A shipment of rechargeable battery packs can raise two different questions. The importer needs to know what is required to sell the packs in Russia or another EAEU market. The shipper needs to know how those exact packs can be carried, including whether they will travel separately, with equipment or installed in it. The answers can involve different documents, and both depend on the actual configuration.
Reestr Garant helps battery manufacturers, distributors and equipment suppliers establish a compliance route before they order tests, finalise labels or book the first shipment. The review can cover standalone cells, assembled packs, batteries sold as replacement parts and products supplied with an integrated battery.
Which product is being placed on the market?
Start with the item in the sale and shipment documents. A bare cell, a battery pack with a protection circuit, and an appliance supplied with that pack are different objects for review. List the chemistry, form, voltage and capacity, then identify the charge and discharge interfaces, safety features and intended equipment. For a replacement battery, include compatible models and the instructions supplied to the buyer.
TR EAEU 037/2016 restricts certain hazardous substances in electrical and electronic products within its scope. It expressly excludes electrical batteries and accumulators, including batteries placed on the market as part of electrical and electronic equipment. The finished equipment still needs its own scope check. When the order includes a separate mains charger, record its model and ratings as well so its requirements can be assessed independently.
The exclusion under one regulation does not resolve the battery's full route. Depending on the actual product, intended use and destination, the review may need to consider other product rules or national requirements. An industrial standby pack, a vehicle battery and a consumer replacement pack should be assessed from their intended application and sales configuration, even if they share a chemistry.
Transport evidence for cells, packs and equipment
Prepare a separate shipment description for the carrier or dangerous-goods adviser. Specify whether the batteries are shipped alone, packed with equipment, or contained in equipment. Include the transport mode, origin, destination, pack condition, number of units per package, method of protection against short circuit and relevant packaging details. A route with more than one mode can require checking each leg.
For lithium cells and batteries subject to subsection 38.3 of the UN Manual of Tests and Criteria, request the test summary for the actual cell or battery type. Compare the model identifiers, chemistry and capacity data on the summary with the item being shipped. Ask for the pack-level evidence where the applicable test requirements concern the assembled battery. A summary for a cell inside the pack cannot by itself establish that the pack is covered.
The transport test summary and the safety data supplied by the manufacturer serve different purposes. Collect both when available and give the transport specialist the packing configuration as well. A report on a normal production pack cannot settle how a damaged, defective, recalled or prototype unit should be shipped. Tell the specialist about such units before arranging transport.
Product labels, instructions and evidence for buyers
Check whether the marking on the item and packaging can be traced to the technical file. Confirm that the model, manufacturer, electrical ratings and pack configuration match the documentation. Review warnings, charging instructions, storage conditions and disposal information against the product and destination. Identify what must appear on the battery, on the retail packaging or in the accompanying instructions under the applicable rules.
Prepare the shipment markings separately. A dangerous-goods handling mark addresses transport, whereas any product conformity mark follows the requirements for placing the applicable product on the market. An existing foreign approval, international test report or transport document can be useful evidence if it covers the exact model and the procedure accepts it. Check those conditions before copying a mark or releasing new artwork.
Information to send for a first review
- A datasheet for each cell, pack, charger and finished product in scope. Include chemistry, form, voltage, capacity and energy rating where applicable.
- Photographs of the battery, packaging and labels. Add model and revision identifiers for the cells, pack and equipment.
- A description of the cell configuration, protection circuit, connectors and compatible charger. Identify any changes between versions sold under the same commercial name.
- Available safety information, test reports and UN test summaries. Include attachments identifying the tested product and the construction or revision it represents.
- Sales and shipment configuration, including whether batteries are installed, sold separately or included as spares. State the transport modes, destination and condition of the units.
What the review delivers
We separate the sale, shipment and documentation questions, then identify which product or configuration each one concerns. The initial review records the likely product requirements and what needs to be checked with a carrier, assessment body or laboratory. It also identifies mismatches that could delay an order, such as a label using a retail model number while the only test report refers to an earlier engineering sample.
After the scope is agreed, we can help organise the technical file, review labels and coordinate evidence collection. Keep a version record when the supplier changes a cell source, protection circuit, pack capacity or case design. That record helps the responsible parties decide whether existing evidence still applies before the next shipment goes out.
What changes the quotation?
We quote after seeing the number of battery constructions, chemistries, supplied accessories and shipment configurations. Reviewing one pack with a complete, traceable report set is different from classifying a family of packs with several cell suppliers and different transport routes. The scope also depends on whether you need label or instruction review, missing evidence, translation or coordination of new tests. Send the datasheet and one proposed shipment configuration to start.
Frequently asked questions
Do all batteries need an EAC certificate?
There is no single certificate route for every battery. Check the specific item, intended application and destination, then assess any equipment or charger in the order separately.
Does TR EAEU 037/2016 cover the battery inside a device?
The regulation excludes electrical batteries and accumulators, including when supplied as part of electrical or electronic equipment. The finished device still requires its own scope and evidence review.
Can a UN 38.3 test summary be used as a document for retail sale?
The summary records transport test information for the relevant cell or battery type. The requirements for placing the actual product on the destination market are checked separately.
What should we check after changing the cell supplier?
Record the cell and pack revisions, the technical changes and the configuration covered by the current reports. Ask the relevant testing and transport specialists whether existing evidence still covers the changed pack before shipping it.
Compare the certificate and declaration routes and check what evidence applies to your product.