Removability of Pouch cells (soft cells) embedded within Electrical and Electronic Equipment. A position paper prepared by RECHARGE aisbl. Introduction. On 23 April 2013, the EU Parliament, the Council and the Commission informally agreed on a revised text of article 11 of the Batteries Directive, dealing with the removability of batteries from appliances. The revised wording of article 11 requires appliances to be designed to allow for removability of the battery either by the end-user or by independent qualified professionals. In this paper we outline why it is of critical importance that the removal of batteries not intended to be removed by end-user, is performed by qualified professionals in order to ensure product and consumer safety. Additional justification can be found in Annex 1. Summary The end user removal of pouch cell (Lithium-Ion) embedded batteries creates a safety risk which has not been anticipated by several Regulations, and should not be encouraged by giving out removability instructions to end-users as it would conflict with the intent of the law: Technical standards guard end-users from hazards during the use of the complete equipment, but do not cover safety issues linked to the handling of individual parts taken from that equipment. The shipment of waste Lithium-Ion batteries are regulated as Dangerous Goods for Transport by the United Nations and National Transport Regulations which requires an appropriate level of training from the shipper. The General Product Safety Directive (GPSD) requires the manufacturer to ensure that equipment put on the market is safe throughout its service life. The revised wording of Article 11 of the 2006 Batteries Directive adopted in Trialog in June 2013 by the Council, the EU Parliament and the Commission makes it clear that removal instructions should be provided to either the end-user or the independent qualified professional, depending on the design of the appliance. 1
1. Compliance with technical standards Specific safety standards apply to rechargeable batteries such as IEC/EN 62133: Secondary Cells and Batteries Containing Alkaline or Other Non-acid Electrolytes Safety Requirements for Portable Sealed Secondary Cells, and for Batteries Made from Them, for Use in Portable Applications. The equipment in which these batteries are deployed, they must be tested and certified compliant with the applicable safety standards before being placed on the market. Some examples are: Cordless Power Tools: International/EU harmonized standard IEC/EN 60745 Part 1. Information and Communication Technology Equipment (ICT equipment) such as mobile phones and tablets: International/ EU harmonized standard IEC/EN/UL/CSA/AS-NZ 60950-1, harmonized under the EU R&TTED and Low Voltage Directives. Audio Video Equipment such as personal music players (PMP): international/eu harmonized IEC/EN/UL/CSA/AS-NZ 60065. Whilst covering a diverse range of equipment, the primary focus of these technical standards is to ensure product safety guidance. They define the various requirements and test methods that manufacturers should use to ensure the legal presumption of conformity of the equipment with the essential requirements of the applicable safety related Directives, but do not cover individual parts taken from that equipment. The removal of the embedded batteries from equipment by a non-professional is not an expected or intended operation, and must be guarded against through appropriate user instructions. Therefore the protection of end users, as provided by the standards, will be circumvented if manufacturers are obligated to provide removability instructions to end users. Such standards do not provide for the exposure of consumers to unexpected hazards during disassembly of complex and professional products, including, but not limited to, cells offering non-protected poles and cells without mechanical protection from an external jacket. It must be noted that the technical design of pouch cells present several (environmental) benefits, such as lower resource consumption (smaller battery, smaller products, smaller packaging), lower overall product weight (i.e. lower environmental impact of transport), higher volumetric energy density and higher product and battery reliability. 2. The status of Lithium Batteries under the UN Transport Regulation of Dangerous Goods. In addition to the above, there is the added risk of safe storage, safe disposal and safe transport of the waste battery removed by end users. Transportation of Lithium batteries are regulated by the UN Model Regulation for the Transport of Dangerous Goods. Lithium batteries when shipped out of a manufacturing plant have to comply with basic requirements such as: - Testing for safety. - Packaging in accordance with the regulation. - Appropriate labeling. 2
