Lithium battery test In-depth guidance and Q&A

Recently Vietnam MIC has released new version of Nation technical regulation on lithium battery used for handheld devices (mobile phone, tablet, laptop) – QCVN 101:2020/BTTTT with roadmap of implementation and replacing QCVN 101:2016/BTTTT on July 01, 2021. So what is the impact and how to be in compliance with the new standard for lithium battery? Which test laboratory in Vietnam has been designated by Vietnam MIC for lithium battery testing? Please find below the common questions raised from our customers and our according consultancy and recommended compliance solutions:

Q1> Can we keep using test report according to QCVN 101:2016/BTTTT to make Self-assessment report on conformity (Self-assessment Declaration of Conformity - SDoC) for importation clearance of lithium batteries (used for mobile phone, tablet, and laptop) or mobile phone, tablet, and laptop on or after July 01, 2021?

A1> Pursuant to Vietnam MIC regulations at Circular 15/2020/TT-BTTTT and QCVN 101:2020/BTTTT:

→ QCVN 101:2020/BTTTT shall take effect from July 01, 2021

→ QCVN 101:2016/BTTTT shall be invalid from July 01, 2021

→ QCVN 101:2020/BTTTT shall replace QCVN 101:2016/BTTTT from July 01, 2021

Therefore, the manufacturers and importers are not allowed to use test report according to QCVN 101:2016 to make SDoC for compliance according to QCVN 101:2020/BTTTT. If the Vietnam MIC and VNTA found the SDoC were issued based on a wrong standard version of test standard, the MIC and VNTA shall request the applicant to pay a penalty, force the applicant to make “corrective action” (re-test products, or re-call products from market and destroy the products if non-conformance found)

Q2> Are QCVN 101:2016/BTTTT and QCVN 101:2020 equal to IEC standards?

A2> The QCVN 101 has been composed based on IEC standards for technical requirement with requirement on management specifically applicable for Vietnam. Details as below:

QCVN 101:2016/BTTTT including two major parts of technical requirements:

(1) IEC 62133:2012

(2) IEC 61960:2011

(Vietnam MIC consider UN 38.3 is a part of IEC 62133:2012 but UN 38.3 test is not enforced yet at this moment)

QCVN 101:2020/BTTTT including two major parts of technical requirements:

(1) IEC 62133-2:2017

(2) IEC 61960-3:2017

Q3> We are exporting battery to Vietnam only, and the Circular 11/2020/TT-BTTTT says that only battery needs to do compliance test, do we need to apply for the its cell also?

A3> The QCVN 101:2016/BTTTT include requirements on both lithium battery (battery pack) and lithium cells. In this case, the cells is considered as a part of the battery pack so compliance for the cell is also required. This is continous requirements of Vietnam MIC from July 01, 2017 till now with no change.

Q4> QCVN 101:2016/BTTT include requirements on safety (IEC 62133:20212, electrical performance (IEC 61960:2012), and safety in transportation UN 38.3, do we need to test them all in VIetnam labs?

A4> Pursuant to (**) remark at bottom end of Annex 2 of the Circular 11/2020/TT-BTTTT of MIC Vietnam, only safety requirements according to item 2.6 of QCVN 101:2016 is required at this moment. Electrical performance at item 2.5 (IEC 61960:2012) and safety in transportation at item 2.6.2.7 (UN 38.3) of QCVN 101:2016 is also not required yet so they can can be tested in oversea labs.

Q5> If we have obtained CB test report and CB certificate according to IEC standard, can we use CB test report and certificate to make SDoC for QCVN 101:2020/BTTTT?

A5> At this moment, MIC and VNTA does not accept CB certificate but can accept CB test report if it meets below conditions at the same time:

(1) Issued by a CBTL which located in countries which has signed Mutual Recognition Agreement with Vietnam (US, Korea, Singapore, Canada) and the recognition scope must have IEC 62133 and IEC 61960

(2) Such CBTL has applied and got accredited by Vietnam MIC as a MRA recognized lab. Link to find list of MRA lab on MIC website

Obviously, there is no oversea lab has been recognized by Vietnam MIC for QCVN 101 testing at this moment.

Furthermore, the Vietnam MIC has repeated this requirement on official guidance No. 2305/BTTTT-KHCN dated June 23, 2020 that only test report issued by MRA lab or local lab accredited by MIC can be acceptable. So, obtaining a test report issued by a local test laboratory, which has been designated by Vietnam MIC for QCVN 101 or equivalent IEC standard testing, is a must.

