How Can the Confusion About the
Battery Definition be Overcome?
Dr. Thomas Dittrich
Team leader JMT 18
Transport safety of lithium cells and batteries
IEC TC35/SC21A
IEC (Dittrich) UN Informal working group on large lithium batteries, Washington, 2014-09-29
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Outline - Battery Definition
 DGAC proposal
 Battery Definition UN vs. IEC
 Why did the UN change the battery definition?
 Can the DGAC proposal overcome the confusion?
 How can confusion be overcome with a harmonized
battery definition?
 Other sources of confusion
 Summary
IEC (Dittrich) UN Informal working group on large lithium batteries, Washington, 201409-29
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Battery Definition – DGAC Proposal
 The DGAC proposes to include the definitions for
“lithium cell”, “battery” and “single cell battery” in the
Model Regulations
 These terms are now only defined in the Manual of
Tests and Criteria
 Consignors must understand the difference between
a cell and battery in order to comply with the
exceptions provided in SP 188
 Common consignors do not generally acquire or have
access to the Manual of Tests and Criteria
Source: UN working document ST/SG/AC.10/C.3/2014/90 (46th SCETDG)
IEC (Dittrich) UN Informal working group on large lithium batteries, Washington, 201409-29
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Battery Definition – UN vs. IEC
UN Manual of Tests and
Criteria
Battery definition
See
Rev. 1
Rev. 2
Rev. 3
Rev. 3, Amend. 1 - 2002
...means one or more cells ...
Rev. 4 - 2003
...means one or more cells ...
Rev. 5 - 2009
...means one or more cells ...
Slide 27
Rev. 5, Amend. 1 - 2011
...means two or more cells ...
Slide 28
IEC International
Electrotechnical
Vocabulary or IEV
Battery definition
IEC 60050, 482-01-04
Publication date: 2004-04
...means one or more cells ...
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Slide 29
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Why did the UN change
the battery definition?
The current definition in Section 38.3.2.2 stated that
“Battery means one or more cells which are electrically
connected together ----- “. While this definition is
consistent with the reality that single cell is used as a
“battery” in many applications, it causes the difficulty
and confusion with regards to implementation of testing
requirement for cell and battery. The current definition
for battery is also inconsistent with the definition of “cell”
given in Section 38.3.2.2. In fact the explanation given
in the definition of “cell” implies that a single cell shall be
treated as “cell” not “battery”.
Source: US proposal to the U.N. Lithium Battery Informal Working Group, 3rd Meeting, Nov. 9 – 11, 2009, Kyoto, Japan
IEC (Dittrich) UN Informal working group on large lithium batteries, Washington, 201409-29
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Battery Definition – Can the DGAC
Proposal Overcome the Confusion?
 No. The UN battery definition is not helpful, because
 Consigners do not normally know the number of cells in a
battery
• Consigners can refer to manufacturers‘ data sheets which will most
likely be based on the IEC definition
• Consigners can refer to what is written on the battery
 Consigners will be confronted with a conflicting battery
definition in „reality“ (term used in the Kyoto US proposal)
 The UN definitions for „cell“, „battery“ and „single cell
battery“ are confusing in themselves.
 The UN definitions state that a „single cell battery“ is a
„cell“, not a „battery“. Such a terminology is not self
consistent and will always remain confusing.
IEC (Dittrich) UN Informal working group on large lithium batteries, Washington, 201409-29
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Battery Definition – Can the DGAC
Proposal Overcome the Confusion?
The term „BATTERY“ is used on „cells“
IEC (Dittrich) UN Informal working group on large lithium batteries, Washington, 201409-29
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Battery Definition – Can the DGAC
Proposal Overcome the Confusion?
What looks like a „cell“ is a battery (here comprising 2 cells)
IEC (Dittrich) UN Informal working group on large lithium batteries, Washington, 201409-29
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Battery Definition – Can the DGAC
Proposal Overcome the Confusion?
