US end device standards
and it is a pretty severe test as it requires a single fault to be applied on the battery pack. The fault
is applied to a non-UL rated component. This forces the designs to have redundant protection to
pass several of the UL2054 tests.

The UL2054 standard includes electrical and mechanical, and requires construction assembly review
ensuring the battery is built per the standard such as type of plastic, wall thickness, amount of non-
UL qualified material used, etc. Table 2 lists out the UL2054 testing.

Table 2 UL2054 testing

UL 2054 Testing
Short-Circuit Test (20 and 55°C)
Abnormal Charging Test
Abusive Overcharge Test
Forced-Discharge Test
 Limited Power Source Test
Component / Surface Temperature Test
Upper limit charging voltage
250N Steady Force Test
Mold Stress Relief Test
Drop Impact Test
Enclosure Flammability
Construction Assembly

There are two options with UL testing: listed and recognized. Listed ensures that a product has
passed all the testing as required and was built according to the specification. Recognized is meant
for battery packs installed in systems at the factory and not in the field. They typically have not
passed all the testing requirements, such as the limited power source test, nor met all the
construction requirements. An example of a UL recognized battery would be a shrink-wrapped
battery installed in the device that is not user replaceable.

International safety regulations

The European Union and other countries have accepted IEC62133 as their requirement for batteries
to be used in their countries. The IEC62133 is a much more straightforward specification. It accepts
UN38.3 testing as an acceptable method of compliance. Table 3 lists out the battery testing that is
conducted.

Table 3 IEC 62133 testing

IEC 62133 2nd Edition Tests

Molded Case Stress at Elevated Temperatures
External Short Circuit
Free Fall
Over-Charging
UN 38.3 Testing

As shown above, the IEC 62133 has half the amount of tests the UL2054 calls out and is much easier
to pass as it does not require the battery to have a single fault.

Other regulations

There are several countries that do not accept UL2054 or IEC62133 certifications as acceptable for
batteries shipped into their countries; they have their own standards. India requires testing to done
in their country based on the IS16046 spec, which is similar to IEC 62133. But they will not accept
compliance to IEC62133 to be enough. The batteries need to obtain BIS (Bureau of Indian
Standards) certification. Maneuvering the BIS process is extremely tricky especially when trying to
find a battery testing lab in India and coordinating the testing. It can take six months or more to
obtain certification. It is better to have a 3rd party lab or battery manufacture coordinate the logistics
of obtaining BIS.

Russia GOST certification is much easier to obtain. It does not require in-country testing.
Compliance to IEC62133 should be suffice to obtain certificate from Russia and lead time is about 1
month.

Korea requires in-country testing to obtain the KC certification. The testing is based on the IEC
62133 standard and requires around three months to obtain certification.

Thailand has another tricky process to obtain the TISI (Thai Industrial Standards Institute)
certification. It requires in-country testing based on the TIS 2217-2548 spec which is again similar to
IEC62133. The process can take more than six months. TISI also requires a factory inspection.

Japan allows self-certification with in-country registration. The testing is based on “Revision of the
Ministerial Ordinance for Determining Technical Standards for Electrical Appliances (Lithium Ion
Secondary Batteries)”.

China requires the battery to be tested and comply to the GB 31241-2014 spec. This spec is different
from any other standard, so careful review of the spec is required when designing for China.

Taiwan also requires testing to their standards by a BSMI (Bureau of Standards, Metrology and
Inspection) certified lab.

Markings

Most of these certifications require specific marking to be applied on the label. Table 4 shows the
marking that needs to be applied and if its required.

Table 4 List of regulatory markings

Test Name Marking Required on

Product
UN 38.3 Not Required

UL – Listed Required

UL – Recognized Required

EU Required

India Required

Russia Required
 Thailand Required

Japan Required

China Not Required

Taiwan Required

Korea Required

Summary

Although battery regulations may seem complicated at first, it can be simplified by asking yourself
where is this battery going to be used and in which country. By understanding that, we can
determine which regulations apply. Each regulation is a little different, but they all try to test the
safety of the battery if the battery is used incorrectly. Inventus Power has great relationship with all
the agency bodies and can ensure that your product gets designed to pass the regulations and then
also ensure that it gets certified in a timely manner.

Also see:

● Proper Lithium-Ion battery charging and safety

● Introduction to lithium-ion rechargeable battery design
● California passes new regulations for battery charging systems
● Dreamlining Boeing and batteries
● Special Report: Beyond the exploding battery