What You Need to Know About the New Lithium Battery Test Summary

The Lithium Battery Test Summary

If you ship batteries or products containing batteries, you’re likely aware of new regulations that took effect this year regarding lithium battery test summaries. Like many new policies, there can be a period of misinterpretation and confusion.

But there’s good news: CHEMTREC can make the compliance much easier for shipping or handling of these materials.

Let’s dive into exactly what these new regulations are and what they may mean for you.

What do we know about the new lithium battery regulations?

Organizations including IATA, IMO, IMDG Code, ICAO Technical Instructions, and potentially other national and international dangerous goods regulations have mandated manufacturers and distributors of lithium cells, batteries, and equipment powered by lithium cells and batteries make available a test summary as specified in the UN Manual of Tests and Criteria, Sixth Revised Edition, Amend 1, Part III, sub-section 38.3, paragraph 38.3.5.

These summaries confirm the batteries or cells have been tested to meet the specified international safety requirements. The requirement applies to all lithium batteries or cells manufactured as of July 1, 2003, and is applicable to both cells and batteries, including those which are contained within a product.

These regulations don’t introduce any new testing. Fortunately, the new regulations only require providing information regarding testing already conducted by the manufacturer of the lithium battery or cell.

Furthermore, this information isn’t required to be attached to or even shipped with the batteries, but must only be available to anyone who requests it. The requirement applies to all lithium batteries or cells manufactured as of July 1, 2003, including those which are contained within a product.

What is a lithium battery test summary?

For safety reasons, lithium batteries are subject to a series of design tests mandated by the UN (sub-section 38.3 of the UN Manual of Tests and Criteria). At this time, these regulations don’t introduce any new testing that must be done.

The new regulations are only about providing information regarding the testing already conducted by the manufacturer of lithium batteries or cells. The revised addition to the UN manual 38.3.5 now requires lithium battery test reports to be made available in the form of a test summary available to the supply chain. These summaries confirm the batteries have been tested to meet the referenced safety requirements.

What information is required in the lithium battery test summary?

One of the most important aspects of the test summary requirements is that the summaries be standardized and include the same relevant information. Per PHMSA guidance, a proper test summary must include:

• Name of cell, battery or product manufacturer, as applicable. Cell, battery, or product manufacturer’s contact information to include address, phone number, email address and website for more information.
• Name of the test laboratory to include address, phone number, email address and website for more information.
• A unique test report identification number.
• Date of test report.
• Description of cell or battery to include at a minimum:
  • Indicate if a lithium ion or lithium metal cell or battery.
  • Mass of cell or battery.
  • Watt-hour rating or lithium content.
  • Physical description of the cell/battery.
  • Model numbers.
• List of tests conducted and results (i.e., pass or fail).
• Reference to assembled battery testing requirements, if applicable (i.e., 38.3.3 (f) and 38.3.3(g)).
• Signature with name and title of signatory as an indication of the validity of information provided.

*For more detailed analysis and guidance concerning the lithium battery test summary requirements, you can review IATA's official document.

What does "Make Available" mean?

This information isn’t required to be attached to or even shipped with the batteries, but must only be available to anyone who requests it.

It is acceptable for the provider to require the requestor to obtain a document electronically from a provider's website. The provider must ensure that the cell/battery/product has appropriate identifiers to align to the test summary.¹

What are the challenges with complying? 

As lithium battery regulations become more complex, the supply chain will need more information about the batteries and cells they handle in order to maintain compliance.

These challenges include:

• Complying with the requirement with respect to when equipment contains cells or batteries from other manufacturers.
• Implementation of an appropriate system for complying with the new requirement.
• Difficulty validating or obtaining a test summary from some cell or battery manufacturers.

How can I minimize the regulatory burden?

As lithium battery regulations become more complex, shippers in the supply chain need more information about the batteries they transport in order to maintain compliance. CHEMTREC has developed a lithium battery test summary document management system, CRITERION™, to assist with regulatory compliance.

CRITERION acts as a central source for test summary documents and provides customers with a full range of useful tools. A snapshot of these resources include:

• CHEMTREC will provide a secure log-in to your dedicated company library that will allow you to create, upload, or download test summary documents relevant to your company.
• Customers may request CHEMTREC to source test summary documents that are not entered into the system.
• CHEMTREC can respond to test summary requests as a 3rd party provider minimizing corporate resource burdens.
• CHEMTREC can provide an external link that can be provided to subscribers and added to a company intranet or public website.
• CHEMTREC has the ability to customize this service to meet your company needs.

For additional information on how CHEMTREC’s CRITERION lithium battery test summary document management system can work for you, contact us today.

Where can I find more information on the shipping and handling of lithium batteries?

CHEMTREC also offers training that meets the U.S. DOT training requirements for individuals who perform or direct the functions of packaging, marking, labeling, or loading packages containing lithium batteries for shipment by highway, rail, air or vessel.

Check out our Lithium Battery Training Course today to learn more.

1 “New UN Requirement For Lithium Battery Test Summaries.” U.S. Department of Transportation, Pipeline and Hazardous Materials Safety Administration, https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/training/hazmat/71126/us-dot-testsummarybrochure.pdf