st599
Well-Known Member
The main outcome from that clause is that it prevents people buying cells and making their own battery.
Lithium Positive and Negative Insurers
- Thread starter aqua_sax
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PaulRainbow
Well-Known Member
Not if the cells are CE marked.
st599
Well-Known Member
No, the insurance text quoted required the battery to be CE marked, not the cells.
Even if all the components had CE marks, the battery wouldn't acquire a CE mark and would need to be individually assessed.
PaulRainbow
Well-Known Member
The boat is fitted with 4 x 3.2V batteries (CE marked) wired in series.
Stop making nonsense up.
RunAgroundHard
Well-Known Member
Equipment (that is required to be CE marked) manufactured from CE marked components does not become CE marked automatically. It still needs to be assessed against the machinery directive for CE marking. Very likely a battery assembled from CE marked cells would require to be assessed for the battery to be CE marked. This is from a course I did decades ago when CE was introduced, it was a fundamental concept. At that time I was involved in designing drilling rig components that were assembled from various individual parts.
st599
Well-Known Member
I'm not. The battery is the cells and control hardware. The insurance text talks about the battery.
PaulRainbow
Well-Known Member
My power system comprises of batteries connected in series and parallel, mains chargers, solar charger, DC-DC charger, BMS etc etc. Each component is CE marked, the system is NOT.
When i fit a LFP system i fit individual cells, a BMS and various charging devices. Each is CE marked, as with mine and everyone else's power systems.
PaulRainbow
Well-Known Member
So if i connect a number of batteries in parallel (like almost every boat out there) that string of batteries has to be CE marked ?
How about if i connect 4 x 12V batteries in series to make 48V (same as connecting 4 x 3.2V cells in series to make 12V) the whole thing has to be CE marked ?
PaulRainbow
Well-Known Member
So if a device has 2 x AA batteries (single cell) in it those 2 batteries have to be CE marked collectively ?
RunAgroundHard
Well-Known Member
From my memory of the course. Your first example, not if the boat has already been sold into the market where CE applies.
In the second example, if doing that to a boat not yet placed on the market where CE is applied to the boat , then yes, if new battery is a change to the CE marked design. You would have to demonstrate that the change was compliant. This last point was a significant complaint about CE and small scale builders and customisers of products.
I don’t know about the current status of CE, so happy to be corrected, also CE status in the UK, or its replacement, if any, post Brexit.
ylop
Well-Known Member
My understanding is that if someone buys 4x12V assembled them together and sells that as a product it has to be CE marked, but if someone buys 4x12V and installs that then it doesn’t. Certainly that’s how it works in other CE marking regimes (safety equipment, medical devices etc).
Do the regs apply in the UK? Most of the old CE regs were cut and pasted as UKCA rules but batteries might be too new for that? Of course nothing to stop an insurer “demanding” a “foreign” accreditation if they thing the UK is too soft.
PaulRainbow
Well-Known Member
But the discussions on here are all about boats already on the market.
PaulRainbow
Well-Known Member
That's my point and why i believe post #221 is incorrect. If someone buys 4 LFP cells and fits them together in series, adds a BMS, mains charge etc all he as done is to assemble a collection of individually CE marked equipment.
st599
Well-Known Member
Yes, but that doesn't give you a CE marked battery which is what the insurance text requires, it gives you a battery made of CE marked parts. If that battery is permanent (i.e. it has been manufactured), it would need CE before it could be sold.
PaulRainbow
Well-Known Member
Nonsense. When the cells are purchased individually and so fitted It gives 4 x 3.2V single cell batteries in series.
Besides, you're just quoting from one insurance company, which means nothing. But, in their example it would be correct that a battery that was purchased as a single component would need CE certification.
You are confusing manufacturing a new product from CE marked components and using a number of CE marked devices to assemble a system etc. If your claims about DIY fitting of individual cells was correct CE certification would need to be sought just to fit a solar panel and controller, or to install shore power where the components were individually purchased. Plus a billion other things.
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RunAgroundHard
Well-Known Member
I can see the logic in that point. What does CE mean. I reckon if the cells are CE marked, the BMS is CE marked and the assembled cells are connected in a designed manner for the current ratings, then it complies with the insurance company’s requirements. They of course, might disagree and believe that the assembled battery shall be CE approved. Likely they want the user to buy a pre approved battery, minimising their risk.
It’s an interesting point being made, especially in a UK jurisdiction that doesn’t require CE marking (I think).
It’s an interesting point being made, especially in a UK jurisdiction that doesn’t require CE marking (I think).
ylop
Well-Known Member
Well if you were the insured you’d perhaps want to verify their interpretation is the same as yours - or find an insurer who agrees. A strict interpretation of the words in post 208 would suggest that that insurer doesn’t want DIY assembled batteries and only wants CE marked Batteries - it’s not a direct quote, and there in no certainty that the person quoted knew the difference between a battery and a cell.
The battery regs stop some guy in his garage from buying cells that have CE marks, spot welding them together into a battery (with or without a BMS) and reselling them within the EU (legally), unless he is prepared to go to a lot of admin and expense. That’s probably a good thing in general.
They don’t stop someone buying components and assembling them for their own use. If carefully worded they wouldn’t stop someone engaging a specialist to come and design and install an installation made from certified components.
I wonder if there’s actually a market opportunity for a credible name to produce a kit which is insurance endorsed.
st599
Well-Known Member
I haven't checked the UKCA version, but the original text about certifying products is a copy and paste.
PaulRainbow
Well-Known Member
A cell is a battery.
Agreed.
They don't stop someone fitting multiple cells, a BMS, mains charger etc as long as they are not all assembled into a single product and marketed. If they did, no-one would be able to fit any 2 or more devices together to make anything. For instance, you wouldn't be able to buy a TV and connect it to a soundbar to make an entertainment system.
Dunno, but i've yet to have an issue with any of my LFP installations.
PaulRainbow
Well-Known Member
That's if you are making batteries from CE marked cells and marketing them, not for individually buying items and fitting them to your boat.
