And Why it’s Important for Manufacturers to be in Compliance
Manufacturers, distributors, retailers, and home consumers ship hazardous materials out all the time. Among those HAZMAT materials are products containing lithium metal (non-rechargeable) and lithium-ion (rechargeable) cell batteries.
UN 38.3 is a global testing certification to see if lithium-based cells and batteries can survive the special conditions of air travel.
However, it should be noted that even though a product passes UN 38.3 testing, that doesn’t mean it can ship air or even ground in some instances due to state and carrier regulations. Standalone cells and batteries, as well as batteries contained or packed with products that are above certain fully hazardous thresholds, can also not be shipped by air without being fully regulated. We also must look at the containerization of multiple items and properly label them as well. That’s what we are the experts at.
Understanding the Different Lithium Terms
There are two types of batteries: Lithium Metal which are not rechargeable, and Lithium-Ion, which are rechargeable. Each of these is classified as either a cell or a battery.
- Cell: A single-encased electrochemical unit (one positive and one negative electrode) which exhibits a voltage differential across two terminals
- Battery: Two or more cells that are electrically connected and fitted with devices necessary for use such as an outer case, terminals, markings, and protective devices
Each of these factors plays a role in shipping.
Why is UN38.3 Testing so Important?
It’s about safety.
According to the FAA, since 2006, there have been 414 incidents reported to them involving lithium metal or lithium-ion cells and batteries. The products were either shipped as cargo or were in baggage. They also state their “list does not include three major aircraft accidents where lithium battery cargo shipments were implicated but not proven to be the source of the fire.”
Since lithium can be a fire or explosive hazard during transport, it’s important that cells and batteries travel safely throughout the entire process—from supplier to product manufacturer to wholesale distributor to end user. This is where UN 38.3 comes in.
Whether a standalone product or already installed in a device, all kinds of lithium-based batteries and cells must undergo UN 38.3 testing. Here in the U.S., it’s also part of US law (49CFR 173.185(a(3)) and international law, and is required before shipping a product ground or air.
How Important is it to be Able to Ship by Air?
When it comes to online shopping, being able to ship is a must and both 49CFR (regulates ground transport in the US) and the IATA (regulates air transport) require distributors to have a UN38.3 Test Summary document in their possession before shipping out products.
According to retailwire.com:
“Free two-day shipping, what many see as the norm of online retail, was important to 79.3 percent of those surveyed…”
“Not getting delivery right is a business killer, with 72.7 percent saying they are unlikely to do business with a site again after a poor delivery experience”
Forbes indicates:
- 77% have “abandoned a purchase due to unsatisfactory shipping options”
And according to Arvato:
- 53% of online shoppers consider delivery speed to be the most important factor in the purchasing process
- 24% of shoppers have canceled their orders due to slow shipping speeds
- Only 17% like multiple delivery options
If air is offered to the end-user but it turns out that’s not an option—due to a battery failing the UN 38.3 test, no Test Summary provided for verification one way or the other, or carrier restrictions—the sale process comes to a halt.
The reseller may choose to cancel the customer’s order. Or they may inform the customer that it can’t go air and then offer other options, thus delaying arrival. That, in turn, can lead to the customer canceling the order and taking dollars elsewhere—a losing proposition for all concerned.
Having the Test Summary might have saved the sale. And working with the shipping company from the get-go might have revealed that air was never an option. In that case, other options could have been listed with an explanation why. If online shoppers understood the issues from the beginning, it would reduce customer dissatisfaction.
What is Required for UN 38.3 Testing?
UN38.3 is a set of standards to ensure lithium-based cells and batteries can safely travel by air, whether being shipped on their own or pre-installed in devices.
Here’s the table of tests for non-rechargeable cells and batteries:
And here’s the table of tests for secondary/rechargeable cells and batteries:
There are eight T tests (T.1, T.2, etc., as you can see across the top of the table). Third-party entities can do testing. Sometimes a battery manufacturing plant will set up a sister test facility to ensure compliance. And on rare occasion, a company will self-certify. But given liability issues that can arise, third-party testing is best.
T.1 is for air transport cargo hold altitude
T.2 is thermal. This is based on rapid and extreme temperature changes to make sure the seal integrity and internal connections are good.
T.3 is vibration
T.4 is for shock
T.5 is for external short circuits
T.6 tests for impact and crush
T.7 is to see how well a rechargeable battery tolerates being overcharged
T.8 tests to see how well a primary or rechargeable cell can withstand being forcibly discharged
A 1.2 meter (3.937 ft.) free-drop test and others might be performed too.
What Does a UN38.3 Test Summary Report Look Like?
The summary is straightforward. Since there’s a Pass/Fail section, it’s easy to spot a failed test. A failure, of course, doesn’t necessarily mean the battery is bad. But it does mean the lithium cell or battery cannot be shipped by air.
For those interested in reading through the UN Manual of Tests and Criteria, here’s a link to the 7th Edition, 2019. It is downloadable. The relevant pages dealing with lithium testing are 420 through 433.
And for those interested in how the U.S. DOT defines shipping regulations in the United States, here’s a link to 49 CFR. Sections 100 through 185 are the relevant ones for hazardous materials, including lithium batteries.
Why is UN 38.3 Such a Big Deal Now?
Many testing standards (for example Prop 65 and WERCS) take a while to be fully implemented. The first deadline for UN38.3 compliance was the beginning of 2020.
As of January 1, 2021, all battery manufacturers must have Test Summaries available upon request. Here at Petra, the Test Summary must be provided before a new item is accepted into our system for resale. Please note that some test reports can be accepted as test summaries, as long as all of the required 10 points are on the summary.
Cleared for Takeoff
In summary, UN 38.3 is all about safety. After all, no one wants products to explode or catch fire.
More and more resellers are requiring UN 38.3 Test Summaries before they’ll even accept a product for sale. So, if you are a manufacturer or importer of lithium-based cells and batteries, you need to design them to ensure they pass the UN 38.3 tests, pass the tests, and get the Test Summary to prove it. And if you incorporate third-party’s batteries into your products, you need to have their UN 38.3 test reports and summaries on hand so you can supply it to distributors and resellers who ask for it.
As mentioned in the beginning, experienced distributors know the ins and outs of shipping hazardous materials. And they understand the restrictions placed by shippers like USPS, UPS, FedEx, and DHL.
Petra Industries’ Shipping Department is compliant with the necessary protocols and our Product Information Team checks for UN 38.3 Test Summaries from product manufacturers and inputs the data so that our distribution center can process the order. They also pass them on to resellers as required by law.
To find out other ways Petra works to keep manufacturers in compliance with today’s ever-changing regulations, as well as other special services we offer, be sure to visit petra.com today.