The personnel responsible for the packaging, labeling and shipment of waste batteries need to be trained before the use of such transport regulations. The list of duties to secure safe transport of Lithium Batteries is described in the UN Model regulation and in the Manual of Tests and Criteria (see Table 1 below). When an end-user removes the pouch cell from equipment, this battery needs to be collected and transported to a facility, where it will be recycled in accordance with the Batteries Directive 2006/66/EC. Because pouch cells are easily damaged when handled incorrectly, it is essential they are removed and processed by qualified professionals in order to ensure safe processing and transportation. Typically, end users will be unaware of the Transport Regulation of Dangerous Goods requirement to correctly prepare the removed pouch cell for its safe collection and shipment even though such batteries are classified as Dangerous Goods. Instructions given to end users on how to remove such batteries from equipment will therefore create an additional level of hazard during storage, transport and in the end of life management of waste batteries. 3. The General Product Safety Directive. The EU General Product Safety Directive (GPSD) 2001/95/EC covers consumer products and obliges producers to only place safe products on the market (Art 3). Such safe product must be designed to be safe under 'normal or reasonably foreseeable conditions of use including installation and maintenance requirements and may not present any risk or only the minimum risks compatible with the product's use". The Directive s justification is that any risks for the health and safety of consumers must be prevented (preamble 6). Therefore, providing end-users with instructions on how to remove batteries which are not intended to be removed by them for safety reasons (i.e. to ensure safe removal and handling) is incompatible with the requirements of the GPSD. To provide such instructions, irrespective of any warnings, would create a foreseeable and unnecessary risk, contrary to the GPSD provisions. 4. The new text of Article 11 of the Batteries Directive. The revised wording of Article 11 makes a clear distinction between batteries intended to be removed by end-users and those intended to be removed by qualified professionals. This distinction reflects the acknowledgement by both the European Parliament and the Council of the fact that there are good (safety) reasons for certain integrated batteries to be removed by qualified professionals instead of end-users. (1) Where they cannot be removed by the end-user, Member States shall ensure that manufacturers design appliances in such a way that waste batteries and accumulators can be easily removed by qualified professionals that are independent of the manufacturer. Requiring producers to facilitate end users with the information on how to open such equipment, through the supply of battery removability instructions, would create an unjustified burden which is not mandated by the proposed text of Article 11. (2) Appliances into which batteries and accumulators are incorporated shall be accompanied by instructions how they can be removed safely by the end-user or by independent qualified professionals. 3
Above sentence (2) requires instructions to be provided to either end-users or independent qualified professionals. This sentence cannot be read and interpreted in isolation from the rest of Article 11, especially sentence (1). When reading the requirements together, as intended, it is clear that the requirement to provide removal instructions to end-users does not apply to the product range where the battery cannot be removed by the end-user. Additionally, it is not possible to provide end user instructions on how to safely remove embedded batteries, when it is not safe for unqualified persons to do so. 5. Conclusion The EU Parliament and the Council have recognized that there are good reasons (including, safety, reliability and environmental) for certain integrated batteries to be removed by qualified professionals instead of end-users. This is reflected in the first three sentences of Article 11, which must be read and interpreted together. It is clear, and logical, that manufacturers shall only provide technical battery removal instructions to end-users if the battery is intended to be removed by them. In all other cases such instructions should only be made available to qualified (independent) professionals. RECHARGE is of the opinion that end-users should not be incentivized to remove a non-end user removable battery themselves, by providing them with technical removal instructions. Despite the inclusion of explicit warnings, providing such instructions would aid and abet users to do something which is potentially unsafe, in conflict with the above referenced standards and Directives, and would raise undefined liabilities. Manufacturers cannot recommend such practice while acting in compliance with the current EU legislation. RECHARGE aisbl Brussels, August 2013. For any additional information, please contact, Mr. J-P Wiaux, Director General, jpwiaux@rechargebatteries.org or Mr. C. Chanson, cchanson@rechargebatteries.org www.rechargebatteries.org 4
