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2020 Vision or Still Blurry for Lithium Battery Shippers?

The title says it all, can you see clearly when you ship lithium batteries, or are the waters still a little murky? If it is the former rather than the latter for you, that may change as Amazon has announced new global FBA requirements for all lithium batteries and products which contain lithium batteries. A Lithium Battery Test Summary will now need to be uploaded to Amazon, starting this past 1st of January 2020. This new rule will affect those who sell a variety of products, from watches to smartphones to toys. This type of change is not only exclusive to Amazon, as IATA and IMDG Code will now also be enforcing a new regulation that requires the test summary for the lithium battery/cells to be made available throughout the entire distribution network. 

What is the Test?

Lithium cells and batteries that are manufactured after June 30, 2003, and equipment powered by those cells and batteries have to be tested in accordance with the UN Manual of Test and Criteria Part III, Section 38.3. If the testing passes, the test facility provides a summary certificate to the manufacturer that confirms that the cells or batteries meet an international standard and can be shipped around the world in accordance with the appropriate regulations. The test standard includes eight tests total: Altitude Simulation; Thermal Test; Vibration; Shock; External Short Circuit; Impact; Overcharge; and Forced Discharge.

Why?

Amazon simply fell in line with what The United Nations’ Committee of Experts decided by introducing a new requirement which requires manufacturers and distributors of cells or batteries to make the test summary available for their products. This new regulation appeared in the ICAO Technical Instructions and, therefore, the 60th edition of the IATA Regulations (air) as well as in Amendment 38/18 of the IMDG Code (sea). However, the regulators provided a derogation until the end of 2019, so the implications of the rule have been largely ignored throughout last year. Both IATA and IMDG have now begun enforcing this regulation as of January 1st, 2020. 

Regulatory Complications 

Now the complicated part of this is that both Transport Canada and PHMSA haven’t officially added this as a requirement yet, (at least at the time this blog was written, see HM-215O) but still can theoretically enforce ICAO and IMDG regulations. But to be technical (and we’re always technical in regulatory), anyone who ships lithium cells or batteries and/or whose customers may ship them by air or sea would be required to have the test summary available. The other question here is what does “available” actually mean? Well, the wording of the regulation is pretty vague as it just states manufacturers and distributors must make the test summary “available”. Some are interpreting this as meaning the actual document must accompany the shipment while others may look at this differently and not include it in physical form, and as you can imagine this can potentially cause confusion and stop or slow down shipments of lithium batteries. Well, the easy answer is that if the test summary is requested by someone within the supply chain, for example, forwarders, regulators, etc., it must be available to obtain, which may mean physically or electronically (website for example). Here at ICC The Compliance Center we offer a training course that can assist you when shipping lithium batteries ground, sea, or by air. For more information call 1-888-977-4834 or visit our website at www.thecompliancecenter.com

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