BA Guide – Electric Bike Batteries

Transportation
Sourcing & producer responsibilities

BA Guide to electric bike batteries – introduction

The fast-growing e-bike industry in the UK handles large
numbers of relatively high-capacity lithium batteries, and
there is a need for clarity about the regulations and best
practice involved in their procurement, transport, handling
and, eventually, disposal and recycling.

We will first provide guidance on storage and handling
best practice, which will be relevant to all levels of the
supply chain.

Then we will look at “producer obligations”, which mainly
affect importers but have implications for retailers.

Next we examine the requirements for safe transport of
both separate batteries and e-bikes under the Dangerous
Goods regulations. As part of this we will explain some
common transport scenarios relevant to the e-bike
industry.

Finally we’ll look at best practice for suppliers in sourcing safe batteries, and at the obligations (mainly around waste batteries) which apply to anyone placing batteries on the UK market (typically importers).

It is important to note that much of the other advice available online about transport of lithium batteries (for power tools, laptops, etc.) concerns different rules, which apply to smaller batteries with a capacity below 100 Wh. As far as we are aware, all current e-bike batteries exceed this capacity (300 to 700 Wh is more typical). Also, note that no ‘limited quantity’ or ‘excepted’ rules apply to e-bike batteries, as they do for some smaller batteries.

About the BA Guides

The BA Guides are a series of concise documents aiming to offer definitive information on matters of interest to the UK cycle industry. BA Guides are available as free downloads on the Bicycle Association website for reference by the wider industry, media and general public, while more
detailed and specific material is reserved for Bicycle Association member companies.

This Guide was produced by the Bicycle Association Technical Service. Please note that the Bicycle Association Technical Service cannot give formal legal, financial or insurance advice. Any business or technical decision you may take based on our advice is entirely at your own risk. All information given, especially that related to regulations, laws etc., is a summary of our best understanding of what the law requires, but ultimately the interpretation of the law is a matter for the courts based on the individual facts of any particular case. You are therefore advised to consult the relevant legislation yourself and, if necessary, to seek independent advice on specific legal questions.

Storage and general safety advice

Other than general catch-all ‘duty of care’ provisions, we are
not aware of any legal requirements or official regulations
for storage of lithium batteries (although there is some insurance industry guidance, right).

E-bike batteries from reputable suppliers do generally have a high level of safety, unless mistreated, but there always remains some risk, and the consequences of a lithium battery fire can be very serious. Several such incidents involving e-bike batteries, and the total loss of buildings, have been reported. So it is worth taking practical measures to further minimise any fire risk.

We would note that used battery packs (which end users
may have mis-treated) and battery packs from unknown
suppliers where it is harder to be confident of good design
and proper testing, could potentially pose higher fire risks.

So all companies dealing with e-bikes and their batteries should make a risk assessment of their storage arrangements and make appropriate provision to minimise risks.

Also, we suggest that you consult and inform your insurers and the local emergency services if you store significant numbers of e-bike batteries.

Insurance resources

The insurance industry has produced a number of documents with handling and storage guidance – document RE2 is probably the most relevant:

Also potentially relevant are documents RC59 re battery charging and RC61 (older guidance on battery handling).

All of these can be downloaded for free here: https://www.thefpa.co.uk/advice-and-guidance/free-documents.

Key points from our understanding include:

  • Many brands and drive system suppliers will provide advice to retailers on the safe handling and storage of lithium batteries. We recommend retailers request this information from e-bike and drive system suppliers when being on-boarded with the brand, or ASAP if they have not already. For example, Bosch has issued guidance on the handling and storage of its electric bike batteries to approved dealers, and as a part of its ongoing training programme.
  • If possible, obtain dummy batteries from suppliers for display purposes and keep all ‘real’ batteries in a secure store until needed for test rides or sale. This also allows display bikes to be placed in direct sunlight – which might otherwise damage the batteries over time.
  • Lithium batteries should be stored in a well ventilated and cool place well away from other flammable and combustible materials.
  • Only charge lithium batteries when the premises are attended.
  • Keep a Class D extinguisher nearby, and/or dry sand, as in the event of a fire, it should be smothered with dry sand or covered with contents from a Class “D” fire extinguisher. The use of a Class “D” fire extinguisher is the preferred extinguishing method.
  • Avoid contact with water unless a lot of water is available. If large amounts are available it may slow down the reaction and can prevent burning cells from igniting neighbouring cells. Usually it will not completely extinguish the fire.
  • Do not use Halon extinguishers as toxic gases will be generated.
  • Even when the material has apparently burned and cooled, be prepared as it may re-ignite.

