Buyer Beware


It wasn’t so long ago that branded stress balls, pens, key chains and coffee mugs were the promotional products of choice showcased in most promotional products catalogues and on websites. Serving the purpose of an inexpensive branding opportunity, these products came in unique designs and colorful options, and they were considered to be relatively practical.

Today’s technology has created new categories in the promotional products industry. Take, for example, lithium-ion power packs, also referred to as portable chargers or backup batteries, and similar multi-tasking devices such as hand warmers with built-in chargers. These new, high-tech devices provide an opportunity to differentiate yourself to potential clients and the competition by offering a unique, useful and attention-getting device for branding. However, these devices also have some shipping compliance concerns that need to be fully understood.

Lithium-Ion Power Packs

A lithium-ion power pack is a portable USB charging unit that contains one or more lithium-ion cells or batteries for storage of energy and device charging. For compliance in transportation you first have to know how this product is defined. Is it a battery, a charger, a battery contained in a case or a cell contained in equipment? The answer to this question was provided in a letter from the Portable Rechargeable Battery Association (PRBA) sent to the International Civil Aviation Organization (ICAO) Dangerous Goods Panel in April 2013. PRBA stated that lithium-ion power packs can be considered cells and batteries contained in equipment for shipping purposes. The IATA Dangerous Goods Panel has agreed so far, and this is how these products are being classified for shipping purposes. One additional clarification needed is on the difference between a cell and a battery. The terms are often used interchangeably by sellers and consumers but the definitions are different.

Cell Versus Battery

By definition, a cell is a single encased electrochemical unit with one positive and one negative electrode that exhibits a voltage differential across its two terminals. A cell cannot be fitted directly into an end device and work properly without additional circuitry or a means of connection or circuitry. Basically, a cell is a component of a battery.

A battery is defined as one or more cells electrically connected and fitted with a device necessary for its use. Devices may include an enclosure, safety circuit or connector. The primary function of a battery is to provide power to another piece of equipment.

These definitions alone reveal why there is so much confusion about how to classify power packs for shipping, and how to determine whether a product has a cell or a battery contained within it. The testing requirements under the UN Manual of Tests and Criteria (UN 38.3/T1-T8) are different for cells and batteries as well, so making this distinction is critical.

Buyer Beware: Obtain Transportation Documentation

When you order a lithium-ion power pack directly through a supplier, transportation compliance must be addressed. Lithium-ion rechargeable power packs have transportation regulations that vary by geography and mode of travel such as air, land or sea. It is your responsibility to ask your supplier for documentation that demonstrates the minimal lithium-ion transportation requirements have been met. For example, cells and batteries must be manufactured under a quality management system.To verify compliance, ask for a valid ISO certificate that includes the design and/or manufacture of lithium-ion batteries or cells, or of USB chargers. The ISO certificate should not be for something unrelated to your product such as a computer, MP3 player or electronic toys. The cells and batteries must also be compliant with the testing requirements of the UN Manual of Tests and Criteria and must be appropriately packaged, labeled and documented.

What makes power packs unique for transportation compliance is that they are defined as cells or batteries contained in equipment. This means they are subject to a much less stringent set of shipping requirements than if they were individual cells or batteries. The definition of each type must be fully understood to guarantee compliance at all levels.

The cost of not complying with transportation regulations is often greater to your bottom line than the cost of completing the necessary testing and verifying compliance with the appropriate packing instructions. Consequences of not complying can include civil and/or criminal penalties, product liability claims, state attorney general actions, consumer class actions, shareholder liabilities and reputation management issues.

Imagine this scenario: Your electronics client, a respected industry leader, takes your recommendation of a branded lithium-ion power pack for his giveaway at a large industry event. Thousands of these power packs, or chargers, are distributed to visitors at your client’s booth. The charger overheats and causes damage to someone’s carry-on bag. And that someone happens to work for your client’s No. 1 competitor.

Transportation Compliance Webinar

For a comprehensive presentation with detailed explanations on the regulations related to transportation requirements of lithium-ion battery packs, watch PPAI’s webinar, Global Shipping Regulations For Lithium Ion Power Packs. Search for it under Transporting Electronics by selecting Education and E-learning at The 60-minute webinar is free to view and contributes one hour toward the Product Safety Aware requirement.

The webinar explains the technical side of transportation and provides answers to many questions, such as:

  • What is the T1-T8 UN manual?
  • Who issues Hazardous Material Regulations (HMR) in the U.S.?
  • What happens when you don’t have short-circuit protection on a multiple cell pack?
  • How does the International Air Transport Association construct regulations?
  • Who regulates international shipments by boat?
  • How are power packs classified for shipping?


The outlook for the transportation of lithium-ion power packs, and for new technological developments for the promotional products industry, has good and bad sides. The good news is that global harmonization of regulations is moving forward. Organizations such as PRBA are leading forces in the movement toward consistency. The bad news is that various international regulations and interpretations related to the classification of lithium-ion power packs currently exist. These regulations are in constant flux and should be monitored as closely as possible to mitigate risks. Watch for updates on transportation regulations in this magazine and in PPB Newslink.

Cindy Millsaps is president and CEO of Energy Assurance, LLC. She has worked in global regulatory approvals, quality systems management, product safety and product qualification testing with emphasis on information technology equipment, power/energy and batteries. In addition to advising her clients, she serves on Underwriters Laboratories Standards Technical Panel for UL 1642 and UL 2054 where decisions are made that impact the future of the industry. She was a presenter at the PPAI Product Safety Summit in August.


>>Top 10 Considerations When Transporting Tech Products

  1. Does the product contain a battery or cell to power the device?
  2. Should the device be considered a battery or cell, or a piece of equipment that contains a battery or cell, or a battery or cell shipped with equipment?
  3. Has appropriate testing been completed on the internal cell or battery in the device, and can proper documentation be provided?
  4. Is the battery or cell manufactured under an appropriate quality management system?
  5. Are there multiple constructions of the product? Does the supplier allow for substitutions of critical components?
  6. If critical substitutions are allowed, are the new constructions covered by the testing report provided on the product?
  7. Are the packages used to ship the product appropriately sturdy for the shipping method and the weight of the devices?
  8. Are the packages appropriately labeled and documented for shipment under local and international laws and regulations?
  9. Are the devices packaged to prevent inadvertent shorting out or activation of the device during shipment?
  10. Have the shipping regulations changed in a way that affects the product?


>>General Lithium-Ion Battery Shipping Requirements

  • Cells or batteries must be manufactured under a quality management system.
  • It’s illegal to ship defective or damaged cells or batteries.
  • Contents must be protected from short circuiting.
  • There must be an effective means to prevent accidental activation.
  • Place the contents in a strong outer package. The definition of “strong” generally means the package can be dropped from 1.2 meters (four feet) without spilling the contents.
  • Secure the contents against movement within the outer packaging. A good solution is to package the contents separately and then bag or wrap them in packs.

Source: Global Shipping Regulations For Lithium-Ion Power Packs, a PPAI on-demand webinar presented by Cindy Millsaps.


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