George Kerchner, Executive Director
PRBA-The Rechargeable Battery Association
Four major battery associations met in Kyoto, Japan on May 21st and 22nd to discuss current global regulatory challenges facing the industry and to lay the groundwork for future cooperation on a number of issues. Representatives and members from the Korea Battery Industry Association (KBIA), Battery Association of Japan (BAJ), RECHARGE – The European Association for Advanced Rechargeable Batteries, and PRBA-The Rechargeable Battery Association participated in the meeting formally known as the World Rechargeable Battery Regulatory Forum (WRBRF).
The WRBRF previously was held in Annapolis, Maryland, Rome, Tokyo and Washington, DC. In Kyoto, KBIA participated in the Forum for the first time and offered a unique perspective on its activities.
Issues discussed during the forum included, but were not limited to, the following:
- New dangerous goods transport regulations for damaged/defective lithium batteries and waste lithium batteries
- Global battery collection and recycling programs and initiatives
- Industry standards on rechargeable batteries
- Lithium ion battery fire code developments
- Safety issues and coordinated industry responses
- Flammability testing of lithium ion batteries by government agencies
- Proposed changes to European battery directive and ban on cadmium in power tools
- Re-use and second use of rechargeable batteries and producer responsibilities
- Information Technology Agreement and elimination of import tariffs on rechargeable batteries
Battery Collection and Recycling, Transport Regulations and Lithium ion Battery Fire Code Developments
The first day of the Forum covered a wide range of issues impacting the industry. Representatives from RECHARGE updated the participants on the European Commission’s work to amend Battery Directive 2006/66/EC and eliminate the cordless power tool industry’s longstanding exemption from the EU’s ban on the sale of portable batteries and accumulators that contain more than 0.002 percent of cadmium. The European Commission’s believes there are sufficient substitutes for nickel cadmium batteries and that the measure is economically justified. The exemption is due to expire this year but the power tool and battery industry would like to see it extended until 2018. There appears to be support within the Commission to extend the exemption until 2015. Negotiations over the final date are expected to conclude this summer.
Representatives from Call2Recycle and Japan’s Portable Rechargeable Battery Recycling Center (JBRC) reported on their activities and the regulatory challenges they face in collecting secondary and primary portable batteries. JBRC promotes the collection of portable Ni-Cd, Ni-MH and Li-ion batteries and has over 30,000 collection sites in Japan. Call2Recycle promotes the collection of secondary batteries in the US and primary and secondary batteries in Canada. Call2Recycle has a network of collection sites at over 30,000 retailers, municipalities, businesses and public agencies throughout the US and Canada. Collection data from each organization are provided below.
- JBRC Battery Collection Data
- Call2Recycle Battery Collection Data (Percentages represent annual growth rates)
PRBA reported on battery product stewardship legislation that has been introduced this year in the US and the challenges this has created for the industry. PRBA provided an update on the legislation that was introduced in Minnesota, Oregon, Washington and California. In Oregon and Washington, legislators considered bills that would have required companies that place rechargeable batteries into the marketplace to finance the collection and recycling of the batteries. In California and Minnesota, bills requiring non-rechargeable battery producers to design, fund and operate a stewardship program to collect and manage their batteries were introduced. Ultimately, legislators in each state failed to adopt any new battery bills.
PRBA and RECHARGE spent a significant amount of time explaining the new international dangerous goods transport regulations applicable to waste lithium batteries and damaged and defective lithium batteries adopted by the UN Sub-Committee of Experts in December 2012. The new regulations adopted by the UN were based on proposals filed jointly by the PRBA and RECHARGE, which are recognized as officials Observers with Sub-Committee.
PRBA noted that starting January 1, 2016, shipments of waste lithium batteries and damaged or defective lithium batteries will be governed by new Special Provisions and Packing Instructions when shipped by sea in accordance with the International Maritime Dangerous Goods (IMDG) Code. Similar regulations will take effect in accordance with the European Road Regulations (ADR) and the US Department of Transportation is expected to consider equivalent regulations for incorporation into the hazardous materials regulations.
