Import and Export Inspection and Supervision-Lead Acid Battery

 

The battery, which refers to the device that converts chemical energy into electrical energy, is the most common source of electricity in people's daily lives. In 1800, the Italian scientist Alessandro Volt invented the voltaic pile, and since then, the modern battery has entered the world of mankind.

 

 

Nowadays, the common carbon batteries, alkaline batteries, lead-acid batteries, lithium-ion batteries, etc., all share the same working principle as the ancient voltaic stacks, and through the oxidation and reduction reactions inside the battery, the formation of electric current flows through the external circuit, which converts the stored chemical energy into electric energy.

 

Batteries can be categorized into primary batteries, storage batteries, solar cells, and fuel cells according to their nature of use. Among them, the storage battery is also known as a secondary battery, which can be recharged to regenerate the internal active material (electrical energy into chemical energy), and when it needs to be discharged again, the chemical energy is converted into electrical energy and reused many times. Lead-acid batteries (lead-acid batteries), nickel-cadmium batteries, nickel-metal hydride batteries, lithium-ion batteries, etc. are common batteries. Due to the large proportion of lead-acid batteries, lead-acid batteries are usually listed in a separate category, and other batteries are generally referred to as small secondary batteries.

 

 

Since their invention in 1859, lead-acid batteries have had a history of more than 150 years. The technology is very mature and is the world's most widely used chemical power supply. Although in recent years, nickel-cadmium batteries, nickel-metal hydride batteries, lithium-ion batteries, and other new types of batteries have been introduced and widely used, lead-acid batteries are still in the field of secondary power supply and account for more than 85% of the share.

 

 

Lead-acid batteries are composed of pole plates, partitions, shells, electrolytes, poles, and other parts. Positive plate is lead dioxide (PbO2), negative plate is fluffy lead (Pb), when the two plates are placed in the sulfuric acid-based electrolyte, the lead and sulfuric acid of the pole plate chemical reaction occurs, divalent lead positive ions (Pb2+) transferred to the electrolyte, leaving two electrons on the negative plate (2e-), the potential difference between the two plates is generated, and when connected to an external circuit, the current that is from the positive electrode to the negative, the battery begins to discharge. The battery begins to discharge. The charging process is the inverse reaction of the discharging process.

 

 

 

1. Lead-acid batteries are the batteries with the longest industrialized production time and the most mature technology, which have the advantages of stable working voltage, wide range of temperature and current, more charging and discharging cycles, good storage performance, low cost, mature recycling technology, etc., and thus are widely used.

2. However, compared with lithium-ion batteries and other new batteries, there are also shortcomings in service life, unit battery capacity, volume and weight, high-current charging and discharging performance, green environmental protection, and other aspects.

 

 

At present, lead-acid batteries are widely used in industry, agriculture, transportation, communications, people's livelihood and other fields, according to the use of the battery can be roughly divided into: starter batteries (car start), stationary batteries (standby power supply), traction batteries (electric locomotives), storage batteries for energy storage (power station energy storage), as well as other uses of batteries (lighting) and so on.

 

 

If lead-acid batteries are used, maintained or disposed of improperly, they may bring harm to people's lives and properties, such as: physical harm caused by electric shock and fire due to short-circuit and high temperature, chemical harm caused by metal and skin corrosion due to leaking of electrolyte, as well as environmental harm generated by improper manufacturing and waste disposal, etc. In particular, lead, as the main raw material of lead-acid batteries, is internationally recognized as the most threatening heavy metal in the environment, especially to children. In particular, lead as the main raw material for lead-acid batteries is internationally recognized as the heavy metal that poses the greatest threat to human beings, especially children, in the environment, and lead contamination can lead to children's brain damage, reduced intelligence, neurological developmental deficiencies, and severe lead poisoning can even lead to coma or death, therefore, the state of the lead-acid batteries production, processing and disposal of waste are subject to stringent regulations and access requirements.

 

 

Import and export of lead-acid batteries involved in the customs commodity code (HS code) mainly includes: 8507100000 lead-acid batteries for starter piston engines, 8507200000 other lead-acid batteries, as well as 8507901001 electrodes for lead-acid batteries, 8507901090 other lead-acid battery parts.

