HS 85.07 · 85.41

Renewable energy & storage

Batteries are not really a product category. They are a dangerous-goods category with a product attached, and the cell decides the freight lane, the shelf life, the certification file and the warranty tail long before anyone discusses the box.

A Zeero portable power station with a coiled cable beside it
§ What we trade

What we trade in this category

  • Portable power stations 300–3000 Wh anything over 100 Wh is fully regulated Class 9, so the lane and the packaging are fixed before the specification is
  • LFP wall and rack storage modules above 5 kg they stop being portable batteries under the EU regime and become industrial ones, which changes the label, the registration and the passport
  • Hybrid and off-grid inverters a CE file does not get a unit connected; grid-code approval is national and granted per model
  • Glass-glass and glass-backsheet PV modules cheap per watt and expensive per cubic metre, and the breakage exposure sits in handling and the inland leg rather than in the sea passage
  • Balcony and plug-in solar sets sold as an appliance, treated as a generating installation, and the registration rules differ by member state
  • MPPT charge controllers and off-grid kits no lithium on board means no Class 9, which is why these still move by air when a project slips
  • Cells, BMS boards and pack hardware the test file follows the exact configuration, so a substituted cell is a new product with a new file
§ How we select

How a supplier and a product get chosen.

01

Cell provenance first

You are buying cells; the enclosure is joinery. We establish the chemistry, the cell maker, the grade and the date codes on the actual cells in the sample, and whether the pack uses one lot or a mix. A pack built from downgraded or rewrapped cells passes a five-minute demonstration and fails once the warranty is running.

02

Read the test file

Not the certificate — the file. A UN 38.3 test summary is valid for the configuration that was tested, so a changed cell, or any of the design changes sub-section 38.3.5 lists, sends it back for retest, and the summary a factory sends is often for a superseded revision. The same discipline applies to the IEC 62133-2, IEC 62619 or EN IEC 62368-1 report: check the model annex actually lists the variant you are buying, and check the issue date against the current bill of materials.

03

Bench the sample

Discharge at the rated continuous load to measure usable watt-hours rather than nameplate, then test surge behaviour, pass-through charging, BMS quiescent draw and the low-temperature charge lockout that LFP requires below zero. Add a thermal soak at the temperature the destination market actually reaches. We compare the bench figures against the datasheet line by line and quote from the bench figure.

04

Audit dangerous-goods capability

A factory that cannot get cargo onto a ship is not a supplier. We check UN-marked packaging with a current test report, the correct packing instruction, and whether the plant can produce the Chinese export dangerous-goods identification report and the packaging performance and use certificates without a three-week scramble.

05

Fix the tail before price

Battery products carry a multi-year obligation, so the warranty terms, the spare pack and board ratio, the firmware update route and the serial-to-lot records are negotiated with the unit price, not after it. We also settle who registers as producer in each destination market before the first order, because that decides who carries the recycling and reporting cost.

§ Development

Development and design.

Design

Specification written to the label

For Zeero Energy and Highbeam Energy we specify usable output at a stated continuous load, continuous and surge watts separately, and cycle life at a defined depth of discharge and temperature. The figure printed on the carton has to be the figure the bench produces. Where nameplate and usable energy differ, the difference is explained in the manual rather than argued about later.

Design

Certification held in our own name

We commission and hold the test file in our own name rather than the factory's, and have the model annex drawn to cover the capacity, colour and socket variants, so adding a market variant does not restart the programme. Cell substitution is treated as a design change and goes back through UN 38.3 and the safety report, because the alternative is a shipment that cannot be booked.

Design

Enclosure, artwork and the label stack

Battery pictograms, chemistry, capacity and importer identity on the product, and a reserved field in the artwork for the QR code the EU regime brings in. Separate plates for Serbian, Portuguese, Arabic and traditional Chinese manual sets. Vent placement, ingress rating and handle load are settled at the same time, since all three move when the enclosure is retooled.

Design

Packaging engineered as dangerous goods

UN-certified boxes with cushioning proven by drop and stack testing, not a carton chosen on cost per unit. Units leave in transport or sleep mode at the state of charge the booked line will accept, with a recharge-by date on the outer, and the pallet plan is drawn to fit both a 40ft high cube and a European pallet network without restacking.

§ Our part

What we do that a broker does not.

A

We book the dangerous goods

Shipper's declaration, safety data sheet, UN 38.3 test summary and packaging certificates assembled before the cargo is ready, and carrier dangerous-goods approval requested with the lead time the line actually needs. Class 9 space is rationed and rolls easily, so the booking is treated as a long-lead item alongside the cells.

B

Inspection before the balance moves

We book pre-shipment inspection on the finished pallets, with capacity discharge on drawn samples and electroluminescence imaging on modules, and hold the balance payment until the report passes. Where a lot fails, rework happens at the factory rather than in a European warehouse where the stock is already Class 9.

C

Registration files per market

Producer registrations and recycling scheme enrolment, national declarations of conformity in the required language, translated manuals, and importer identity applied to the product and packaging rather than stickered on at the depot. Where DG Brands Europe or Sana Vivo Brands is the importer of record, that registration sits with us and the buyer receives goods already placed on the market.

D

Storage that will take the stock

Not every warehouse will accept lithium above threshold quantities, and those that will impose segregation and quantity limits. We place stock where it can legally sit, monitor state of charge against the recharge-by date and rotate by cell lot rather than by pallet position.

E

After the sale

Spare packs, BMS boards and inverter modules landed with the first order rather than ordered when the first failure appears. Firmware versions are recorded against serials and serials against cell lots, so a defect can be answered as a lot action instead of a whole-range one.

§ Documents

What the paperwork actually is.

