According to The LoadStar article, Shippers of lithium batteries will face a new hurdle from 1 January, thanks to new transport regulations.
Dangerous goods regulations framework
Test summary
The United Nations’ Committee of Experts, which creates the framework for dangerous goods regulations, has introduced a requirement which obliges manufacturers, and distributors of cells or batteries, to make available the test summary for their products.
To date, lithium cells and batteries have to be tested in accordance with the UN Manual of Test and Criteria Part III, Section 38.3.
Summary certificate
If satisfied, the test facility provides a summary certificate for the manufacturer that confirms that the cells or batteries meet an international standard and can be shipped around the world in accordance with relevant regulations.
What is the innovation in the document?
The innovation is that this document must, from the new year, be made available throughout the distribution network, and this additional hurdle is causing some disquiet among lithium battery shippers.
Implications of the rule ignored
The regulation appeared in the 2019/2020 editions of ADR (the road regulations) and the ICAO Technical Instructions and, therefore, the 60th edition of the IATA Regulations (air) as well as in Amendment 38/18 of the IMDG Code (sea).
However, the regulators provided a derogation until the end of 2019, so the implications of the rule have been largely ignored – until a few weeks ago.
Misinterpretation of regulation
Shipments acceptance refused
Already there are stories circulating of freight forwarders refusing to accept shipments of lithium batteries if they are not supplied with a copy of the test certificate.
Open to different interpretations
Of course, this is not what the regulation states; it just says that “manufacturers and subsequent distributors must make it available,” and this wording is vague enough to be open to different interpretations.
Certificate need not accompany the shipment
It can just mean the shipper has to confirm in writing that they have a copy of the test certificate, while some carriers might insist on seeing a copy. Crucially, there is no requirement in the legislation for the certificate to accompany the shipment.
Movement of lithium batteries slow down
Obliging shippers to present a copy of the test certificate has the potential to slow down the movement of lithium batteries around the world.
Manufacturers sell their batteries to a vast number of users in the IT, motor, entertainment, medical and other sectors. There is hardly a device that is not powered by a lithium ion or lithium metal battery and once installed in a unit (for example a laptop), this can be sold through several distributors before, perhaps, ending up being sold from a shop or a website.
Test certificate produced to logistics partner
All these distributors might be required to show their logistics partner the test certificate, and it is going to be challenging to ensure that this document accompanies every item as it makes its way through the supply chain to the final customer.
In addition, as batteries become larger and more sophisticated, some manufacturers could be reluctant to provide a test certificate as it could end up in the hands of their competitors.
Regulations far too complex
It is generally recognised that the lithium battery transport regulations are far too complex. Many batteries are air freighted, where typically the packing instructions stretch to more than three pages of tightly written text, and there are also a lot of special provisions to comprehend.
The reason is that the regulators have had to keep up with rapid technical developments, which is also why there are changes to the regulations almost every year – with more to come in 2021!
Complexity of the regulations
The result is that shippers and distributors that want to comply, struggle with the complexity of the regulations, while others choose, either deliberately or through lack of knowledge, to ignore them.
There are a lot of incidents worldwide related to the shipment of undeclared lithium batteries, which pose a danger to the public as well as to the trucks, vessels and aircraft that transport millions of batteries each day.
Safety or hindrance?
Whether this latest amendment to the regulations will provide a further degree of safety, or just a hindrance and delay for legitimate shippers and distributors, will become clearer in the new year.
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Source: The LoadStar
