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61/5831/RVC

RESULT OF VOTING ON CDV (RVC)

PROJECT NUMBER:

IEC 60335-1/FRAG3 ED6

DATE OF CIRCULATION:

2019-04-19

REFERENCE NUMBER OF THE CDV:

61/5735/CDV

IEC TC 61 : SAFETY OF HOUSEHOLD AND SIMILAR ELECTRICAL APPLIANCES

SECRETARIAT: SECRETARY: CHAIR:

United States of America Ms Randi Myers Mr Fabio Gargantini

OF INTEREST TO THE FOLLOWING COMMITTEES: HORIZONTAL STANDARD:

SC 61B, SC 61C, SC 61D, SC 61H, SC 61J

FUNCTIONS CONCERNED:

EMC ENVIRONMENT QUALITY ASSURANCE SAFETY

SUBMITTED FOR CENELEC PARALLEL VOTING NOT SUBMITTED FOR CENELEC PARALLEL VOTING

The CDV document was distributed to National Committees with a request that voting take place for circulation as a FDIS or publication as an International Standard.

P-MEMBERS VOTING

MEMBERS VOTING P-MEMBERS IN FAVOUR IN FAVOUR % CRITERIA RESULT

34 31 91.2 ≥66,7 % APPROVED

ALL VOTES

TOTAL VOTES CAST TOTAL AGAINST AGAINST % CRITERIA RESULT

37 3 8.1 ≤25 % APPROVED

The chair (in cooperation with the secretariat and the project leader) has taken the following course of action:

WHEN THE APPROVAL CRITERIA HAVE BEEN MET:

A1 THE COMMITTEE DRAFT FOR VOTE (CDV) WILL BE REGISTERED AS A FDIS BY 2019-07-31

A2 THE COMMITTEE DRAFT FOR VOTE (CDV) WILL BE REGISTERED AS AN IS BY

WHEN THE APPROVAL CRITERIA HAVE NOT BEEN MET:

B A REVISED COMMITTEE DRAFT FOR VOTE (CDV) WILL BE DISTRIBUTED BY

C A REVISED COMMITTEE DRAFT (CD) WILL BE DISTRIBUTED BY

D THE COMMENTS WILL BE DISCUSSED AT THE NEXT MEETING OF ON

A2 When proceeding directly to publication, no changes to the technical content of the enquiry draft shall be made.

In the case of a proposal B or C made by the chair, if two or more P-members disagree within 2 months of the circulation of this compilation, then the draft shall be discussed at a meeting.

TITLE:

Household and similar electrical appliances - Safety - Part 1: General requirements

NOTE FROM TC/SC OFFICERS:

This document will be discussed during the TC 61 Plenary meeting in Bled, Slovenia, 3-7 June 2019. After the meeting, a revised RVC document will be circulated with the confirmed Observations of the Secretariat included.

Annexes: Result of voting, Comments received

61(Bled/WG31)46

June 2019

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Voting Result on 61/5735/CDVCirculation Date: 2018-12-28 Closing Date: 2019-03-22IEC 60335-1/FRAG3 ED6: Household and similar electrical appliances - Safety - Part 1: General requirementsCountry Status Vote Comments ReceivedAlbania P -Argentina O -Australia P Y - 2019-03-06Austria P Y - 2019-03-21Belarus O Y - 2019-03-22Belgium P A - 2019-03-22Brazil O A - 2019-03-22Bulgaria O -Canada P Y - 2019-03-12China P Y - 2019-03-11Czech Republic P Y - 2019-03-15Denmark P N Y 2019-03-22Egypt P Y - 2019-03-20Finland P Y - 2019-03-21France P Y Y 2019-03-19Germany P Y Y 2019-03-22Greece P Y - 2019-03-21Hungary P Y - 2019-03-22India P Y - 2019-03-19Indonesia P A - 2019-03-19Iran P A - 2019-03-17Ireland P A - 2019-01-04Israel P A - 2019-03-21Italy P Y - 2019-03-21Japan P N Y 2019-03-22Korea, Republic of P Y - 2019-03-22Kuwait O -Malaysia P Y - 2019-03-21Mexico P Y - 2019-03-22Netherlands P Y Y 2019-03-22New Zealand P Y Y 2019-03-05Norway P Y - 2019-03-07Pakistan P Y - 2019-03-19Philippines, Rep. of the P Y - 2019-03-19Poland P Y - 2019-03-19Portugal P A - 2019-03-22Qatar O Y - 2019-03-19Romania O -Russian Federation O Y - 2019-03-21Saudi Arabia O -Serbia P Y - 2019-03-15Singapore O -Slovakia O -Slovenia P Y Y 2019-02-16South Africa P A - 2019-03-22Spain P A - 2019-03-14Sweden P N Y 2019-03-19Switzerland P Y - 2019-03-19Thailand P Y - 2019-02-26Turkey P Y - 2019-03-20Ukraine P Y - 2019-03-21United Arab Emirates - - - 2019-03-17United Kingdom P Y - 2019-03-20United States of America P Y Y 2019-03-12Vietnam P Y - 2019-03-14