 

General Administration of Customs on the adjustment of the import and export commodities catalog must be implemented test Notice (General Administration of Customs Announcement No. 39 of 2021), has canceled the 8507100000, 8507200000 two customs codes of the regulatory conditions "A", since June 10, 2021 will no longer be implemented in the import of goods Inspection, up to now, lead-acid batteries related to the four HS codes have no inspection and regulatory conditions, without the implementation of import and export commodity inspection.

 

However, the "Import and Export Commodity Inspection Law" provides that the production of dangerous goods for export enterprises must apply for commodity inspection agencies to identify the use of packaging containers. Therefore, the classification of hazardous characteristics identified as dangerous goods lead-acid batteries, before exporting to the Customs and Excise Department should apply for identification of the use of dangerous goods packaging, after passing the identification before export.

 

 

The UN Model Regulations on the Transportation of Dangerous Goods (TDG) contain two UN numbers for lead-acid batteries, namely UN2794 (accumulator batteries, wet, containing acid) and UN2800 (accumulator batteries, wet, sealed). The principle of categorization is whether the lead-acid battery passes the 3 tests of vibration, differential pressure and 55℃ temperature listed in TDG "Special Provision 238".

 

1. If the lead-acid battery has not passed the above tests, it can be categorized as UN2794, and the hazardous category is Class 8 (corrosive substances);

 

2. If the lead-acid battery passes the vibration and differential pressure test test, but does not or does not pass the 55℃ temperature test test, it can be categorized as UN2800, and the hazardous category is Class 8 (corrosive substances);

 

3. If the lead-acid batteries have passed the three test tests of vibration, differential pressure and 55℃ temperature test, they can be exempted from transportation as general cargo and are not subject to TDG.

 

4. In addition, in the actual transportation, in addition to maintenance-free lead storage batteries, there are also batteries without electrolyte (acid) transportation, lead-acid batteries without electrolyte itself is not dangerous goods. The danger of its transportation mainly comes from the electrolyte, which is categorized as Class 8 dangerous goods and applies the UN No. UN2796 (sulfuric acid, containing no more than 51% acid, or acidic battery fluid).

 

The warning label for the transport of dangerous goods for lead-acid batteries of Class 8 is shown below.

 

 

 

 

First, lead-acid batteries are most commonly categorized as UN2794, with hazard class 8, packing guideline P801, and special provision 295.

 

Packaging requirements:

Packaging guidelines P801 allows the use of packaging containers, including rigid outer packaging, wooden crates, trays, and other forms of common packaging types such as cardboard boxes, plywood boxes, wooden boxes, and so on. In practice, when lead storage batteries are packed in cartons, the cartons are stacked on pallets to form transportation components, and the whole pallet is operated by a forklift for container loading and unloading. In addition, according to the special provisions of 295, if the pallet is affixed with appropriate markings and labels, the battery does not need to be marked and labeled individually.

 

Supplementary provisions: first, batteries must be protected against short circuits; second, stacked batteries must be secured in layers, and each layer must be separated by a layer of non-conductive material; third, the electrodes of the batteries must not support the weight of any batteries stacked on top of each other; fourth, the batteries must be packaged or secured to prevent accidental movement; and fifth, the batteries are required to pass a tilt test to ensure that, when tilted at a 45-degree angle, electrolyte will not leak. In practice, common ways to prevent short-circuits are a jacket plastic bag, electrode terminals with a protective sleeve, electrode terminals with paste tape, and other ways.

 

Second, lead-acid batteries categorized as UN2800, hazard class 8, packaging guidelines for P003, special provisions for 238 (i.e., the previously mentioned vibration, differential pressure, and 55 °C temperature of the three tests), and special packaging requirements for PP16 (packaging to prevent short-circuiting of the battery). Specific packaging requirements can be found in the "Rules for the International Maritime Transportation of Dangerous Goods" in the packaging guidelines P003 of the relevant provisions.

 

Third, lead-acid battery electrolyte is categorized as UN2796, hazardous category 8, packaging guidelines for P001 and IBC02, and there are no special provisions. The use of medium-sized bulk packaging of packing category II or above conforming to Packing Instruction P001 or Packing Instruction IBC02 is permitted. Specific packaging requirements can be found in the International Maritime Dangerous Goods Transportation Code (IMDG Code) in the relevant provisions of Packing Instructions P001 and IBC02.

 

 

I. Lead-acid batteries classified as UN2794, hazard class 8, packing instruction 870, special provisions A51, A164, A183, and A802.

