UN 38.3 TSD Requirements – Implications for Battery Manufacturers & Retailers

by | Jan 21, 2020

If you manufacture, sell, or transport lithium ion batteries, you’ve been thinking a lot about the UN 38.3 testing requirements over the last year. 

As a part of this continued push towards greater consumer safety and transparency, the EPA published a proposed rule, 83 Fed. Reg. 60970, requiring Test Summary Documentation (TSD) be provided by manufacturers of lithium batteries under the guidelines of UN 38.3. 

These tests ensure the safety of those batteries and the products that they’re shipped in under all forms of transport: air, rail, water, and ground. With these tests conducted and properly documented, manufacturers, transporters, retailers, and consumers can all rest assured that your cell phone battery will not explode the next time you fly off for vacation. 

Here are the most important things to know.

Who should have TSD on file?

According to § 173.185(a)(3),

“Each manufacturer and subsequent distributor of lithium cells or batteries manufactured after June 30, 2003, must make available upon request at reasonable times and locations, a test summary.”

Any individual or entity in the supply chain may request the test summary (i.e. regulator, consumer, or transport provider). The Test Summary Documentation must be provided in a reasonable timeline. For this to work in accordance with the intent of the law and to best satisfy increasing consumer demand for transparency, all stakeholders in the supply chain should have quick access to the UN 38.3 Test Summary Documentation for a given product.

What Requires UN 38.3 TSD?

According to § 173.185, 

“…lithium cell(s) or battery(ies) includes both lithium metal and lithium ion chemistries”.

This means that any lithium cell, lithium battery, or product containing a lithium cell or battery, requires TSD. The distinction between cells and batteries means that your battery product may in fact require two different test reports: one for the cell; and one for the completed battery. They are not the same and are not interchangeable. Single cell batteries (e.g., AA, AAA, CR2032 button cells) will have a text report for the cell and it may be used for the battery as it is a single cell. However, multiple cell batteries may have different wirings (series, parallel or both) and the electrical properties are different. Therefore, each new battery configuration will require a different test report. 

When is testing required?

According to § 173.185(a)(2),

“Each person who manufactures lithium cells or batteries must create a record of satisfactory completion of the testing (e.g. test report) required by this paragraph prior to offering the lithium cell or battery for transport.

Prior to offering a lithium cell or battery for transport, the UN 38.3 test must be performed. Testing guidelines can be found here (beginning on page 424) if you plan to do this testing in-house. Otherwise, Eurofins or Intertek are two examples of testing labs that could perform these tests. Contact these providers for pricing inquiries, but prices generally range upwards of $10,000 per test. The upside of this approach is that third party labs’ results will have more credence than in-house results. 

More Information:

For answers to more detailed questions and example test summaries, see this pdf from the Committee of Experts on the Transport of Dangerous Goods.

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