Q6> What is the differences between QCVN 101:2020/BTTTT and QCVN 101:2016/BTTTT

A6> Because at this moment the MIC Vietnam is requiring compliance according to Safety only, we have made a comparison table between the two technical regulations on safety requirements as below:

Compare Safety requirements of QCVN 101:2016/BTTTT vs QCVN 101:2020/BTTTT

Test items for safety requirement of QCVN 101:2020/BTTTT		Test method change	Samples required
Test items for cell
2.6.1.1	Continuous charge at constant voltage (cell)	No	5
2.6.2.1	External short circuit (cell)	Yes	10
2.6.2.2	Free fall (cell)	No	3
2.6.2.3	Thermal abuse (cell)	Yes	10
2.6.2.4	Crush (cell)	Yes	5
2.6.2.6	Forced discharge (cell)	No	5
2.6.2.8	Forced internal short circuit (cell)	No	10
Total (minimum) (pcs)			48
Test items for battery pack
2.6.1.2	Moulded case stress (battery)	No	3
2.6.2.1	External short circuit (battery)	Yes	5
2.6.2.2	Free fall (battery)	No	3
2.6.2.5	Over charging (battery)	Yes	5
2.6.7.1	Vibration (battery)	New	3
2.6.7.2	Mechanical shock (battery)	New	3
Total (minimum) (pcs)			22

Q7> Shall MIC enforce the full QCVN 101:2020/BTTTT including requirements on safety (IEC 62133-2:2017) and requirements on electrical performance (IEC 61960-3:2017) from July 01, 2021?

A7> Because electrical performance test requires at least 90 days for testing which cause tremendous cost, Vietnam MIC could still temporary allow performance test to be waived by an official Circular in future which shall replace the current Circular 11/2020/TT-BTTTT - Circular taking effect at this moment.

Q8> Can we apply for testing according to new standard QCVN 101:2020 now?

A8> Because QCVN 101:2016/BTTTT is the regulation which taking effect at this moment and MIC Vietnam shall not designate a test laboratory directly for National Technical Regulation (QCVN) which has not entered in force yet. Therefore, no local lab can test and issue test report according to QCVN 101:2020/BTTTT directly. However, you can apply for testing according to IEC 62133-2:2017 at the test laboratory which has been accredited by the Vietnam MIC for such standard.

Q9> If we apply for local testing according to IEC 62133-2:2017, is the test report accepted to make SDoC according to QCVN 101:2016/BTTTT and QCVN 101:2020/BTTTT

A9> You can use test report according to IEC 62133-2:2017 to make make Self-assessment report on conformity (Self-assessment Declaration of Conformity - SDoC) for safety requirement of both to QCVN 101:2016/BTTTT and QCVN 101:2020/BTTTT. Because:

(1) Pursuant to the QCVN 101:2020/BTTTT:

"The QCVN 101:2020/BTTTT is composed based on IEC 61960-3:2017 and TCVN 11919-2:2017 (IEC 62133-2:2017)" (at page No. 4) so IEC 62133-2:2017 is accepted to be based on to make SDoC according to safety requirement item 2.6 of the QCVN 101:2020/BTTTT. The insight is the same as the time MIC allows IEC 62133:2012 test report issued by ISO/IEC 17025 accredited oversea test labs to apply for Declaration of Conformity according to QCVN 101:2016/BTTTT during the 2017 ~ 2018 period.

(2) Pursuant to Guidance No. 2305/BTTTT-KHCN dated Jun 23, 2020:

“For lithium batteries which are under mandatory scope for declaration of conformity, organization and individual are allowed to use test report issued by test laboratories which are designated or recognized or registered to MIC Vietnam only for declaration of conformity according to QCVN 101:2016/BTTTT; organization and individual shall be allowed to use test report according to IEC 62133:2012 or later version of IEC 62133”

This is supposed to be an intended guidance of the MIC so the manufacturer and importer will have more time to prepare and can apply for IEC 62133-2:2017 testing in advance to prevent delay in exportation on or after July 01, 2021

Q10> Which lab has been designated by the Vietnam MIC for the new standard IEC 62133-2:2017 testing so we can apply for testing from now?

A10> Our VNCA lithium battery test laboratory has been designated by the Vietnam MIC as the first test lab accredited by MIC to test according to IEC 62133-2:2017 (beside the QCVN 101:2016/BTTTT). We are not only providing services to test lithium batteries according to IEC 62133-2:2017, but also providing the best regulation constancy on market in one package without additional fee. Please contact us at below addresses:

VNCA lithium battery test laboratory