Blast From The Past


(This article is a follow-up to “Buyer Beware: Lithium-ion Power Packs Require Careful Transport” in PPB’s December 2014 issue.)

Power packs that contain lithium-ion batteries are a relatively new and increasingly popular category of promotional products. These convenient devices are used to recharge portable devices such as cell phones. They are typically charged from a USB connection and provide a charge to a product in a similar way.

The issue is that the quality of construction for these devices varies radically from supplier to supplier. Currently these devices are allowed to be considered as lithium-ion batteries contained in equipment. However, the International Air Transport Association (IATA) is proposing to require them to be shipped as batteries instead.

Additionally, the UN informal working group on lithium battery safety has several discussions related to power banks on its agenda for this month. These proposals would impose stricter limits on the number of units that can be contained in a package as well as require additional battery level testing of these units prior to offering them for shipping.

The close of 2014 brought a number of significant changes to the transportation regulations related to lithium-ion batteries and, in particular, lithium-ion power banks.

What’s On The Horizon For Lithium Battery Transport Regulations

In early December 2014, the sub-committee completed its work on a number of battery-related papers that will affect the transport and testing of lithium batteries. It is important to understand the changes and when they will go into effect in order to maintain compliant shipping practices within your organizations.

The most significant changes came from the UN Subcommittee of Experts on the Transportation of Dangerous Goods and will affect international shipping regulations. The discussions among this group have triggered larger industry-wide discussions specifically related to power banks and how they are classified for testing and shipping purposes. These discussions will likely have an even greater impact on the shipment of these devices, and changes in this area should be expected in 2015.

Adopted changes that directly affect the shipment of power banks (also called power packs) include the following:

  1. There is a change on the implementation of the lithium battery handling label for use with small lithium batteries shipped alone, as well as those contained in or shipped with equipment. The new label is consistent with the current label used for air shipments. The new label will become mandatory on January 1, 2019, although it can begin to be used voluntarily on January 1, 2017. Additionally, some of the paperwork requirements for these small batteries were eliminated due to redundancy. (Yo: change minimum dimension on chart to 4.72 inches.)
  2. At its 2014 meeting, the IATA proposed that power packs should be regulated as batteries instead of as cells and batteries contained in equipment as they are now. This proposal was not adopted and power banks are currently still shipped under the less stringent requirements of cells and batteries contained in equipment. However, the issue is not completely closed; it will be discussed at a number of industry meetings this year. Stay tuned.
  3. There are new marking requirements for consignments of lithium cells and batteries contained in equipment. The current exemption from marking of packages that contain fewer than four cells or two batteries installed in equipment will be updated based on the subcommittee decision to adopt new requirements that limit the exception to the following:
    1. Packages containing only button cells or batteries installed in equipment (including circuit boards);
    2. Packages containing no more than four cells or two batteries installed in equipment, where there are not more than two packages in the consignment.

The new requirements mean that if more than two exempt packages are contained in a larger package (over-pack), then the overall package will now be required to have the label and associated markings and documentation. This change will become effective January 1, 2017.

  1. As a clarification on how to handle single cell batteries for shipping, a definition was adopted that aligns with the current definition in the UN Manual of Tests and Criteria. This definition states that single cell batteries are to be considered cells and should be shipped in accordance with the regulations for cells for the purposes of the exception for small cells and batteries. This allows for a larger number of units to be shipped in a single package than if they were considered batteries.
  2. A new Class 9 hazard label was adopted for lithium batteries. It contains a pictogram of batteries on the standard Class 9 label. This new label will become effective January 1, 2019, however can be used voluntarily starting January 1, 2017.
  3. Several changes were adopted for the shipment of prototype or low-production-run batteries contained in equipment, including the following:
    1. Authorization to transport prototype and low-production lithium batteries contained in equipment, which were not previously addressed by the regulations;
    2. Authorization to use Packing Group II (PGII) packaging including 4G fiberboard boxes;
    3. Clarification of short circuit protection requirements;
    4. New provisions that clarify the applicable packing instructions for transporting damaged and defective lithium-ion batteries as well as waste lithium-ion batteries.

In addition to these new provisions, there were a number of items that were identified for further discussion in 2015. These include the following:

  1. Discussion was opened based on a proposal to raise the lithium-ion battery exception limit to 300Wh from the current 100Wh limit under the special provision for small lithium batteries.
  2. Testing requirements applicable to power packs
  3. Definitions of cells and batteries in the transportation regulations in relation to those used in the IEC standards related to lithium batteries
  4. Standardized declarations of conformity with the UN tests
  5. Development of a database of declarations
  6. Testing requirements related to large cells used in small batteries

The items adopted by the subcommittee will be reviewed by the International Civil Aviation Organization (ICAO) Dangerous Goods Panel as well as the International Maritime Organization (IMO) and decisions made on how to incorporate them into the ICAO Technical Instruction and the International Maritime Dangerous Goods (IMDG) Code. The above noted changes will affect all modes of transportation of lithium batteries as they are adopted by the international organizations and various local regulation authorities.

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 2014 Product Safety Summit.


>>Learn More On Demand These relevant and content-rich webinars are available on-demand from PPAI by clicking the Education and E-learning tabs at

Transporting Electronics
Speaker: Cindy Millsaps, president and CEO of Energy Assurance, LLC
60 minutes
1 MAS Point
If you ship batteries and other technology products this session is a must for you to attend. Shipping regulations exist for air, land and sea to protect against hazards. Learn first hand what your obligations are under these complex regulations in plain language.


Focus On Lithium-Ion Batteries and Power Banks
Speakers: Ibrahim Jilani, the North America Program Manager for Small Batteries at UL and Anne Lardner-Stone, director of public affairs at PPAI.
60 minutes
1 MAS Point
This course will address the critical need for safety and certification when sourcing lithium batteries. Learn what you need to look out for to keep you and your channel partners on the right side of compliance.


Product Safety Summit 2014: Electronic and Lithium Battery Promotional Products: Get A Charge Without Getting Zapped!
60 minutes
1.3 MAS Points
$15 PPAI members; $30 nonmembers
Speakers: Don Mays, director of product safety and quality at Deloitte & Touche LLP; Ibrahim Jilani, North America program manager for Small Batteries at UL; and Cindy Millsaps, president and CEO of Energy Assurance, LLC
Tech products are one of the industry’s hottest product categories, but what do you really know about sourcing them? This session will address the critical need for safety and certification when sourcing lithium batteries and other electronics.




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