Two obligations on one pack
A rechargeable camping lantern carries a pack that is subject to more than one battery obligation at the same time. The pack powers an LED or COB array through a driver and sits in a battery bay that a user can sometimes reach, which is why the pack is both a product component and a regulated item. The first is an electrical safety document for the cell, and the second is a set of requirements that fall on the product as a whole and are being phased in over time. The two are frequently described as one compliance item, and describing them as one item is how a buyer ends up holding a file that covers the first and misses the second.
The electrical safety document is a report on the cell or the pack against a defined test method. It covers the behaviour of the cell under specified fault and abuse conditions and is the document that supports the pack's electrical safety claim. The battery regulation obligations are different in kind: they concern the label on the product, the way the pack can be removed or replaced, and the due diligence expected of the party that places the product on the market.
For a buyer the practical rule is that each obligation is requested separately, filed separately and confirmed separately. A supplier who sends one document and describes it as covering both has not answered either question, and a buyer who files one document against two requirements is working from a snapshot.
The electrical safety report
The electrical safety document is the first request. It covers the cell or the pack against a defined test method, and it states how the cell behaved under the specified conditions. A buyer should ask whether it was produced at the cell level or at the pack level, and should treat a cell-level report as covering the cell and not automatically the assembled pack.
The report is issued for a cell or a pack and for a specific product. A buyer who changes the cell chemistry, the capacity, the protection board or the casing changes the product and should ask whether the report still applies. The report belongs to the pack as designed, and the pack as designed is the product the buyer is quoting.
The report is also a document that can be superseded. A test method can be revised, and a report issued against an earlier revision may not describe the current one. A buyer should ask when the report was issued and against which revision, and should ask the supplier to say when a change to the method re-opens the document.
The battery regulation obligations
The battery regulation obligations fall on the product and are phased. Some concern the label: the marking that identifies the battery, the chemistry and the required information. Others concern the design: whether the pack can be removed or replaced by the user, and whether the design supports the collection and recovery obligations. Others concern the party that places the product on the market and the due diligence that party is expected to perform.
A buyer should ask which obligations apply to the product as it will ship, and whether each is in force for the intended market at the time of shipment. A phased obligation can land between a quotation and a shipment, and a buyer who confirms only at quotation time is confirming a snapshot.
The removability question is the one that most often changes the design. A pack that is sealed into the housing is easier to assemble and harder to replace, and the obligation to make the pack removable can re-open the housing design, the tooling and the packaging. A buyer who asks the removability question in the first round learns the cost of the answer before the tooling is committed.
What to request from each obligation
| Obligation | What it asks for | What a buyer should verify |
|---|---|---|
| Electrical safety report | The cell or pack tested against the method | Level, product covered, and revision issued against |
| Battery label | The marking on the pack and the housing | Whether it matches the product as it ships |
| Removability | Whether the pack can be removed or replaced | Whether the design supports it, and at what cost |
| Due diligence | The process the placing party must perform | Whether the supplier performs it and can evidence it |
| Collection and recovery | The take-back and recovery obligation | Whether the buyer inherits it, and how |
| Effective date | When each requirement takes effect | Whether the obligation is in force at shipment |
Ask for the rows, not the summary. A supplier who can fill each row has both the document and the design answer. A supplier who can only describe the framework in general terms has neither.
An electrical safety report ≠ a battery regulation file
The boundary to state plainly: an electrical safety report is not a battery regulation file. The first is a test report on the cell or pack; the second is a set of product-level obligations covering the label, the design and the placing party. A buyer who files one against the other is filing a mismatch, and the mismatch is discovered when the shipment or the listing is reviewed.
A second boundary: a current report is not a permanent one. The report is issued against a revision of the test method and can be superseded, and the buyer should file the date and the revision. The same discipline is applied to the test summary that supports the transport side, as set out in UN38.3 test summary: the four checks.
A third boundary: a regulatory file is not a substitute for the disposal path. A pack that leaves the product still needs a disposal route, and the obligation moves from the product file to the waste side. Disposing of lantern batteries safely covers that route, and [emergency backup lighting](/insights/emergemergency backup lightinge must carry.
Five questions for the supplier
- What electrical safety document is offered, at which level was it performed, and which revision of the method does it cover? The three answers are separate.
- Does the report cover the pack as it will ship, and does a change to the cell or the protection board re-open it? Coverage is a claim about the product.
- Which battery regulation obligations apply to the product in the intended market, and which are in force at the time of shipment? The phased obligations are the risk.
- Can the pack be removed or replaced, and what does that cost in tooling and assembly? Removability can re-open the housing design.
- Does the supplier perform the due diligence expected of the placing party, and can that be evidenced in the file? The obligation belongs to the party that places the product.
Next step
Request the electrical safety report with its level and revision, and request the battery regulation file with the effective dates for each obligation. Keep them in separate files, and revisit the effective dates before each shipment. Related reading: CE, FCC and UKCA for the market file framework that sits beside the battery obligations. To apply this to a live sourcing project, start at contact.
Part of the Lumizuno outdoor-lighting notes. Illustrative values only; lumens and ingress ratings must be read with their test conditions.