Approval Criteria ResultP-Members voting: 34P-Members in favour: 31 = 91.2% >=66.7% APPROVEDTotal votes cast: 37 Total against: 3 = 8.1% <=25% APPROVEDFinal Decision: APPROVED

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Notes

1. Vote: Does the National Committee agree to the circulation of the draft as a FDIS: Y = In favour; N = Against; A = Abstention.2. Abstentions are not taken into account when totalizing the votes.3. P-members not voting: Albania(1).

*Comments rejected because they were not submitted in the IEC Comment form. **Vote rejected due to lack of justification statement.

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Date Document Project Nr.2019-03-22 61/5735/CDV 60335-1/FRAG 3 ED6

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1 ZA01 ge ZA NC accept 61/5735/CDV the no technical comment:

Noted

2 DK01 ge As commented earlier DKNC supports the intention and background for the proposal. However, the content and phrasing will need to be reconsidered and modified throughout to ensure correct and appropriate implementation into the standard. Requirements of annexes of IEC 60355-1 always modify the main body of the standard and cannot be applied separately to products as assumed in §5.17 of the proposal. Even if §5.17 is accepted there are still several in inconsistencies in how to apply the annex. Additionally, some specific tests and conditions and requirements seem to be inadequately specified.This leads to a negative vote since it’s not feasible to have a published standard where the application and requirements are not clear and consistent.In the detailed DKNC comments, examples of the mentioned inconsistencies can be found, however they cannot be seen as complete.

Rewrite the annex such that the application of the requirements becomes clearer and consistent.

Not accepted. The Annex text follows the usual style – see line 98

3 JP01 ge We do not agree to the CDV for the following reasons.

- For battery packs, the proposal does not completely refer to necessary requirements of IEC 62133 and includes unique requirements not harmonized with IEC 62133.

- Requirements for metal-ion batteries should be only applicable to lithium-ion batteries.

- Clause B.11.101 requires the unpractical temperature measurement on all of the cells.

- Clause B.11.101 and B.19.106 require the unique and complicated cell-imbalance test.

- B.20.101 and B.20.102 includes unique and difficult test gas release test for vent.

Noted

WG31:These aspects have been discussed in length in the previous documents.

The necessary requirements with regards to battery safety have been addressed in this proposal.

It was an earlier decision to convert Lithium/Lithium-ion to Metal-ion.

The imbalance test and test gas release test have been used in other standards and successfully used by test laboratories.

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4 DK02 ge In some clauses of Annex B, it is explained how the clause shall be inserted in the main standard, and in other clauses there are no explanation. It is necessary to be consistent and to decide whether Annex B shall be used completely without the main part of the standard or be used together with the main part. See DK03 for further details

Noted

5 DE01 2 1 ed Comment NZ1 on 61/5696/CD was accepted (see 61/5721A/CC) but not correctly implemented

Replace current text by:Replace 2nd sentence of NOTE 1 by "Dual supply appliances are regarded as battery-operated appliances when deriving their energy from batteries."