Additional guidance:

The BA also very much endorses the recommendations of the Fire Chiefs’ Council on lithium battery safety: https://www.nationalfirechiefs.org.uk/E-bikes-and-e-scooters-fire-safety-guidance. This covers aspects of charging, storage, and includes good advice for consumers about how to minimise risk when buying batteries.

London Fire Brigade also has much excellent advice as part of its #ChargeSafe campaign.

Human Powered Solutions from the USA has proposed a cycle industry specific best practice document detailing storage, charging and handling procedures, for retailers who wish to minimise risks by using a secure battery store. It is a free download here: https://humanpoweredsolutions.com/safe-lithiumion-
battery-storage-and-charging-procedures-forthe-ebike-shop/

Commercial solutions

At the time of writing we are aware of the following commercial offerings which may be of assistance to companies in the e-bike industry. Additional proposals or
suggestions are welcome: please contact the BA so they
can be added here:

  • Madison can supply a fire safe battery storage cabinet solution for electric bike batteries from Asecos. Details are here. Contact your Madison representative for more information.

Larger companies may already be part of a batteries compliance scheme: if so, this would generally be the first port of call for commercial storage and waste battery disposal solutions.

Collection service example

As an example of a commercial service, recycling operator Ecolamp has a solution available for retailers who may have a stockpile of faulty or end-of-life batteries within their business.

Ecolamp can dispatch a waste battery storage drum (either 30 litre or 60 litre) to the individual store. The store can then safely store batteries in this drum until such time they want a collection.

Both the 30 litre and 60 litre drums have a weight limit of 40 kg. Once a collection has been arranged and completed, Ecolamp will make a visual inspection to check the contents and weigh the drum for completion of a hazardous waste note.

Indicative pricing for a 60 litre drum (40 kg) is £179+VAT (as at October 2021). To obtain a quotation for this service please contact [email protected] or telephone
01925 230825 (www.ecolamp.co.uk)

Transportation of batteries and e-bikes – Dangerous Goods regulations

Lithium batteries with a capacity of above 100 Wh, as used on all e-bikes, are classed internationally as “Class 9 Dangerous Goods”.

Understanding the resultant legal obligations for transportation is complicated by the existence of separate regulations for shipping by air (IATA and IACO), road (ADR) and sea (IMDG). Individual courier companies sometimes also often seem to have their own requirements and interpretations.

This document will focus mainly on in-country transport,
principally by road. It uses information from the latest
ADR version, ADR 2023, which can be downloaded here, in two volumes: https://unece.org/transport/standards/transport/dangerous-goods/adr-2023-agreement-concerning-international-carriage

These regulations are aimed at protecting the vehicle drivers, other road users, and the general public and
wider environment from damage which could potentially be caused by the dangerous goods which are being transported.

The UK legal framework

In the UK, ADR is implemented as The Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 (as amended), often abbreviated to “CDG”.

The Health and Safety Executive has further guidance on these regulations here.

There are some variations in the regulations as they apply in Great Britain, compared to the international ADR regulations, and these are called “derogations”. These are detailed here.

There is also a helpful “document “CDG manual” about the application of these regulations here.

Note that private end users are exempted from all of these requirements.

Some basic concepts

UN38.3 battery testing

Almost all of the regulations insist that for legal transport batteries must be of a type which has passed UN 38.3 type testing (strictly, Part III, Sub-Section 38.3.1 of the UN Manual of Tests and Criteria, available here) and also some other basic requirements such as short circuit protection and manufacture under a quality management programme. These requirements are detailed in para 2.2.9.1.7 of ADR 2023 Vol 1 (page 247).

All reputable battery suppliers will provide proof of UN 38.3 type testing and related requirements, and it is advisable for importers and suppliers to retain documentation of this in the product’s Technical File, and they must make this evidence available to e.g. retailers on request.

The situation for batteries which have not passed UN 38.3 testing is more difficult. They cannot be shipped by air. If you discover such batteries (third party copies, perhaps) they would need to be shipped as defective/damaged, with stricter packaging rules (see below) as this does not require UN 38.3 compliance.

