But of course the technical argument is not the only one that governs the official policies on product certification. In recent years, the regulatory requirements for batteries have extended beyond those specified in the globally accepted International Electrotechnical Commission’s (IEC) battery pack safety standard IEC62133. This increase in the regulatory burden runs counter to the clear wish of the electronics industry for standards harmonisation.
This article describes the global state of play in the field of battery certification today, and outlines a common-sense approach for OEMs to take to minimise the cost, time and effort involved in complying with the regulations governing battery-powered products.
Certification Body scheme: a partial success
In 2012, this author wrote an article offering guidance to customers of VARTA Microbattery. It suggested that the Certification Body (CB) scheme was a valuable and effective means of streamlining the product certification process when developing global or multi-region products.
To some extent, it is still applicable today. But as much as the CB scheme helps to ease the compliance burden on electronics OEMs, the introduction of new regulations, for example the standards recently published by the Chinese and Indian authorities, appears instead to add to it.
The introduction of the CB scheme reflected the strength of the argument that safety standards may be applied universally. A battery pack, a concentrated source of energy, requires protection devices to be integrated into it to ensure its safe use, transport and storage. Through the application of well understood electronic technology, the behaviour of a battery can be reliably managed across a wide range of operating conditions.
Manufacturers and users can verify the reliability and safety design of a battery pack by systematic product testing. Once verified, a battery pack may be marked with the applicable national safety marks (for example, Europe’s CE mark or Japan’s PSE mark). The familiar marking gives consumers confidence in the product’s safety (see Figure 1).
Fig. 1: the CE marking on this lithium battery charger gives European consumers confidence that the device’s safety has been independently verified |
In nearly all cases, the national regulators’ standards for battery safety are derived from the IEC’s 62133 standard. Indeed, the IEC is driving a long-term effort to harmonise the industry’s standards for safety performance and safety testing. IEC 62133, a unified standard for rechargeable batteries which came into effect in May 2012, is an example of this trend.
Since national or regional regulations governing batteries closely match the requirements of global IEC standards, a product which achieves certification in one country is very likely to be compliant with the regulations in other countries as well.
The CB scheme enables battery producers and electronics OEMs to benefit from this uniformity of standards. When submitted for certification under the CB scheme, a product may be tested in any one participating country and, if it passes the tests, it will be certified as compliant in every other participating country. Currently, over 50 countries participate in the CB scheme. It is hard to overstate the time and cost saving and the sheer convenience of implementing all global tests at once in one country, compared to the alternative of conducting separate testing in every single country in which a product is to be marketed.
China and India buck the trend
In recent months, however, the welcome trend towards global harmonisation has suffered setbacks.
China and India are very attractive, growing markets which offer huge opportunities to manufacturers with a global marketing strategy. However, both countries have implemented new certification requirements which cannot be met through a normal CB arrangement.
For India, a new mandatory standard for rechargeable lithium batteries, IS16046, is effective from 13 August 2015. The tests specified in IS16046 are based on IEC 62133. The Indian government, however, does not recognise IEC 62133 test reports from a foreign laboratory, so the battery must be tested at an approved laboratory in India. India also requires manufacturers to submit specific information about the factory that produced the battery, including its production capacity, production equipment and the number of employees.
Since the Indian IS16046 standard is based on the IEC 62133, a battery which has already passed the IEC 62133 tests elsewhere is certain to pass the IS16046 requirement as well. Manufacturers, then, do not need to be concerned that the Indian regulations will entail any specific design or production modifications. But the sheer fact of having to arrange for local testing and supply documentation will extend the timeline and costs of the whole certification process.
In China, by contrast, unique new tests are being introduced which could require specific design measures to be taken in order to be achieve compliance. The new mandatory standard, GB31241, applies to lithium-ion cells and batteries, and is effective from 1 August 2015. Compliance is regulated on a self-declaration basis, but manufacturers must be able to provide compliance documentation demonstrating that the product has passed the relevant tests.
The GB31241 standard, as of May 2015, had only been published in Chinese. Many of the test items are derived from various existing standards, including UN38.3 (transport regulations governing lithium batteries), UL2054 (safety standard for lithium battery packs), UL1642 (safety standard for lithium cells) and parts of IEC 62133.
On top of those, China has also added unique requirements of its own: it is these which could give manufacturers the greatest cause for concern, because of the potential need to redesign products that are already compliant with every other standard applied globally. For instance, China has introduced a ‘washing machine’ test simulating a battery experiencing a washer/dryer cycle, complete with soaking, rinsing, spinning and drying.
Fig. 2: the Chinese government’s test specifications show how the test rig is to be constructed when performing the ‘washing machine’ test |
Manufacturers now face the potential new problem of modifying their product to ensure it complies, without the benefit of any familiar design guidelines or best practices for designing a consumer product to withstand a complete washer/dryer cycle.
A newly inflated compliance burden
Despite the broad industry support, then, for harmonisation of the standards with which battery packs and cells are required to comply, some national governments are pulling in the opposite direction. China and India are the most commercially important, but they are not isolated examples: Thailand, for instance, instituted its own TIS 2217-2548 standard for rechargeable batteries which, like India’s, requires testing at an approved local laboratory.
What then should be the response of manufacturers of products that contain an embedded battery? There are some general guidelines which apply in every case, and which help OEMs to prevent the compliance process from delaying a product’s release to the market.
First, the OEM should build a certification plan into its product development process from the very beginning (see Figure 3). The product development plan should include a statement of all the countries/regions in which the product is to be marketed, and the compliance requirements of each should be built into the development team’s specifications from the outset.
Second, OEMs should engage the advice of their battery supplier early and ideally from the beginning of the development project. A battery supplier such as VARTA Microbattery has technical expertise and experience of the compliance process. It can help the OEM’s design engineers to ensure that the product’s mechanical and electrical design, as well as the battery itself, will be adequate to achieve compliance in the countries specified in step one.
Finally, OEMs should avoid generating unnecessary compliance burdens. Regulatory requirements, such as the CE mark for products sold in Europe, are mandatory. Others, such as UL recognition, may not be.
Fig. 3: how to build standards compliance into the product development process |
There is no avoiding the cost of complying with the law. But compliance with other voluntary certifications may be a matter of company policy, not of law. OEMs should consider carefully whether the cost of such certifications is justified by its effect on revenues.
(It’s worth stating that it is VARTA Microbattery’s policy that critical battery components are UL recognised. This is a marketing decision: VARTA has a strong reputation for quality and reliability, and UL recognition helps to support this reputation, particularly in the crucial North American market.)
OEMs should also take careful account of the continuing costs of compliance, as well as the up-front initial costs of product testing. Some certifications, such as Russia’s Gost-R, have an expiry date, and the cost of renewing documentation must be allowed for. Likewise, the UL organisation mandates regular inspection visits, for which it charges a fee.
Minimising the cost and pain
There is no avoiding the fact that compliance with battery regulations is burdensome and costly. But the burden and the cost can be managed, if attention is paid to compliance early in a development project. The regulations governing batteries are particularly complex and fast-changing. Fortunately, battery manufacturers and assemblers such as VARTA Microbattery are well placed to stay current with the changes and to understand the operation of the testing regimes, and their early advice and guidance will help many OEMs to release products to market without suffering large delays or cost over-runs due to failure to pass a standard test.
