Regulatory and Product Safety Updates

In what products are Lithium-Ion batteries commonly used?
Lithium-Ion batteries are rechargable batteries that are generally found in products such smart phones, laptops, scooters and E-bikes.

In what products are Lithium metal batteries commonly used?
Lithium metal batteries use lithium metal as an anode and are commonly used in items such as watches, car key fobs, remote controls and some toys.

What is the risk?
Lithium batteries present a safety risk to aviation because they use a positively charged electrode that contains oxygen and if the battery is exposed to excessive heat or pressure, it can catch fire. Currently there is more than one aviation incident a week related to lithium batteries in the USA alone. Additionally, the number of batteries in increasing rapidly across the globe as is the energy density in the batteries which is further increasing the risk.

What requirements must my product fulfil for air freighting?
It is important to talk to your shipping company or freight forwarder to make sure they are across the requirements for shipping of batteries in or with your products. They will need to be providing a shippers declaration in most instances. The key requirements you will need to be aware of are:

• All cells and batteries much be tested in accordance with the UN manual of tests and criteria Part III Subsection 38.3 (DGR 3.9.2.6) – and a test summary must be provided to your shipper
• For rechargable batteries, the maximum state of charge for the shipment must be 30%
• When Lithium batteries are not installed in the equipment they power, they must be carried on a cargo aircraft (or if they are over the weight restriction – see below)
• All terminals must be protected against short circuits and inner and outer packaging must be appropriate as per the Wh rating
• See the tables below for further requirements:

The above table is based on the provisions set out in the 2023-2024 Edition of the ICAO Technical Instructions for the Safe Transport of Dangerous Goods by Air (Technical Instructions) and the 65th Edition (2024) of the IATA Dangerous Goods Regulations (DGR): http://www.iata.org/dgr
 
The provisions of the DGR with respect to lithium batteries may also be found in the IATA lithium Battery Shipping Regulations (LBSR) 11th Edition: http://www.iata.org/lbsr                  

Refer to our article on the new EU battery regulation for additional battery related requirements.

What are the regulations key objectives?

• Global demand for batteries is increasing rapidly and the new Batteries Regulation’s objective is to minimise the environmental impact of this exponential growth by bringing forward the circular economy and zero pollution ambitions of the EU
• The aim is to make batteries sustainable throughout their entire life cycle – from the sourcing of materials to their collection, recycling and repurposing

Are all batteries included?

• The only exceptions are batteries for military, space, and nuclear purposes
• Rechargeable and non-rechargeable batteries; cells, battery modules, and battery systems (including stationary systems) are all included
• The regulation divides batteries into the following categories:
  • portable batteries - a battery that is sealed, weighs 5 kg or less, is not designed specifically for industrial use and doesn’t fit into one of the below categories
  • starting, lighting and ignition batteries (SLI batteries) – that can also be used for auxiliary or backup purposes in vehicles, other means of transport or machinery
  • light means of transport batteries (LMT batteries) - a battery that is sealed, weighs 25 kg or less and is specifically designed to provide electric power for the traction of wheeled vehicles but is not an EV battery
  • electric vehicle batteries (EV batteries)
  • industrial batteries – for industrial purposes or any other battery that weighs more than 5 kg and that is neither an electric vehicle battery, an LMT battery, nor an SLI battery

Who is responsible for complying with this regulation?

• The regulation specifies obligations of the product developer/manufacturer, importer and distributor of batteries and products containing batteries
  

What sort of battery requirements are included?

• Requirements include safety performance and durability requirements as well as requirements for the detachability and replaceability of portable batteries and Light Means Transport (LMT) batteries, substance restriction and labelling. Carbon footprinting and battery passports come later for some battery types.

What is the timeline for new requirements? (refer to the regulation for full details, this list is not exhaustive)

Need help understanding how this regulation applies to you as a product development business? Get in touch.

www.rbdevelopment.co.nz/connect