Accepted

6 DK05 14 2 ed The reference to IEC 61058-1-1 is already included in 61/5733/CDV (FRAG 4)

Delete line 14 It will be covered by the FDIS

7 DK06 34 3 ed It is unclear why these new definitions are included in the main part of the standard and not in Annex B considering that they relate specifically to battery operated appliances

Move these new definitions to Annex B To be discussed. These symbols were moved from existing Annex B to 7.6 by WG31 when the prepared 61/5178/DC. The document has been through further changes stages 1Dc, 2DC, 1CD and 2CD.withour any proposal to change.

WG31: Not accepted

The reason for having the definition in the main part is that the terms are already used in the main part of the standard (eg. 5.17, 8.2) and not only in Annex B

8 NZ01 45 3.6.10 NTE ed Grammar Correction Replace “A detachable battery or separable battery have an enclosure” with “Detachable batteries and separable batteries have enclosures”

Accepted

WG31: Accepted with modification

Detachable batteries and separable batteries have enclosures that are ……..

9 NL01 45-47 3.6.10 ed The note refers to the defined term 'integral batteries’ while the definition is only given in annex B. Terms used in the main part of the standards should be defined in clause 3 of the main part of the standard.

Move the definition for 'integral batteries' from annex B to clause 3 of the main body of the standard.

Accepted.

10 US01 46 ed Correction Replace “then” with “than” Accepted

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11 NL02 48-52 3.6.11 te/ed The definition of detachable battery can be improved In order to make a better distinction between the terms detachable battery (where the battery is directly connected to the appliance by attaching it to the appliance) and separable battery (where the battery is remote from the appliance and connected to the appliance via a cord).Further the phrase ‘or range of appliances’ does not add value. There is no need to indicate appliance both in single and plural form.

Modify the definition as follows:detachable batterybattery in an enclosure separate from the battery-operated appliance, that is attached to the appliance, and intended for use with specific appliances a specific appliance or range of appliances and intended to be removed from the appliance for charging purposes

Accepted

WG31: Accepted in principle

detachable batteryrechargeable battery in an enclosure separate from the battery-operated appliance, that is attached to the appliance, and intended for use with specific appliances and intended to be removed from the appliance for charging purposes

12 DE02 53 3.6.11 Note 1 to entry

ed Comment NL5 on 61/5696/CD was accepted (see 61/5721A/CC) but not correctly implemented

Print the defined term "detachable battery" completely in bold font

Accepted

13 NZ02 53 3.6.11 NTE 1 ed Style correction Bold “detachable battery” See comment 1214 DE03 54 3.6.11 Note 2 to

entryed Comment NZ6 on 61/5696/CD was accepted

(see 61/5721A/CC) but not correctly implemented

Print the defined term "battery" in bold font Accepted – also print the adjective associated with the noun in bold font

15 NL03 55-59 3.6.12 te The word ‘separable’ indicates the ability to be separated from something. However the term is used throughout the annex for both batteries that can be disconnected from the appliance and those that are permanently connected to the appliance by a cord.As a consequence the word ‘separable’ in the term is not appropriate and should be replaced by ‘separate’.

Modify the term as follows:separable separate battery

And as a consequence modify the term used throughout the complete standard.

Not accepted. This term has been used through stages 1DC, 2DC, 1CD, 2CD

16 NL04 55-59 3.6.12 ed NLNC proposes a few improvements to the definition of ‘separable battery’:1.When following the definition of separable battery, a separable battery could consist of either rechargeable batteries or non-rechargeable batteries, while the Annex B requirements for separable batteries do only make sense for rechargeable batteries.This is also in contrast to a detachable battery which is per definition limited to only rechargeable batteries.The definition of separable battery should therefore also be limited to rechargeable batteries.2.We suppose the aim of the phrase ‘external to the enclosure of the appliance’ is to make

Modify the definition as follows:separable batteryrechargeable battery contained in an enclosure separate from the battery-operated appliance and connected to the appliance by a cord external to the enclosure of the appliance, intended for use with specific appliances a specific appliance or range of appliances.

The change to the term is not accepted. The change to the term definition is accepted.

