China GB 31241 Battery Compliance
China has always been a difficult region for product compliance with many different standards and authorities that are driving the requirements. There are mandatory standards and voluntary standard as well as mandatory and voluntary product lists and most of the standards are not harmonized and not available in English. Li ion batteries are no exception and there are some major changes in this area for the rest of 2015 and into 2016.
China released a new standard that applies to Li Ion batteries and cells for use in portable electronic equipment. This will apply to Li ion batteries and cells used in electronic equipment that is not more than 18kg and can be transported by the user. The new standard is GB 31241 and it is not harmonized with IEC 62133 first or second edition. Also, there is currently not a commercially available English translation.
As of August 1, 2015, the standard becomes mandatory for compliance in China, however the enforcement of this requirement is still up in the air. The reason for this is that even though the standard is required, the products covered by the standard are currently not included on the CCC mandatory products list. This means that enforcement will be tricky and may be achieved through a few different options as long as the products are not on the mandatory CCC list.
Option 1: Obtain a voluntary CQC mark for the product. If you want to be able to mark your product to show compliance, you can obtain a certification to apply the CQC mark to your product based on an evaluation by CQC to the GB31241 standard. This would show compliance of the product and allow for a mark on the product as well. This would require in-country testing and a factory inspection associated with the certification and right to use the CQC mark on the battery.
Option 2: Obtain a GB 31241 test report from a Chinese accredited test lab. This would be a report only and there would be no associated mark or certification that would be used to show compliance on the product. Most, if not all, Chinese accredited labs are in China so the testing would likely need to be done in China, however, since there is not a mark or certification involved, there is not a need for a factory audit.
Option 3: Provide a manufacturer’s self-declaration of compliance to GB 31241. This can be completed by the manufacturer or through an outside test lab. The lab would not be required to have a Chinese accreditation for the testing and there would be no mark or certification and no need for factory inspections. The testing in this case can be done by anyone and the manufacturer is declaring compliance and taking responsibility that the testing was done properly.
All of these options are currently viable since GB 31241 is mandatory, but the products have not been added to th e mandatory product list. However, there are a couple of unknowns that need to be considered. First of all, since a battery is a component to an end product, the end product will have certification requirements, and it is not clear how the test labs evaluating the end products will enforce this mandatory standard. Of the options noted above, Option 1 is the most likely to be the most accepted since it is granted by CQC and involves on-going factory inspections. However, it is also the most cost prohibitive and time consuming to achieve.
Alternatively, if the battery manufacturer decides to self-declare, they run the risk that the end product evaluating lab will not accept a self-declaration that is provided for compliance to GB 31241, the battery manufacturer would then be in a tight spot to complete the CQC evaluation or even the Chinese accredited lab testing in a timely manner.
Another consideration is if the batteries are added to the CCC required product list at some later date. In this case, the manufacturers’ self-declaration may have been acceptable to show GB 31241 compliance prior to the update of the CCC mandatory product list, however, once the product is added to the list, the self-declaration and even the Chinese accredited testing will no longer be considered acceptable. The battery manufacturer will then need to go back and have it tested by the Chinese agency and have factory inspections completed for the product. Depending on the timeline allowed for compliance, this could become an issue for currently shipping products that have been self-declaring compliance to GB 31241.
Until more details are available on how the enforcement will be handled for the end products employing batteries, the above mentioned options are all equally viable and acceptable to show compliance to GB 31241. However, close attention will need to be paid to changes in the CCC mandatory product list, as well as the acceptance of self-declarations to the GB 31241.