Multilingual IEC definition readily available in „Electropedia“
IEC (Dittrich) UN Informal working group on large lithium batteries, Washington, 201409-29
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How can confusion be overcome
with a harmonized battery definition?
 Model Regulations, Rev. 18:
 Special Provision 188 b)
For a lithium metal or lithium alloy battery the aggregate
lithium content is not more than 2 g, and for a lithium ion
battery, the Watt-hour rating is not more than 100 Wh…
Add: Each component cell of a battery shall not exceed the
limit for a cell.
 Special Provision 188 f)
or no more than four cells installed in equipment
Add: or single cell batteries
or no more than two batteries installed in equipment
Add: multicell
IEC (Dittrich) UN Informal working group on large lithium batteries, Washington, 201409-29
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How can confusion be overcome
with a harmonized battery definition?
 Manual of Tests and Criteria, Rev. 5 Amend. 1:
 38.3.2.3
Battery means two or more cells which are electrically
connected together and fitted with devices necessary for use,
for example, case, terminals, marking and protective devices.
A single cell battery is considered a "cell" and shall be tested
according to the testing requirements for "cells" for the
purposes of the Model Regulations and this Manual (see also
the definition for "cell").
Replace “two or more cells” with “one or more cells”.
Delete “A single cell battery is considered a "cell" …”
IEC (Dittrich) UN Informal working group on large lithium batteries, Washington, 201409-29
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How can confusion be overcome
with a harmonized battery definition?
 Manual of Tests and Criteria, Rev. 5 Amend. 1:
 38.3.2.3
Cell means a single encased electrochemical unit (one
positive and one negative electrode) which exhibits a voltage
differential across its two terminals. Under the Model
Regulations and this Manual, to the extent the encased
electrochemical unit meets the definition of "cell" herein, it is
a "cell", not a "battery", regardless of whether the unit is
termed a "battery" or a "single cell battery" outside of the
Model Regulations and this Manual.
Delete “Under the Model Regulations and this Manual, to the
extent the encased electrochemical unit meets the definition
of "cell" herein, it is a "cell", not a "battery", …”
IEC (Dittrich) UN Informal working group on large lithium batteries, Washington, 201409-29
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How can confusion be overcome
with a harmonized battery definition?
 Manual of Tests and Criteria, Rev. 5 Amend. 1:
 38.3.2.3
Single cell battery means a single electrochemical unit fitted
with devices necessary for use, for example, case, terminals,
marking and protective devices.
Delete this definition or replace it with the following one:
Single cell battery means a battery with one component cell.
If considered necessary, add the following definition:
Multicell battery means a battery with two or more component
cells.
IEC (Dittrich) UN Informal working group on large lithium batteries, Washington, 201409-29
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How can confusion be overcome
with a harmonized battery definition?
 Manual of Tests and Criteria, Rev. 5 Amend. 1:
 38.3.3 (a) …
(i) ten cells in undischarged states;
(ii) ten cells in fully discharged states;
(iii) four small batteries in undischarged states;
(iv) four small batteries in fully discharged states;
(v) four large batteries in undischarged states; and
(vi) four large batteries in fully discharged states.
Replace “cells” with “cells or single cell batteries”
Replace “batteries” with “multicell batteries”
IEC (Dittrich) UN Informal working group on large lithium batteries, Washington, 201409-29
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How can confusion be overcome
with a harmonized battery definition?
 Manual of Tests and Criteria, Rev. 5 Amend. 1:
 38.3.3 (b)
same change as in 38.3.3 (a)
 38.3.3 (c)
no change required
 38.3.3 (d) When testing rechargeable batteries or
rechargeable single cell batteries under test T.7, the following
shall be tested in the quantity indicated:
Delete “or rechargeable single cell batteries”
Batteries not equipped with overcharge protection that are
designed for use only in a battery assembly, which affords
such protection, are not subject to the requirements of this
test.
This paragraph was not changed when the UN changed the
battery definition. Therefore, it may have changed its
meaning.