The document set below is what this category needs to clear. We raise it rather than forwarding a checklist.

  • Transport: UN 38.3 testing with the test summary made available, UN 3480 for batteries alone and UN 3481 packed with or contained in equipment, Class 9 under the IMDG Code by sea, where the state-of-charge condition comes from the carrier's booking terms rather than the Code, IATA packing instructions 965 for batteries alone and 966 and 967 for batteries packed with or contained in equipment, with the state-of-charge limits that attach to 965 and 966, ADR on the road legs, plus a shipper's declaration, safety data sheet and UN-marked packaging with a valid test report.
  • EU market access: Regulation (EU) 2023/1542 on batteries, including the category split between portable and industrial batteries, the Annex VI labelling and information set phasing in from August 2026, the QR code and digital passport that follow it, and separate producer registration in every member state where the goods are placed on the market; WEEE Directive 2012/19/EU, which covers photovoltaic modules; RoHS; the Low Voltage Directive 2014/35/EU and EMC Directive 2014/30/EU; the Radio Equipment Directive 2014/53/EU where the unit carries a Wi-Fi, Bluetooth or cellular module; and an economic operator established in the Union under Article 4 of Regulation (EU) 2019/1020, and the General Product Safety Regulation (EU) 2023/988 for the risks the harmonised directives do not cover.
  • Product standards: EN IEC 62368-1 for the finished appliance, IEC 62133-2 for portable lithium cells and batteries, IEC 62619 and IEC 63056 for industrial and storage cells, IEC 62109-1 and 62109-2 for inverters, IEC 61215 for module design qualification with IEC 61730 for module safety, and EN 50549 alongside the national grid codes that decide whether a hybrid inverter can be connected at all.
  • Serbia and duty: national rulebooks aligned to the low-voltage and electromagnetic compatibility directives, a declaration of conformity issued in Serbian by the importer with the technical file held locally, the Serbian conformity mark, and the eco-fee for products entering the special waste streams. Preferential duty on Chinese-origin cells, batteries and photovoltaic modules runs through the China–Serbia free trade agreement in force since 1 July 2024, and the origin proof has to travel with the shipment. Classification itself is contested in this category — portable power stations sit between the accumulator heading 8507.60, the static converter heading 8504.40, and the photovoltaic generator subheadings under 8501 once a panel travels in the set — so we settle it with binding tariff information before quoting a landed price, not at the border.
  • Asia: Hong Kong is a free port, so the constraint is warehousing rather than duty — lithium sits in the dangerous-goods regime and stock above the exempted quantity needs licensed storage — with the Electrical Products (Safety) Regulation applying to mains-operated household equipment. Singapore's Consumer Protection (Safety Requirements) Registration Scheme needs a registered local supplier and a SAFETY Mark on controlled goods, and portable batteries fall into the NEA e-waste producer responsibility scheme. Mainland China requires CCC certification for cells and packs used in portable electronic products and for mobile power supplies up to 18 kg, mandatory since 1 August 2024 and tested to GB 31241-2022 with GB 4943.1-2022.
  • Gulf: Saudi shipments run through SABER with a product certificate of conformity followed by a shipment certificate for each consignment; GCC conformity marking under the low-voltage technical regulation elsewhere; Arabic labelling on product and packaging; and civil-defence approval where storage is installed as a fixed system rather than sold as an appliance.
§ Corridors

How it moves.

Cells, modules and finished units come out of Greater China into the EU, Serbia and the Gulf, while European-specified and European-branded stock moves the other way into Hong Kong and Singapore. Class 9 rules the routing in both directions: full containers by sea on bookings placed weeks ahead, transhipment only through ports that will accept lithium, and the inland ADR legs planned before the vessel is fixed.

See the lanes we run

§ Questions

What buyers ask first.

Can you air freight a sample power station?

A finished unit moves as UN 3481 contained in equipment, PI 967 Section I, on passenger or cargo aircraft; a loose pack moves as UN 3480, PI 965 Section IA, cargo aircraft only and at or below 30% state of charge, in UN-marked packaging closed by a trained packer. Freight and handling frequently cost more than the sample itself, and many forwarders decline it outright. We either book it properly and give you the real number, or build a sub-100 watt-hour demonstration unit that moves under lighter conditions.

Who counts as the producer under the EU battery rules — you or us?

Whoever first places the goods on the market in that member state. If DG Brands Europe or Sana Vivo Brands imports and invoices you, that registration and the reporting sit with us. If you import directly, they are yours, in each member state you sell into, and the registration number has to exist before the first sale. We prepare the file either way and state plainly which of us is carrying it.

Why does a pack rated 2048 Wh deliver noticeably less?

The nameplate is cells at nominal voltage. What reaches the socket is reduced by the depth-of-discharge window the BMS enforces, inverter conversion loss, standby draw and ambient temperature. We specify and test to usable output at a stated continuous load, and the gap between the two figures belongs in the manual rather than in a claim after delivery.

Our last container arrived with units that will not switch on. What causes that?

Cells leave at a low state of charge because the line's lithium terms require it, then spend the whole Asia-Europe transit plus port and customs dwell, and a BMS with real quiescent draw keeps pulling the whole time. Cells drift under the recovery threshold and the pack refuses to charge. We measure quiescent current at sample stage, ship in transport mode, print a recharge-by date on the outer carton and top up stock in the warehouse against that date.

§ Other sectors

Moving renewable energy & storage?

Tell us the product, the origin and the destination. We come back with the classification, the document set and a realistic timeline.

Open a file with us
§ Two minutes

Not ready to write a brief?

Leave three lines and we will come back with the corridor, the customs position and a realistic timeline for whatever you are moving.

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