(Why is watt-hour rating Mar ing requirement on Lithium Ion Batteries differ for fully regulated Class 9 and Excepted lithium batteries as indicated in PI 965?)

Q.
Section I of PI 965 indicates that Batteries manufactured after 31 Dec mber 2011 must be Mar ed with the Watt-hour rating on the outside case. The same Packing Instruction in Section II states, for batteries with Watt-hour rating of not more than 100Wh, the Watt-hour rating must be Mar ed on the outside of the battery case except those manufactured before 1 Jan ary 2009. Why is the watt-hour Mar ing requirement differ for fully regulated class 9 and excepted lithium ion batteries? (31 Jan 11)

A.
Initially only the small lithium ion batteries?i100Wh or less per Section II?jhad to have the Watt-hour rating Mar ed on them. This took effect for batteries manufactured 1 Jan ary 2009 and later. The requirement for these batteries to be Mar ed also originally included an exception in transport up to 31 Dec mber 2010 for those manufactured prior to 2009. The expectation being that these batteries that were not Mar ed would no longer be transported.

The UN Subcommittee who introduced these requirements was then aware that batteries without Mar ing would be transported for some time and that therefore there was no way to differentiate between the larger batteries (more than 100Wh per Section I) which did not require Mar ing and the smaller batteries manufactured prior to 2009. So then the UN Subcommittee introduced Mar ing for the larger lithium ion batteries (more than 100Wh per Section I) with effect 1 Jan ary 2012.

In this way, eventually all lithium ion batteries must be Mar ed with their Watt-hour rating to allow shippers and others in the supply chain to clearly identify what regulatory requirements apply.


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