IEC (Dittrich) UN Informal working group on large lithium batteries, Washington, 201409-29
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Other sources of confusion
 Manual of Tests and Criteria, Rev. 5 Amend. 1:
 38.3 Lithium metal and lithium ion batteries
The title of chapter 38.3 and, in fact, the proper shipping
names of UN 3090, 3091, 3480, 3481 may be less confusing
if the term “batteries” does not exclude single cell batteries.
If the battery definition cannot be changed then it may have
to be considered to change the title of chapter 38.3 and the
proper shipping names so as to replace “batteries” with “cells
and batteries”. However, the IEC proposes rather to
harmonize the battery definition.
IEC (Dittrich) UN Informal working group on large lithium batteries, Washington, 201409-29
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Other sources of confusion
 Manual of Tests and Criteria, Rev. 5 Amend. 1:
 38.3.2.3
Large battery means a lithium metal battery or lithium ion battery
with a gross mass of more than 12 kg.
This definition was not changed when the UN changed the battery
definition.
Large cell means a cell with a gross mass of more than 500 g.
This definition was changed when the UN changed the battery
definition. However, it seems not to harmonize with the Large
battery definition. Also consider the following definitions:
Small battery ...
Small cell ...
IEC (Dittrich) UN Informal working group on large lithium batteries, Washington, 201409-29
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Other sources of confusion
 Manual of Tests and Criteria, Rev. 5 Amend. 1:
 38.3.3 (e)
no change required. But the mentioning of cells and,
separately, component cells may be redundant
 38.3.3 (f) When testing a battery assembly …, that is
assembled from batteries that have passed all applicable
tests …
This paragraph was changed when the UN changed the
battery definition. Therefore, it may require consideration.
IEC (Dittrich) UN Informal working group on large lithium batteries, Washington, 201409-29
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Other sources of confusion
 Manual of Tests and Criteria, Rev. 5 Amend. 1:
 38.3.3 after (f)
When batteries that have passed all applicable tests are
electrically connected to form a battery assembly in which the
aggregate lithium content of all anodes, when fully charged,
is more than 500 g, or in the case of a lithium ion battery, with
a Watt-hour rating of more than 6 200 Watt-hours, that
battery assembly does not need to be tested if it is equipped
with a system capable of monitoring the battery assembly
and preventing short circuits, or over discharge between the
batteries in the assembly and any overheat or overcharge of
the battery assembly.
This paragraph was not changed when the UN changed the
battery definition. Therefore, it may have changed its
meaning.
IEC (Dittrich) UN Informal working group on large lithium batteries, Washington, 201409-29
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Other sources of confusion
 Manual of Tests and Criteria, Rev. 5 Amend. 1:
 38.3.4 Procedure
Tests T.1 to T.5 shall be conducted in sequence on the same
cell or battery. Tests T.6 and T.8 shall be conducted using
not otherwise tested cells or batteries. Test T.7 may be
conducted using undamaged batteries previously used in
tests T.1 to T.5 for purposes of testing on cycled batteries.
No change required. However, if the battery definition is not
harmonized, it may be considered to add “and single cell
batteries” after “undamaged” and after “cycled”.
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Other sources of confusion
 Manual of Tests and Criteria, Rev. 5 Amend. 1:
 38.3.4.3.2 Test procedure
Cells and batteries are firmly secured to the platform of the
vibration machine without distorting the cells in such a
manner as to faithfully transmit the vibration. The vibration
shall be a sinusoidal waveform with a logarithmic sweep
between 7 Hz and 200 Hz and back to 7 Hz traversed in 15
minutes. This cycle shall be repeated 12 times for a total of 3
hours for each of three mutually perpendicular mounting
positions of the cell. One of the directions of vibration must be
perpendicular to the terminal face.
No change required, but “cell” may have to be replaced with
“cell or battery”
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Other sources of confusion
 Manual of Tests and Criteria, Rev. 5 Amend. 1:
 38.3.4.4.2 Test procedure
...
