An announcement that sent shockwaves through the Seller Central forums regarding Amazon lithium battery rules starting in 2020 is sure to ruffle some feathers. Here’s what is being tracked to change starting January 1st and how it’ll affect selling lithium batteries and products containing said batteries.

Something I’ve started seeing more of the last few months are changes to Amazon policies that draw more hard and fast lines around what can and cannot be done on the platform. One of the first articles I posted was about shoe sizing, which seemed innocuous, then came listing title enforcements, then lower Inventory Performance Index limits, and let’s toss in Small and Light being gutted for good measure.

What Are the new Amazon Lithium Battery Rules?

Up next on Amazon’s hit list of “cut corners and grey areas” is battery certification. This snipper from Amazon’s lithium battery rules announcement is all you really need to read:

Effective January 1, 2020, battery manufacturers and distributors must provide a lithium battery test summary, per a United Nations standard known as UN 38.3. This new global requirement applies to lithium batteries and products containing lithium batteries

When selling on FBA, you are responsible for obtaining this test summary for any ASIN that you sell. Failure to provide this summary may prevent you from selling the product on Amazon. In addition, any units of this ASIN in our fulfillment centers may be disposed of at your expense.

Let’s dig into Amazon’s lithium battery announcement a bit more and cover why this is happening. Dubbed UN 38.3, the standard for lithium batteries and their transportation was updated back in 2017 to define more obviously and necessarily strict requirements for batteries in order to be transported safely. These tests, known as “T1-T8“, determine whether a battery can be safely transported in all the relevant conditions. More recently, changes to the test now require significantly more detail, and those changes go into effect on January 1, 2020.

An example test for primary lithium batteries, illustrated in table form with the test numbers (T.1 through T.8 across the top) and battery categories and their charge states down the left). The amazon lithium battery rules are based on this test.
An example of the test for primary lithium batteries. (source)

So why is Amazon making this a big deal now? Ultimately, this appears to be one of many small maneuvers in their secretive quest for regulatory compliance and rule-following. A company the size of Amazon can’t not be cutting corners at this point so it’s not surprising to see them taking this more legally and procedurally aggressive stance in an effort to make it seem like they’ve been the “good guys” all this time. Pair that with the high volume of known counterfeits coming from the Chinese marketplace they worked so hard to bolster, liability had to come into play, as well.

Going even farther and considering that these new stricter tests will become standard, it’s not unreasonable to expect a legitimate product from a legitimate manufacturer to have such testing done.

As sellers, this is impactful, and not just slightly. Manufacturers or suppliers may not have or be willing to surrender a copy of the UN 38.3 test, claiming its proprietary, though such documentation is an IATA requirement for legal transportation of batteries and battery-powered goods.

Based on Amazon’s current documentation, the requirement will first start with existing ASINs, and will soon also cover new ones as well. Those who are notified that they’re missing such a document and fail to provide it may see their ASIN removed from Amazon entirely and inventory disposed of at the seller’s expense. This requirement covers all kinds of lithium batteries, including button cell batteries, as those also fall under UN 38.3.

It’s also worth pointing out that any manufacturer that claims they can’t provide this information either never did this testing or did the testing and aren’t comfortable sharing what the tests uncovered. Reputable sources should provide this information, willingly.

This requirement does not pertain to batteries of other composites such as Alkaline or Nickel Metal Hydride (NiMH).

To upload the test summary for an ASIN, head to this page. To follow along in what will eventually become if it hasn’t already become a trash fire of a forum thread, head here.