Battery packs and power banks from China: cells, safety tests and EU rules

Aslan runs battery packs and power banks as a factory search project, quoted per project: it screens the factories in China that make the product, visits the shortlist, negotiates in Chinese, pulls samples and hands you a ready-to-order file. Aslan holds no standing partner factory in batteries and has no engineers, so your specification is the reference: Aslan does not review cell choice, protection design or pack design. Factory visits, audits and inspections are billed at a day rate with travel at cost, and when Aslan manages the order it charges the buyer a commission of 4 to 8 percent of order value, as set out on the pricing page.

This page is general information and does not replace legal or engineering advice.

Cell chemistry and cell format

Figures from Battery University (BU-205). Wh is watt-hours; EV means electric vehicle.

Cell maker and pack assembler

The EU Batteries Regulation treats cell and module suppliers and battery manufacturers as separate roles. Article 39 requires cell suppliers to give the manufacturer, free of charge, the documentation it needs to comply. Cells are finished at the cell maker: a 2023 review describes storing and testing cells for up to three weeks to measure self-discharge.

What the BMS protects against

The BMS, or battery management system, is the electronics that watch each cell. Per Battery University, protection keeps any cell below 4.30 V on charge, cuts current at about 2.20 V per cell on discharge, guards against shorts and faulty chargers, and fuses as cell skin temperature approaches 90°C. Each cell in a series string needs its own voltage monitoring. Internal defects such as microscopic metal particles are beyond its reach.

Specification fields to send

Tests and documents

UN 38.3 is the United Nations transport test series. Guidance from IATA, the International Air Transport Association, says manufacturers and distributors must make available a test summary as specified in paragraph 38.3.5 of the UN Manual of Tests and Criteria, Revision 8. It names the laboratory, report number, date, mass, Wh rating, model numbers, each test result and the Manual edition.

IEC 62133-2:2017 with Amendment 1 of 2021, from the IEC, the International Electrotechnical Commission, sets requirements and tests for the safe operation of portable sealed secondary lithium cells and batteries under intended use and reasonably foreseeable misuse.

EU Batteries Regulation: obligations and dates

Under Regulation (EU) 2023/1542, a portable battery is sealed, weighs 5 kg or less, is not designed specifically for industrial use and is not an EV, LMT or SLI battery. LMT means light means of transport; SLI means starting, lighting and ignition.

Delegated Regulation (EU) 2026/1770, in force since 11 November 2026, widened the exemptions from end-user removability, including some wearables. Under Article 41, importers check the declaration of conformity, technical documentation, CE marking and labels before placing a battery on the market.

The device holding the battery also falls under the WEEE Directive on waste electrical and electronic equipment: producer registration in each national register, through an authorised representative for distance sellers, and the crossed-out wheeled bin. See EU compliance for AI wearables and connected devices.

Shipping by air and sea

By air, lithium-ion batteries shipped alone are UN 3480; those in or packed with equipment are UN 3481. Per IATA, UN 3480 is forbidden on passenger aircraft without approval and ships at no more than 30 percent state of charge. Since 1 January 2026 the limit also covers batteries packed with equipment; for small batteries shipped under Section II of Packing Instruction 966, it covers those above 2.7 Wh. By sea, the IMDG Code, the International Maritime Dangerous Goods Code, is mandatory under the Safety of Life at Sea convention; its 2024 Edition with Amendment 42-24 became mandatory on 1 January 2026.

Customs code and duty

Lithium-ion accumulators sit under heading 8507 of the HS, the Harmonized System of customs codes. On 13 November 2026, TARIC, the EU tariff database, showed a 2.70 percent third-country duty on code 8507 60 00 90 from China. Confirm classification with your broker.

Checklist for a pack assembler

• Cell maker, model and datasheet named in writing, batch codes matching the cell maker’s invoice
• Incoming cell inspection described: what is measured, how many cells per lot
• Ageing, capacity grading and cell matching records for your batch
• UN 38.3 summary and IEC 62133-2 report issued for the exact model, Wh rating and cell you are buying
• EU declaration of conformity and battery labels drafted
• Pre-shipment inspection booked; see how pre-shipment inspection and acceptance quality limits work

Questions buyers ask

Does Aslan have a battery factory it works with? No. Battery packs and power banks run as a factory search project, starting from your specification.

Is a UN 38.3 report enough to sell in the EU? No. It covers transport; the Batteries Regulation duties apply on top.

Who is the importer of record? You are. The factory invoices the goods to you, and the Article 41 duties sit with you.

The battery goes inside our own device. Where do we start? With the device: see AI hardware contract manufacturing.