However, large cells and large batteries shall be
subjected to a half-sine shock of peak acceleration of
50 gn and pulse duration of 11 milliseconds. Each cell
or battery is subjected to three shocks in the positive
direction followed by three shocks in the negative
direction of each of three mutually perpendicular
mounting positions of the cell for a total of 18 shocks.
No change required, but “cell” may have to be
replaced with “cell or battery”
IEC (Dittrich) UN Informal working group on large lithium batteries, Washington, 201409-29
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Other sources of confusion
 Manual of Tests and Criteria, Rev. 5 Amend. 1:
 38.3.4.6.2 Test procedure – Impact (applicable to
cylindrical cells greater than 20 mm in diameter)
The sample cell or component cell is to be placed on
a flat smooth surface. A 15.8 mm ± 0.1mm diameter,
at least 6 cm long, or the longest dimension of the
cell, whichever is greater, Type 316 stainless steel
bar is to be placed across the centre of the sample.
No change required, but “or component cell” may be
redundant.
 Same in 38.3.4.6.3 and 38.3.4 6.4
IEC (Dittrich) UN Informal working group on large lithium batteries, Washington, 201409-29
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Summary
 The DGAC proposal cannot prevent confusion of
consigners
 Since 2011, the battery definitions of the UN and the
„Reality“ are not harmonized
 The UN had a reason to change the battery definition but
the same result could have been achieved by other
means – without causing confusion
 This presentation shows the changes (in red) that would
have had the same effect as the change of the battery
definition
 It also identifies (in green) potential conflicts created by
the change of definition as well as possible solutions.
IEC (Dittrich) UN Informal working group on large lithium batteries, Washington, 201409-29
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Thank you for your attention.
Any questions?
Battery Definition –
UN Manual Rev. 5
Battery means one or more cells which are electrically connected
together by permanent means, including case, terminals, and
markings.
NOTE: Units that are commonly referred to as "battery packs",
"modules" or "battery assemblies" having the primary function of
providing a source of power to another piece of equipment are for
purposes of these Regulations treated as batteries.
Cell means a single encased electrochemical unit (one positive and
one negative electrode) which exhibits a voltage differential across
its two terminals. Under these Regulations, to the extent the
encased electrochemical unit meets the definition of "cell" herein, it
is a "cell", not a "battery", regardless of whether the unit is termed a
"battery" or a "single cell battery" outside of these Regulations.
IEC (Dittrich) UN Informal working group on large lithium batteries, Washington, 201409-29
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Battery Definition –
UN Manual Rev. 5, Amend. 1
Battery means two or more cells which are electrically connected
together and fitted with devices necessary for use, for example,
case, terminals, marking and protective devices. A single cell battery
is considered a "cell" and shall be tested according to the testing
requirements for "cells" for the purposes of the Model Regulations
and this Manual (see also the definition for "cell").
NOTE: Units that are commonly referred to as "battery packs",
"modules" or "battery assemblies" having the primary function of
providing a source of power to another piece of equipment are for
purposes of these Regulations treated as batteries.
Cell means a single encased electrochemical unit (one positive and
one negative electrode) which exhibits a voltage differential across
its two terminals. Under these Regulations, to the extent the
encased electrochemical unit meets the definition of "cell" herein, it
is a "cell", not a "battery", regardless of whether the unit is termed a
"battery" or a "single cell battery" outside of these Regulations.
IEC (Dittrich) UN Informal working group on large lithium batteries, Washington, 201409-29
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Battery Definition – International
Electrotechnical Vocabulary (IEV)
battery
one or more cells fitted with devices necessary for use, for example
case, terminals, marking and protective devices
cell
basic functional unit, consisting of an assembly of electrodes,
electrolyte, container, terminals and usually separators, that is a
source of electric energy obtained by direct conversion of chemical
energy
component cell, single cell battery, multicell battery
Note:
these terms have no definitions but are self-explanatory
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