ANNEX 1: technical information about Li-ion pouch cells. The continuous technology development process in Li-ion batteries has considerably improved the performances of this rechargeable battery technology over the last 10 years. In particular, it has allowed for the doubling of the energy content for a given weight (energy density in Wh/kg) as shown in Figure 1. Similar improvements have been made with respect to volume (energy density in Wh/liter) as well as a significant increase of the number of charge cycles, all of which translate into critical improvement of battery lifetime. This key performances characteristic has made Lithium-Ion battery the technology of reference for all portable electronic devices: mobile phones, laptops, tablets, MP3 players, etc... both for the consumer and the professional markets. Evolution of the cell design. Improvements in battery cell performance is linked to both the active materials and the cell technology optimizations, including the outer casing. As shown in Figure 2, Lithium-Ion batteries are Figure 1: Batteries energy density improvements 1970-2010 manufactured with a solid external casing (Figure 2 a) as well as with a soft external casing, offered on the professional market as a so-called pouch cell (Figure 2 b). In the latter, the outer casing consists of a thin layer of Plastic/Aluminium laminate film, welded around the electrochemical stack. The Pouch Cell battery is widely used in portable electronic devices, because of its higher energy density, smaller form factor and its capability to adapt to the geometry of the appliance. This battery design allows products into which they are incorporated to be compact, highly durable, highly reliable and to have a long battery life. Currently, Pouch Cell performance offered by major equipment manufacturers exceeds the anticipated useful life of the product they are embedded in Figure 2 a Figure 2 b Figure 2 : Illustrations of the prismatic Lithium-Ion cell with a hard outer casing (2 a) and of the Pouch Cell with a soft outer casing (2 b). 5
The success of highly portable electronic devices has confirmed the demand for the Pouch Cell technology. This technology is now also used in batteries for Electric Vehicles. In addition to the usual battery protections against water and humidity, electrical shorts, contacts corrosion or high temperature exposure, etc. the use of the soft external casing requires more specific precautions: - External mechanical protection: the casing can be easily deformed or torn. In this case, there is a risk of electrolyte leakage, and possible fire risks, in case of sparks, hot spot or short-circuits point. For this reason, Pouch Cell batteries are intended to be placed inside an appliance, where the appliance itself forms the protective outer casing. - Homogeneous pressure during handling: local pressure on the stack, such as a finger print, can create a heterogeneous ageing of the active materials due to variations in the distance between electrodes: this will reduce significantly the life duration of the battery. For this reason, the cells have to be handled with care by trained professionals, avoiding local pressure leading to an uneven distribution of active material in the cell. - Cells design and safety: due to absence of rigid outer casing and battery contact protection (necessary for end user replaceable batteries) embedded batteries need care when removed of the equipment. The removal of the battery is expected to be performed by a professional, at the end of life of the product, during the sorting or the recycling process. - Disposal: For the same reason, embedded pouch cells need to be handled with care for disposal. It is not recommended to mix these products with other consumer collected batteries, as there is a risk of short-circuit, electrolyte leakage or fire, if not packaged properly. 6
TABLE 1. Basic requirements for the transport or disposal of Lithium-Ion Pouch cells. Pouch Cell (Li-Ion) removed from EEE or WEEE (< 20Wh/cell) UN CLASSIFICATION (SP & PI) TECHNICAL REQUIREMENTS PACKAGING REQUIREMENTS MARKING REQUIREMENTS Training of qualified personnel before shipment and packaging Shipped UN 3480 Lithium-Ion Batteries SP 188 UN 3480 SP 377 = Waste Lithium ion Batteries and P909 Lithium ion Batteries Transported for Disposal or Recycling UN3480 SP 376 = Damaged and Defective Lithium ion Batteries and P908 1. Tested under UN 2.9.4 and MTC 38.3. 2. Individual Protection against Short Circuit 3. < 30 kg Gross mass 1. Exempt from testing requirements. Diagnosis by qualified personnel (with knowledge of the MTC & UN 2.9.4) before packaging UN United Nations MTC Manual of Tests and Criteria SP Special Provision PI Packaging Instruction (*) Including Lithium ion Polymer Batteries Inner packaging with protection against Short Circuits + Strong outer packaging 1. Cells shall be design or packed to prevent Short Circuit 2. Strong Outer packaging up to 30 kg 1. Inner packaging inside of an outer packaging 2. Packing Group II Performance Level packaging 3. ee P908 for additional packaging requirements Lithium-Ion Battery Handle with care Flammable Label Tel. Nb 1. Lithium Batteries for Disposal (Or Li Batteries for Recycling) 2. Must be marked and labelled for shipping as Class 9 Dangerous Goods 1. Damaged/ Defective Lithium- Ion Batteries 2. Must be marked and labelled for shipping as Class 9 Dangerous Goods 7