WG31: The term is “separable battery” not altered here. The word “rechargeable” in front of “battery” is needed here to avoid confusionThe proposed definition change is accepted.

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clear that this term does not cover batteries inside the appliance however this is already clear from the rest of the definition and can therefore be deleted to keep the definition compact and simple.3.The phrase ‘or range of appliances’ does not add value. There is no need to indicate appliance both in single and plural form.

17 NL05 60-61 3.6.12 ed This note is superfluous. Throughout the whole annex, when requirements apply for separable batteries that are charged while disconnected from the appliance, these batteries are specifically mentioned in addition to detachable batteries.See e.g.:3.1.9 first dash7.1 penultimate paragraph (lines 269, 270)7.12 penultimate paragraph (lines 345, 346)

Delete note 1 to entry, and renumber the remaining notes.

Accepted

18 DE04 63 3.6.12 Note 3 to entry

ed Comment NZ7 on 61/5696/CD was accepted (see 61/5721A/CC) but not correctly implemented

Print the term "replaceable" in regular font Not accepted – Refer to the text in the Foreword “Words in bold in the text are defined in Clause 3. When a definition concerns an adjective, the adjective and associated noun are also in bold.”

19 NL06 63 3.6.12 Note 3 to entry

ed The term replaceable battery should not be bold as this is not a defined term.

Unbold ‘replaceable battery’. See comment 18

20 DK03 65 ge Based on how the §5.17, Figure B.1 and the beginning of Annex (line 105-106) in the proposal is written, it is unclear Annex B shall be used and how it relates to the rest of the standard.This is the main reasons for the DKNC negative vote. It is not feasible to have a published standard the application and requirements of which are not clear and consistent§5.17 specify that: battery operated appliances are tested in

accordance with Annex B and battery operated appliances with a supply

connection are tested in accordance with the relevant clauses of “this standard” and Annex B

This coincide with Figure B.1 indicating that appliance shall be tested to Annex B (alone) in all cases where it is operated on battery power alone not utilizing a mains connection.

Discuss and decide when Annex B apply and how it relates to the rest of the standard and then modify the text accordingly.

Not accepted. The structure has been the same through stages 1DC, 2DC, 1CD and 2 CD

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Together this means that when battery operated appliances have no supply connection or are tested without the supply connection, Annex B apply alone without the “main part” of the standard.This however does not correspond with the specification in line 105-106, which indicate that the annex is also applicable to battery appliances with a supply-connection (as long as it can be operated also without the supply connection).This inconsistency prevents a clear and unambiguous understanding of the application of Annex B.

21 NL07 66-67 5.17 te Not all appliances containing batteries are battery-operated appliances.However appliances that do contain batteries but that are not battery-operated appliances, do also have to be examined according annex B.

Modify the sentence as follows:Battery-operated appliances, and appliances or parts of appliances containing batteries, such as remote controls, are tested in accordance with Annex B.

Not accepted. This is a major technical change that has not been discussed before.

22 DK07 68 5.17 te Requirement suggest that a functional earth connection can exist without being part of a supply connection. It is not clear what would be the purpose of a functional earth connection if the appliance does not have a supply connection to the mains (no electrical reference to earth)

Delete “…an earth connection for functional purposes or …” in line 68 so that the proposal reads:A battery-operated appliance with a supply connection is tested in accordance with the relevant clauses of this standard and Annex B

Not accepted. Appliances can have a functional connection without using the supply connection. See SC 61H appliances for example.

23 NL08 68 5.17 ed For consistency the sentence should editorially be aligned to the first sentence of this clause where battery operated appliances in plural form is used.Further, regarding the earth connection, the purpose of the earth connection is not relevant.

Change the sentence to:A bBattery-operated appliances with an earth connection for functional purposes or a supply connection is are tested in accordance with the relevant clauses of this standard and Annex B.

Not accepted – see the decision on comment 29 in 61/5721A/CC

WG31: Not accepted but modify editorially.

Battery-operated appliances with a functional earth connection for functional purposes or a supply connection are tested in accordance with the relevant clauses of this standard and Annex B.