 

Both cargo and passenger aircraft can be used to transport lead-acid batteries classified as UN2794. The difference is that for the transportation of lead-acid batteries on passenger aircraft, the maximum net weight of each package must not exceed 30 kg, whereas there is no such restriction for cargo aircraft.

 

Packaging requirements: lead-acid batteries categorized as UN2794 can be transported by air in drums, cans, boxes, and other rigid containers as outer packaging; packaging must meet the performance requirements of Class II packaging, such as metal packaging; and corrosion-resistant packaging must be used or have anti-corrosion measures.

 

Supplementary provisions: first, the battery must be protected against short-circuiting, to be filled in a sufficiently strong, tight acid-resistant liner; second, if the battery has a charging port and exhaust port, the packaging must be kept upward, and the direction of the labeling of the packaging pieces; third, unless approved by the relevant national authorities of the country of origin and the country of origin of the operator, it is prohibited to transport waste batteries and batteries for the purpose of recycling or disposal.

 

Ⅱ.Lead-acid batteries classified as UN2800, hazard class 8, packing guideline 872, special provisions including A48, A67, A164, and A183, cargo, and passenger aircraft can be used for transportation, and there is no single piece of the maximum net weight limit.

 

Packaging requirements: lead-acid batteries categorized as UN2800 air transport can be used in barrels, cans, boxes, and other rigid containers as the outer packaging, such as metal packaging; corrosion-resistant packaging must be used or have anti-corrosion measures.
Supplementary Provisions: First, batteries must be short-circuit-proof and must be securely packed in strong outer packaging; second, batteries must pass the vibration and differential pressure test and may be transported without restriction if they also pass the 55℃ temperature test; third, the transportation of waste batteries and batteries for the purpose of recycling or disposal is prohibited unless approved by the relevant national authorities of the country of origin and the country of origin of the operator.

 

III. Lead-acid battery electrolyte classified as UN2796, hazard class 8, packing instruction for transportation by passenger aircraft 851, maximum net quantity permitted for a single package is 1L; packing instruction for transportation by cargo aircraft 855, maximum net quantity permitted for a single package is 30L.

 

(1) passenger aircraft transportation, not allowed to use a single package, should use a combination of packaging; barrels, cans, boxes, and other rigid containers can be used as the outer packaging; glass, metal, plastic, and other containers can be used as the inner packaging; such as the use of metal packaging, corrosion-resistant packaging must be used or have anti-corrosion measures. The maximum net quantity allowed for each inner package and outer package is 1L.

 

(2) Cargo aircraft transportation is allowed to use a combination of packaging, single packaging and composite packaging; the combination of packaging material type requirements with passenger aircraft transportation allows each inner packaging to have a maximum net quantity of 2.5 L, and the maximum net quantity allowed for the outer packaging is 30 L. Single packaging and composite packaging allow the use of barrels, cans, boxes, and other rigid containers, such as metal packaging, which must be used in corrosion-resistant packaging or with anti-corrosion measures.

 

 

With the increasing volume of import and export trade in batteries, foreign technical trade measures for batteries also continue to emerge. Customs reminded battery exporters to continue to track and study the latest foreign technical regulations in advance to ensure that the export of batteries is in line with the requirements of importing countries.

 

 

The 337 investigation is an investigation conducted by the U.S. International Trade Commission (ITC) pursuant to Section 337 of the U.S. Tariff Act of 1930 (Section 337) and related amendments, which generally prohibits unfair practices and unfair measures in imported products or products sold after importation into the U.S. 2021. On January 19, NOCO filed a petition with the ITC under Section 337 of the U.S. Tariff Act of 1930, asserting that portable battery starters and their components exported to, imported into, and sold in the U.S. infringed its patents and requesting the ITC to issue a limited exclusion order and injunction, with a total of more than 100 companies listed as respondents. From the point of view of the enterprise information in the list, the Chinese mainland and Hong Kong enterprises occupy more than half.

 

 

On December 10, 2020, the European Union released a draft proposal for a new battery law that proposes to repeal the current EU Battery Directive (2006/66/EC). The new draft battery law proposes new mandatory requirements for batteries in terms of hazardous substances, carbon footprint, recycled raw materials, electrochemical performance and durability, removability and replaceability, safety, labeling, waste management, electronic information exchange, etc., and the mode of implementation will be changed from a "directive" to a "regulation." The implementation mode has changed from "directive" to "regulation" to ensure that the batteries placed on the EU market become sustainable, high-performance, and safe throughout their life cycle.