There are also provisions for small batch (<100) or prototype batteries which have not been UN 38.3 approved.

Packing Instructions

The ADR regulations specify a wide range of “packing instructions” (PIs) which give requirements for packaging – specifying both the materials used and the performance qualities (leak proof, etc.) of the packaging.

Also often specified is the maximum weight per
consignment and per ‘overpack’ – typically meaning pallet load. Only one overpack per ‘transport unit’ (truck and trailer) is permitted in normal circumstances.

Where “Packing Group II” is mentioned, this means that packaging to a UN-specified performance level must be used.

Packaging can be purchased which complies with
whichever requirements apply, with the types listed at the top of each packing code. e.g. UN/4G/Y30 for a max 30 kg package. Courier companies will often also supply suitable packaging.

For the PIs relevant to e-bike batteries, they specify that the batteries must be prevented from moving within the packaging, must be completely enclosed, and protected against short circuit. For the PIs to be used with damaged/defective batteries, the requirements are rather more extensive, including heat resistance, venting for gases and more.

UN codes
All of the air, sea and road regulations use a common coding system for Dangerous Goods, starting with “UN…”. The infographic below summarises some of the most common codes relevant to e-bikes and when they apply.

Shipping batteries and e-bikes – summary infographic (click to enlarge)

Transporting e-bikes with the batteries installed
There are a number of ‘special provisions’ relating to the UN3171 category, the upshot of which is that there are NO special packaging requirements for transporting e-bikes with the batteries installed. So they can be shipped in a normal bike box without any special labelling. This assumes that the battery type has been UN38.3 approved and manufactured. No transport document is required. However, it is recommended that the code “UN3171 BATTERY POWERED VEHICLE” be entered on the shipping docket so that the carrier is informed of the nature of the load (mainly because some UK couriers may, without your knowledge, use air or rail transport as part of their UK networks – not just road, which is what ADR covers).

Transporting e-bike batteries separately
As shown on the infographic above, the codes UN3480 (for separate batteries) or UN3481 (for batteries accompanying but not installed in the e-bike) will normally apply, approved packaging will be needed, and the Class 9 Dangerous Goods label must be shown. A transport document must also be completed.

Driver and vehicle requirements
If you are using your own company van to transport e-bikes or e-bike batteries then there are some requirements, but as long as the total weight of batteries is under 333 kg, a ‘small load’ exemption applies. The remaining requirements are:
– General training for driver
– A record should be kept
– Carry one 2 kg dry powder fire extinguisher or equivalent
– Stow the dangerous goods properly.
There is no requirement for external vehicle marking, but it is also not prohibited, and could help emergency esponders assess risk in the event of an accident (although some dispute this, suggesting that for small loads especially, it may cause unnecessary escalation of a response). Magnetic 100 mm diamond-shaped hazard signs (Class 9A, as pictured above) would be (optionally) appropriate for a vehicle carrying e-bike batteries. But any such signs MUST be removed when no dangerous goods are being carried.

Incident reporting
You are obliged to report any incidents involving dangerous goods to the Environment Agency in the first instance, and to the police if in a traffic situation.

Document retention
– Transport documents: 3 months
– Training records: one year after employee’s last employment
– DGSA annual report (see below): 5 years.

Dangerous Goods Safety Advisor: do you need one?
There is a requirement in ADR that if you ship batteries regularly from your premises then you must have a “Dangerous Goods Safety Advisor” (DGSA) to do the shipping and complete the transport documentation. However, there are certain exemptions from this requirement, some of them UK specific. Government guidance here indicates that for carriage activities related to ‘small loads’ (in this case, 333 kg or less) this requirement does NOT apply.

However, ADR (1.3.1) does still require “training commensurate with the duties and responsibilities” of the roles involved, and if shipping batteries is more than an occasional matter in your business, having a member of staff qualified as a DGSA is recommended.

Transport and shipping scenarios

Exempt from ADR requirements as a ‘battery powered vehicle’ so no external labelling is required. This assumes that you are sure the parcel will go by road only – it has been suggested that some UK couriers may use airfreight for domestic journeys. So it is advisable to mention "UN3171 BATTERY POWERED VEHICLE" on the waybill.