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24 NL09 69 5.17 ed/te The statement that the appliance is tested with this standard and annex B should be clarified. It is now unclear what testing ‘according this standard’ means. E.g. testing according annex B alone could also be interpreted as testing according this standard.Our proposed modification will also bring the text in line with the wording used in figure B.1.

Change the sentence as follows:….in accordance with the relevant clauses of the main part of this standard and Annex B.

Accepted

25 DK08 74 7.6 ed It is unclear why these marking requirements are included in the main part of the standard and not in Annex B considering that they relate specifically to battery operated appliances and batteries

Move the proposed addition to Annex B See comment 7

WG31: Not accepted

These symbols were moved from existing Annex B to 7.6 by WG31 when the prepared 61/5178/DC. The document has been through further changes stages 1DC, 2DC, 1CD and 2CD without any proposal to change.Furthermore they could be used for other dc products.

26 NL10 73-74 7.6 ed The symbols are only used in annex B and should therefore be added to annex B instead of to the main part of the standard.

Move the addition to clause 7.6 of annex B. See comment 7WG31: see comment 25

27 DK09 75 8.2 te This requirement seems to follow naturally from the existing §8.2 and the general principle of the standard and do not add value.

Delete the proposed addition Not accepted. It is applicable to type Figure B.1 (a) appliances for example.

28 DK10 77 8.2 te See comments regarding “earth connection for functional purpose” in DK07

Noted

29 NL11 77-78 8.2 te The purpose of the earth connection is not relevant.

Change the sentence as follows:For a battery-operated appliance where the battery circuit has an earth connection for functional purposes or a supply connection

Not accepted – see comment 23

WG31: Not accepted but modify editorially

For a battery-operated appliance where the battery circuit has a functional earth connection or a supply connection

30 NL12 78 8.2 ed Replace ‘the’ by ‘a’ as not all appliances will have a battery compartment.

Change the sentence as follows:….it shall only be possible to touch parts within the a battery compartment….

Accepted

31 NL13 80 8.2 te The first dashed item implies that it is acceptable to touch parts that operate on SELV voltage.

Modify the first dashed item as follows:- where the battery compartment is of

class III construction, provided that

Accepted in principle. If the limits in 8.1.4 are exceeded, then basic insulation is required. Referred to

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This is however a contradiction to 8.1.4 where the voltage limits are reduced to less than SELV in order to consider a part safe to touch. For SELV with voltages higher than 8.1.4 basic insulation is required.For reference:3.3.13class III constructionpart of an appliance for which protection against electric shock relies upon safety extra-low voltage and in which voltages higher than those of safety extra-low voltage are not generated3.4.2safety extra-low voltagevoltage not exceeding 42 V between conductors and between conductors and earth, the no-load voltage not exceeding 50 V

the limits from 8.1.4 are complied with; EG1.

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32 US02 80-82 8.2 te Class 0 appliances have inadvertently been removed from the options, so the dashed item from 61/5596/CD should be included.

Replace the period with a semicolon at the end of the second dashed item and add a third dashed item, as follows:Where in Class 0 appliances, they are separated from live parts by basic insulation.

Not accepted. The exclusion was not inadvertent. Refer to the decision on comment 30 in 61/5721A/CC

WG31: Accepted“The exclusion was not inadvertent. Refer to the decision on comment 30 in 61/5721A/CC” does not adequately respond to the comment and proposed change. The initial NZ7 comment in the compilation did not propose deleting reference to class 0 appliances nor did it provide rationale for the deletion. The existing standard defines class 0 as an “appliance in which protection against electric shock relies upon basic insulation only.” Deleting the reference to class 0 effectively requires a battery-operated appliance to have more stringent requirements in a battery compartment than applicable to the construction of all other class 0 appliances. The proposed change (punctuation and adding dashed item) should be accepted.

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33 DE05 84 21 / 21.1 ed Comment FR3 on 61/5696/CD was accepted (see 61/5721A/CC) but not correctly implemented

Add "21.1" in front of "Add the following…" Accepted

34 NL14 83-91 21 ed No subclause indicated.FR03 was accepted with modification. The modification of this comment was processed in the CDV but not the original comment: To add the sub-clause.

