Commentary contributed by Rich Byczek, Global Technical Director – Transportation Technologies, Intertek
February 14, 2018 | As we have more and more portable devices powered via a common USB interface or adapter, the need for convenient charging “on-the-go” has led to the proliferation of the Powerbank, and its’ often larger sibling, the Power Pack. Simply stated, Powerbanks are typically Lithium-ion based batteries encased in a protective enclosure and providing a USB charging interface to power or charge those portable devices such as tablets and smartphones. In some cases, these powerbanks may incorporate their own wall-connection and imbedded charger, but more commonly are recharged via the same USB interface.
One challenge for many manufacturers, retailers, and distributors is to understand how these devices can be deployed both safety and legally, as the global maze of regulations and certification schemes are not always clear for these products. The first question to be asked is simply: is a Powerbank a battery, or is it a battery-powered-device? The answer, as is often the case in the regulatory realm is “It depends.” Specifically, the designation for these products really depends on which regulations or standards you are referring.
The first and most common global requirements affecting these products, are in the transportation space. Lithium-ion batteries are typically regulated for transport as dangerous goods under one of two United Nations Harmonized codes: UN 3480 (Lithium Ion Batteries) or UN 3481 (Batteries Packed in or with equipment). These leads to the follow-up, or modified version of our initial question: is a Powerbank a battery or is it an equipment with a battery inside. For the transportation regulators, these are clearly batteries (UN 3480), as the primary function of the Powerbank is to provide power to another device or equipment. While some powerbanks may incorporate additional features such as an LED lamp or USB memory, we must consider the primary purpose. To the transportation regulators, this means it is a battery.
Within the dangerous goods regulations, we have two primary considerations now: testing and packaging requirements. Lithium Ion batteries, must be tested according to chapter 38.3 of the UN Manual of Tests and Criteria[1]. Packaging requirements, based on the UN 3480 code, are then further divided into cell and battery limitations. A Powerbank consisting of only a single Lithium-ion cell will be shipped according to the limitations for cells within the packaging regulations, and multi-cell powerbanks will be subject to the limitations for batteries. These differ in terms of quantities per shipment as well as labeling requirements than for products shipping under the UN 3481 code. Most of related shipping requirements globally are based on the UN Model Regulations[2], but adoption and dates of enforcement may differ across countries and carriers. A recommendation here is to coordinate with your logistics provider prior to making your own interpretations of the requirements.
Because these are regulated in shipment as batteries, there are a few specific requirements that may affect both design and preparation of product before shipment. Per the UN Model regulations, any Lithium-ion battery must be marked with their capacity in watt-hours on the outside case. Secondly, and specifically for air-shipment of lithium-ion batteries, all batteries must be discharged to less than 30 percent SOC (State of Charge) as defined by ICAO (International Civil Aviation Organization) and IATA (International Air Transport Association). While incoming shipments from the manufacturer may be a bulk shipment by ground or vessel, the ongoing shipment or sale of smaller lots via air shipment become a challenge for distributors and retailers who must be able to document that any air shipments of batteries meet this 30 percent requirement.
Now on to the question of safety. When considering electrical safety, in contrast to the transportation space, the most applicable certification standards are those for electrical devices, rather than only for the component battery. As opposed to the dangerous goods regulations, which are focused on the specific hazards related to Lithium battery chemistry under shipment, we must now consider the actual usage conditions: charging, discharging, handling, and interoperability with the devices which these powerbanks are intended to charge. For many markets, enforcement of voluntary or mandatory electrical safety standards are often limited to products that connect to the electrical mains, or for toys. Battery safety standards often do not incorporate considerations for onboard charging circuitry, enclosures, DC/DC converter circuitry or the USB/charging interface. Often for retailers, compliance can be shown by certification marks on the “wall-wart” USB charger which has the appropriate plug for each market but does not address the safety of the Powerbank itself. For the European market, since the voltage level of the Powerbank will typically fall well below the 60 VDC minimum of the Low Voltage Directive for electrical safety, one may
In the US market, there is currently a draft standard, UL OOI 2056: Outline of Investigation for Safety of Power Banks, which primarily mirrors the component battery standard UL 2054: Household and Commercial Batteries, along with Input/output circuits, referencing UL 60950-1: Information Technology Equipment – Safety – Part 1: General Requirements (Bi-national standard). For PowerPack systems (those systems that incorporate vehicle battery charging, AC inverter outputs or other non-USB type outputs), standard UL 2743: Portable Power Packs, has been released to additionally consider those applications, but specifically does not apply to powerbanks. Manufacturers have the option to test and certify against these standards, and NRTLs (Nationally Recognized Test Labs) may provide 3rd party certification accordingly.
Now, for a more global market, including the US, and considering that UL OOI 2056 is still only a draft, IEC 60950-1: Information Technology Equipment – Safety – Part 1: General Requirements, and it’s more recently released counterpart IEC 62368-1: Audio/video, Information and Communication Technology Equipment – Part 1: Safety Requirements, which are adopted in the US as well as Canada and multiple countries outside of North America, may be utilized to provide a faster path to global market acceptance. These two standards are used for evaluation and certification of Information Technology Equipment (i.e. the very devices that get charged by powerbanks, and subject to the same usage conditions and handling). As the standards have been adopted in the US and Canada, the NRTL certification option still applies, as well demonstrating compliance according to a globally accepted standard for other regions. Specifically, the IECEE CB Scheme[3] provides a path for global certifications accepted in over 50 countries. Additionally, these 2 standards incorporate battery-specific as well as input/output, enclosure, operating temperature and abnormal usage and fault tolerance testing, very similar to the clauses of UL 2056. The intent here is not to dive into specific test requirements, but rather to highlight some options for those wishing demonstrate compliance and gain access to a wider distribution market.
Overall, Powerbank manufacturers and distributors need to meet the needs and requirements of the market as well as transportation authorities. When dealing with the transportation realm, the keys are clear communication with their logistics provider and ensuring proper documentation from their suppliers, to aid in ongoing shipment preparations. In the product safety and certification space, the key here is to know that there may be several options available to demonstrate product safety. Many of the standards noted above and other alternate standards may have overlapping scopes and therefore more applicable depending on product design and intended market. In this area, open communication with their certifications provider is the best route to finding the most efficient path to market access and risk mitigation.
Rich Byczek is the Global Technical Director-Transportation Technologies for Intertek, a global Total Quality Assurance provider. In this role, Rich participates in multiple standards committees and panels related to Energy Storage and Electric Vehicle Batteries and Charging Systems, as well as Lithium Ion Battery transportation.
References
[1] UN Manual of Tests and Criteria, Sixth Revised Edition, United Nations, 2015. www.unece.org
[2] UN Recommendations on the Transport of Dangerous Goods – Model Regulations, United Nations, 2015. www.unece.org
[3] IEC System of Conformity Assessment Schemes for Electrotechnical Equipment and Components. www.iecee.org
