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The appearance of new lithium battery-powered scooters on city streets around the world has focused attention on safety.
All the column inches centre on the danger posed to pedestrians and other road users by these new machines hurtling around at 25-35 kph (about 15-20 mph).
However, moving the scooters also presents a range of challenges to manufacturers, distributors, retailers and consumers, as they fall within the scope of dangerous goods regulations, if transported with a battery.
Once again, consignors are faced with navigating their way through complex and frequently changing lithium battery rules – the most misunderstood and often ignored areas of the regulatory landscape.
The United Nations Committee of Experts is responsible for the classification of dangerous goods, and a powered scooter falls under UN 3171 battery-powered vehicle.
Although a UN 3171 can be moved by air, road, sea, rail and inland waterway, the regulations then diverge, although all the modes classify UN 3171 within Class 9 Miscellaneous Dangerous Substances and Articles.
If the scooter is despatched by air freight and is packed for its protection, it will require hazard labelling and the completion of a shipper’s declaration. Under the IMDG Code (sea) and ADR (road), there are certain exemptions from marking, labelling and placarding, but the dangerous goods note will be needed in most cases for sea shipments.
The scooter might travel with its battery installed, or the battery might be packed with the scooter. In the latter case, it is possible that the classification changes to UN 3481 lithium-ion batteries packed with equipment. These entries come with eight special provisions for air freight and nine for road and sea.
The rechargeable lithium ion scooter batteries are generally in excess of 100 watt hours (Wh) and many special provisions only apply for these more powerful batteries, including the requirement for UN-tested packaging, as well as many of the labelling and documentation regulations which differ between modes.
There are strict regulations for the production and testing of lithium batteries, and these have been developed in response to the large number of counterfeits which have been responsible for numerous serious incidents, including fires and some fatal accidents.
Batteries must be manufactured under a quality management programme, and have to be tested in accordance with the UN Manual of Tests and Criteria. This testing can be a long and expensive procedure, but ensures that the batteries meet all the safety regulations. Manufacturers and distributors must have available a test summary which is a confirmation that the batteries meet the required standards.
Many suppliers also sell replacement batteries for the scooters, and these are classified as UN 3480 lithium-ion batteries. The restrictions for air freight are the most severe; they can only travel on cargo aircraft and, as many of these scooter batteries are more than 100 wH, they need UN-tested packaging and are fully regulated for transport.
There still remains the problem of the disposal of used batteries, which can be shipped for disposal or recycling, but the regulations for these differ from those for batteries that are damaged or defective and might disassemble or dangerously react during transport.
The arrival of these scooters throughout the world is undoubtedly an opportunity for entrepreneurs, but they need to familiarise themselves with the regulatory framework to ensure they can supply their customers safely.
Nicholas Mohr is CEO of Peter East Associates Ltd, a leading provider of live lithium battery and dangerous goods webinars. www.petereast.com. +44 (0)20 8953 6721.
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