The sender will need the UN approved packaging for PI 903, need the Class 9 label, and to provide the shipper with a transport document. Max consignment weight 30 kg. If ‘overpacked’ with other consignments, max weight per truckload is 333 kg before extra measures need be taken. Note that particular couriers may have their own additional requirements - always confirm with the particular company
used! Note also that the person handling the shipment should have (documented) “training commensurate with the duties and responsibilities” involved in this shipment, or be a qualified DGSA.

The retailer will need the UN approved packaging for PI 903, need the Class 9A label, and to complete a transport document. Note also that the person handling the shipment should have (documented) “training commensurate with the duties and responsibilities” involved in this shipment, or be a qualified DGSA.

No requirements for the bike (or box, if it is in one), so long as the battery is UN38.3 compliant and total battery weight is less than 333 kg.
The driver needs to be appropriately trained, must have a 2 kg dry powder fire extinguisher with them, and the bikes must be stowed securely.

No requirement for the e-bike with battery installed – it can just go in the van, so long as the battery is definitely UN38.3 compliant. For the batteries, despite the retailer carrying out the role of both consigner and shipper, we understand that a Transport Document should still be carried with the vehicle. The batteries should also be packaged according to the P903 requirements. As the dealer will be under the small load threshold of 333 kg, the only remaining requirements are that the driver needs to be trained, must have a 2 kg dry powder fire extinguisher with them, and the bikes and batteries must be stowed securely.

Collection should normally be arranged by the distributor or importer who originally placed the battery on the UK market, under their take-back and proper disposal obligations. They will generally employ a specialist carrier. If shipping it themselves, the retailer will need the UN approved packaging for PI 908 and follow its requirements, need the Class 9A label, and a transport document. The person handling the shipment should have (documented) “training commensurate with the duties and responsibilities” involved in this shipment, or be a qualified DGSA.

Sourcing & producer responsibilities

An e-bike battery ‘producer’ (i.e. the company who first
places a battery on the UK market, which would normally
be the importer, typically an e-bike brand or distributor)
has obligations to report, take back and properly dispose of
batteries.

These obligations would not normally apply to retailers or
others in the distribution chain unless they are also the
importer.

Under these regulations, e-bike batteries are classed as
“Industrial”, as specifically mentioned in this guidance.

Producers must register within 28 days of first placing batteries on the UK market. Registration is via the National Packaging Waste Database. Producers must provide the total tonnage, chemistry and brand name of industrial batteries placed on the market by 31 March in the following year (more frequently for some larger companies).

Producers also have a respoonsibility to:

  • Take back waste industrial batteries free of charge
    from any end-user, if they supply them with new
    batteries, if they’re the same chemistry as batteries
    you place on the market or if they cannot be
    returned to another producer
  • Tell end users how they can return waste industrial
    batteries, for example through information on their
    website
  • Ensure that waste batteries go to an Approved
    Battery Treatment Operator (ABTO) or an Approved
    Battery Exporter (ABE) for treatment and recycling.

Because of the reference to ‘end users’, the ‘take back’ obligation is widely understood to apply through retailers: if a retailer sells an importer’s e-bikes, then the importer should make arrangements (at their cost) to take back end of life batteries from that retailer. This would normally be handled by a third party battery collection company commissioned by the producer (importer), who would provide suitable packaging and receptacles, give training to the dealers in proper handling, and arrange collections when required.

The BA is developing a national e-bike battery collection and processing scheme which will be free to retailers. For the latest updates, please see here or contact us.

Sourcing e-bike batteries

More detailed guidance on how manufacturers and importers can best source safe and high-quality batteries is available for BA members via the technical service, but here are a few basics:

– Choose a reputable supplier!

– Obtain credible evidence of UN38.3 certification

– Additionally, request evidence of compliance with the battery testing requirements of EN15194:2017

– Ideally batteries should also comply with EN50604 as amended in 2022 (it’s a standard specifically for light electric vehicle batteries)

– Otherwise, good evidence of safety can come from evidence of compliance with EN 62133-2, as amended in 2021, which is a standard for any portable battery.

“Portable” batteries
Propulsion batteries for e-bikes are classed as “Industrial” – as explicitly stated here. But other batteries that are handled within the cycle industry – for e.g. gear change systems, lights or computers, will be classed as “portable”, for which different requirements apply at producer, distributor and retailer levels. We will not consider these further in this document, but guidance on obligations re portable batteries is here for producers and here for distributors and retailers