What Are RoHS, UN 38.3 and MSDS, and How Do They Differ?

For any product to enter the EU market, especially chemical products and electrical and electronic equipment, four core English terms are often encountered, which constitute four dimensions of product compliance: chemical control, environmental restriction, information transmission, and transportation safety.

Product compliance can be likened to a strict entrance examination, with these four key terms being REACH, RoHS, msds, and un 38.3.

What is un 38.3 certification?

(I) Overview of UN 38.3 Certification

UN 38.3 refers to Section 38.3 of Part III of the UN Recommendations on the Transport of Dangerous Goods – Manual of Tests and Criteria, formulated by the United Nations specifically for the transport of dangerous goods.

Its core requirement: lithium batteries must pass tests including altitude simulation, temperature cycling, vibration test, impact test, external short circuit at 55°C, crush test, overcharge test, and forced discharge test before transportation to ensure transport safety.

Without this test report, civil aviation authorities will prohibit the air transport of lithium batteries.

It should be noted that lithium battery transport compliance requires not only the battery itself to pass the un 38.3 test, but also the packaging for standalone lithium batteries and batteries shipped with equipment to pass a 1.2m drop test. Only when the packaging meets regulatory requirements can transportation be carried out.

(II) Documents Required for UN 38.3 Certification

• Product information of batteries/cells

• Packaging details and instructions

• Declaration documents

• Transport accompanying documents

(III) UN 38.3 Certification Process and Timeline

(IV) Notes on UN 38.3 Certification

• A 1.2m drop test is not required if the battery is installed in equipment and is non-removable.

• The UN 38.3 identification report shall be used together with the msds report during transportation.

• The packaging weight of batteries shall not exceed the standard limit.

• The identification report must be renewed annually and is only valid for the current year.

REACH – The "Constitution of Chemicals" in the EU

REACH stands for Registration, Evaluation, Authorization and Restriction of Chemicals, the most extensive and fundamental EU chemical regulation with legal force.

It applies to all chemical substances (substances, mixtures, and articles), with core requirements including substance registration, risk assessment, svhc (Substances of Very High Concern) disclosure, and compliance with restricted substances.

SVHC (Substances of Very High Concern) is the most frequently mentioned concept in REACH, similar to a "grey list": if the concentration of certain extremely hazardous substances (such as carcinogens) in a product exceeds 0.1%, enterprises are obligated to inform customers or consumers.

The core philosophy of REACH is to shift the burden of proof for chemical safety from governments to enterprises. Enterprises must "prove the safety" of chemicals produced or imported into the EU (including chemical substances in articles) by completing substance registration and providing safety data.

RoHS Compliance

RoHS refers to the Restriction of Hazardous Substances Directive for electrical and electronic equipment, a dedicated environmental directive for electrical and electronic products (the directive itself has no legal force and takes effect only after being transposed into national laws by EU member states).

RoHS focuses on prohibiting hazardous substances in electronic products, restricting 10 hazardous substances in electrical and electronic equipment (EEE): Pb, Hg, Cd, Cr⁶⁺, PBB, PBDE, and 4 phthalates.

The homogeneous material limits are: Cd ≤ 0.01%, and the other 9 substances ≤ 0.1%.

MSDS/SDS

MSDS stands for Material Safety Data Sheet, a detailed technical document that describes the basic information, hazard characteristics, fire-fighting methods, spillage handling, and other contents of chemicals (or chemical-containing mixtures).

Although MSDS is a documentary file, its data on physicochemical properties, toxicity, etc., are based on professional tests or assessments. It serves as the basis for classifying dangerous goods for transport and is also an important tool to meet the information transmission requirements of the reach regulation.

Differences Between RoHS, UN 38.3 and MSDS