Batteries for export: UN 38.3 and the EU Battery Regulation ask for different things

UN 38.3 answers a transport question: whether cells and battery packs can be carried safely under simulated transport conditions. The EU Battery Regulation answers a product question that spans the whole life cycle, covering carbon footprint, performance and durability parameters, recycled content and battery passport duties.

Neither substitutes for the other. A UN 38.3 report does not produce a declaration of conformity, and the technical file prepared for the regulation does not carry out the transport tests.

The scheduling mistake we see most often is leaving transport testing last. UN 38.3 needs complete samples together with cycling and ageing data, so cells that have not finished ageing push the report date past the shipping window. Start it when the cell design is frozen.