Lithium batteries are commonly found in smartphones, electronic toys, e-cigarettes, and many other devices. In this guide, we cover the basics of lithium product safety and regulations in the United States. Keep reading, and learn the essentials of compliance risks, testing requirements, safety standards, labeling and more.
- Lithium Battery Powered Devices
- Lithium-ion battery
- Lithium-ion polymer battery
- Lithium metal battery
Underwriter Laboratories (UL)
Underwriter Laboratories (UL) is an independent product safety organization, providing voluntary standards for many categories of products including but not limited to lithium batteries
Lithium battery safety requirements are addressed by the UL standards, which include the test methods, substances, and technical safety requirements.
UL published a number of lithium battery safety standards. Here are some key standards for lithium battery products:
- UL 1642 – Standards for Lithium Batteries
- UL 2054 – Standard for Household and Commercial Batteries
- UL 4200A – Standard for Safety for Products Incorporating Button or Coin Cell Batteries of Lithium Technologies
- UL 60086-4 – Standard For Safety For Primary Batteries – Part 4: Safety Of Lithium Batteries
Depending on your product type, you can find more additional UL standards here. Further, note that standards can also be replaced or updated.
UL Listing: UL listed mark indicates that the product has been tested, and it is safe to place on the market.
UL Recognition: Similar to UL listing, but it mostly applies to “associated products” such as AC-adapters, and replacement parts.
UL Classification: To indicate that the product meets UL safety requirements for certain properties (e.g energy content).
Amazon and UL Requirements
Besides stand-alone lithium batteries, also many lithium powered products such as hoverboards, thermometers, and laser pointers sold on Amazon must comply with the platform’s requirements for lithium products.
For example, Amazon US requires that all hoverboard sellers must provide UL test reports to show compliance with applicable UL standards such as UL 1642.
Therefore, importers shall either buy UL-listed products or conduct third-party lab testing for the applicable UL standards. Otherwise, Amazon can remove your product listing with non-compliant reasons, and suspend your Amazon account if necessary.
Far from all lithium batteries comply with UL standards. While UL compliance is voluntary, importing and selling potentially unsafe lithium batteries is not only risky for consumers – but also the companies importing the products. Keep in mind that you are liable if anyone is injured, or in case property is damaged. These are real risks, as demonstrated by the Hoverboard safety issues back in 2015.
Our recommendation is that you only procure lithium batteries which are tested and proven to comply with all current UL standards. Keep in mind that most lithium batteries on the market are not UL tested and compliant. In fact, most OEM lithium batteries are not. As such, procuring UL tested and compliant brand name batteries (e.g, Samsung) is often the only option.
CPSC Battery Standards
Battery-powered products shall comply with applicable voluntary standards such as:
- UL 1642 – Standard for Safety for Lithium Batteries
- ANSI/NEMA C18 – Safety Standards for Primary, Secondary and Lithium Batteries
- IEEE 1725 – Standard for Rechargeable Batteries for Mobile Telephones
- UL 2054 – Standard for Household and Commercial Batteries
Battery-powered products shall include a system approach regarding:
- Thermal protection
- Short-circuit protection
- Charge and discharge protection
- Battery management systems
- And other applicable systems
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CPSC Lithium Battery Recalls
CPSC has recalled hundreds of lithium battery-powered products placed in the US market, due to the potential hazards including overheating, fire shock, electrical shock, and battery exposure.
Hazardous Materials Regulations (HMR)
Lithium batteries are subject to specific transport requirements due to its potential hazard.
As such, HMR set requirements regarding the transportation of dangerous goods including lithium battery products. Here is a brief overview of the requirements:
1. Lithium battery label – Importers must attach the standardized label on the product and its packaging when transporting to the United States.
2. Lithium batteries must be properly classed, described, packaged, marked, labeled before transportation.
3. The quantity limitations for lithium-ion and lithium-ion polymer batteries is 35 kg for cargo aircraft only.
4. Importers shall make sure that their lithium battery product complies with all applicable standards or regulations, and provide relevant certification upon importation.
Note: The details of HMR can be found in 49 CFR, parts 171-180.
All lithium batteries shipped to the United States must comply with UN 38.3. Here’s a list some UN 38.3 standards for various types of lithium batteries:
- UN 3090: Lithium metal batteries
- UN 3480: Lithium-ion batteries
- UN 3091: Lithium metal batteries contained, or packed with equipment
- UN 3481: Lithium-ion batteries contained, or packed with equipment
Unless your supplier can provide a valid UN 38.3 test report, you should obtain the test reports from a third-party lab testing companies such as SGS, Intertek and TUV. As mentioned, we normally recommend importers to procure UN 38.3 tested and compliant brand name lithium batteries. Otherwise, your product may not even get loaded on the plane or ship.
Many states in the US including California, New York, and Illinois, enforce the RoHS regulation for imported lithium batteries in the US market. RoHS sets limits for heavy metals in electronic products, and it is illegal to sell products that contain excessive amounts of regulated substances.
Here are some regulated heavy metals under RoHS:
- Lead (Pb)
- Mercury (Hg)
- Cadmium (Cd)
- Hexavalent chromium (Cr6+)
It is essential to instruct your suppliers about the RoHS requirements before the mass production since suppliers shall only use RoHS compliant components when manufacturing lithium battery products.
FCC covers electronic devices that are intended to emit radio energy or operating at a frequency of over 9 kHz. For electronic products that are powered by a lithium battery, FCC regulation might be applicable to restrict the interference on the telecommunication network and frequency spectrum.
FCC Supplier Declaration of Conformity (SDoC)
The SDoC can be self-issued by either the manufacturer or importer. The SDoC shall list all relevant information of the importer, product, relevant standards, and test reports.
Here is an overview of SDoC content:
- Company contact
- Importer contact
- Product information
- Applicable standards
- Test reports
- Representative name and signature
In order to assess your product compliance, you can request an FCC test from a third-party testing company such as SGS, CMA, and Intertek. Noted that you shall book testing from FCC-recognized accredited companies. You can search for authorized testing companies on their official website.
Country of Origin
For most products, including lithium batteries, imported and sold in the United States, it is mandatory for importers to attach a permanently and visibly country of origin on the product and its packaging.
- Made in China
- Made in Korea
- Made in Japan
- Made in the USA
Importers are responsible for creating the label file to the supplier. Before mass production, importers shall provide the label file in .ai or .eps, then instruct the supplier with the placement, size, and other relevant information.