PRBA also explained the lithium ion battery flammability testing being conducted by the Fire Protection Research Foundation (FPRF), which recently issued its Phase IIB report, titled “Lithium Batteries Hazard and Use Assessment.” The report describes the flammability testing conducted on cartoned lithium ion polymer cells, lithium ion 18650 cells, lithium ion power tool battery packs in blister packs. FPRF conducted the testing to determine the flammability characteristics of small format lithium ion cells and batteries and to provide a basis for fire protection guidelines and commodity classification. The high costs of the lithium ion cells and battery packs forced the FPRF to scale back their tests and as a result water-based fire protection recommendations could not be derived directly from the results of the reduced commodity full-scale lithium ion cell and battery tests. As a result, the FPRF believes that further engineering analysis and guidance is necessary to support specific sprinkler protection criteria for bulk packaged cartoned lithium ion cells and batteries in rack storage configurations. FPRF intends to conduct full-scale fire tests this year on eight pallets of lithium ion cells and batteries.
Battery Industry Standards
Representatives from KBIA and Korea Electrotechnology Research Institute provided an update on several Korean “battery energy storage system” (BESS) industry standards, including the following:
- KBIA-10104-01 Secondary Lithium-Ion Cell and Battery System – Battery Energy Storage System ─ Part 1 : Safety test
- KBIA-10104-02 Secondary Lithium-ion Cell and Battery System – Battery Energy Storage System ─ Part 2 : Performance test
The tests included in the Korean standards and comparisons to similar IEC standards are listed below.
- KBIA-10104-01 vs. IEC 62619NP
- KBIA-10104-02 vs. IEC 62620CD
Representatives from BAJ provided an update on the work being done on a number of industry standards, including:
- IEC62133 (Safety Standard) for secondary batteries designed for use in portable applications;
- IEC62620 (Performance Standard) and IEC62619 (Safety Standard) for secondary batteries designed for use in industrial applications;
- IEC62660-1 For secondary lithium ion cells for the propulsion of electric road vehicles – Part 1: Performance testing; and
- IEC62660-2 For secondary lithium ion cells for the propulsion of electric road vehicles – Part 2: Reliability and abuse testing.
Interestingly, a propagation test is being considered for incorporation into IEC 62619. If adopted, it would be the first such test incorporated into a battery industry standard.
As industry standards for large format lithium ion batteries continue to proliferate, it has become evident that the testing requirements for “Large” lithium ion batteries in accordance with the UN Manual of Tests and Criteria need updating to reflect changes in battery design, technologies and formats. PRBA reported on a UN working group meeting that has been scheduled for October 2-4, 2013 at PRBA’s office in Washington, DC during which the UN test procedures and transport regulations applicable to large lithium ion batteries will be addressed. Proposed agenda items for the meeting include, but are not limited to:
- A review of definitions applicable to “large battery” and “battery assembly”
- Proposed changes to shock and short circuit tests
- Testing requirements for “battery assemblies” rated at less than 6200 Wh
- Evaluation of equivalent industry standards and proposal for harmonization of standards;
- Stationary containers and transport regulations
- ICAO packaging proposals for large lithium ion batteries over 35 kg
Global Communication Strategy on Lithium ion Battery Issues
Because of the significant amount of international regulatory activity on lithium ion batteries, the second day of the Forum was dedicated to laying the ground work for establishing a global communication program between the associations. RECHARGE and PRBA presented an outline on how such a program could be developed and the benefits of conveying a consistent industry message on the use, transport, handling and storage of lithium ion batteries.
The types of communication tools needed to establish such a program were discussed at length. RECHARGE provided an excellent update on an interactive tool they have developed for complying with the dangerous goods regulations. PRBA explained their plans for producing a video on the same regulatory issue. The participants also agreed that more information sharing between the associations on lithium ion battery regulatory issues is the key to establishing an effective, long-term global communication program. To that end, PRBA, RECHARGE, KBIA and BAJ agreed to begin scheduling more frequent meetings and conference calls to stay abreast of the regulatory issues impacting the rechargeable battery industry and develop coordinated industry responses.