Modify as follow:

21 Mechanical strength 21.1 Add the following text after the NOTE. For appliances and parts of appliances having pins for insertion…

See comment 33

35 US03 84 21 ed As noted in the previous compilation of comments, this should be an addition to 21.1.

Replace line 84 as follows: 21.1 Add the following text after the NOTE.

See comment 33

36 NL15 96-97 Annex B Title ed The title does not reflect the scope of annex B.Annex B deals with (see also 5.17 of the main part of the standard):-Battery-operated appliances-Appliances or appliance parts with batteries-Detachable batteries-Separable batteriesThe title can be simplified while including all above options.

Replace the title by the following:Appliances employing batteries including detachable batteries and separable batteries

See comment 21

37 NL16 98-102 Annex B te The list is not complete.Annex B also deals with appliances that are not battery-operated appliances, but that do contain batteries.For consistency, the sentence in line 102 should become a fourth dashed item.

Replace the sentence from line 102 by the following:-appliances, and parts of appliances, containing batteries

See comment 21

38 NZ03 99-106 Annex B ed The content of these lines is covered by the text in 5.17 and is a duplication.

Review lines 99-106 and 5.17 to avoid duplication.

Referred to EG1.Also see comment 42

WG31: It is indeed a kind of duplication. The intent of cl. 5.17 is to explain how Annex B is used.Lines 99 – 106 are there to explain the purpose of Annex B. WG31 feels that omitting in either section could confuse readers and incorrect application of the requirements. Hence is in favor to keep text as it is currently.

39 DE06 102 Annex B Introduction ed Dot missing Add a dot after "controls" Accepted – it was in the Word version submitted to project dashboard

40 DE07 103 Annex B Introduction ed Wrong format of a non-defined term Print "metal-ion" in regular font See comment 18

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41 DK11 103 Annex B te The term “metal-ion batteries“ is in bold, but the proposal does not include a definition of it. A definition of this is important for the correct application of the standard and must be added.

Add a definition of a metal-ion battery Not accepted. It is well known that the metal ions provide the energy by flowing between the electrodes. Metal-ion was introduced to cover all metal-ion battery chemistries.Refer to the decision on comment 39 in 61/5689A/CC and comments 39, 108,109 in 61/5721A/CC

42 NL17 105-106 Annex B te The sentence does not add value and can even lead to misunderstanding.Also appliances, that contain batteries, but that cannot perform its intended function without a supply connection are also in the scope of annex B !Therefore it is irrelevant if the appliance can or cannot perform its intended function without a supply connection.

Delete the sentence and note 1. See comment 38

43 NL18 107-114 Annex BIntroduction

ge The NLNC has difficulties understanding NOTE 1 and NOTE 3. In relation the decision on NL01 in Busan and the inconsistencies in the main part of the standard and in the new proposed Annex B.How does a does a supply connection to a renewable energy source look like? Can this be a USB connection with a voltage of 5 V?

NOTE 3 states “When supplied in parts .. “. Suggest there is an option to deliver the detachable power supply.This is further supported by the requirement to mark in the instructions “Connect to an external supply for charging the battery” (lines 337-339) explaining that an appliance for recharging needs to be connected to the supply mains.

To be discussed in combination with NLNC proposal 61/5775/DC.

Not accepted. The document has been through further change stages 1DC, 2DC, 1CD and 2CD.withour any proposal to change in any substantial way. The text in Note 3 does not override 22.56 in the main part of the standard.

Lines 337 – 339 apply to appliances of the type in Figure B.1 (a).Lines 345 – 348 apply to appliances of the type in Figure B.1 (e).

Lines 340 – 343 apply to appliances of the type in Figure B.1 (b), (c), (d) and (f)That are consistent with the text requested by FR 9 and decision 111 in 61/5721A/CC)

WG31: TO BE DISCUSSED

It has not been commented before as there was a difference in understanding. This difference in understanding became only clear after the IEC TC61 made its

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decision on enquiry NL01. See also 61/5775/DC.There is a major conflict which needs to be resolved and it has impact on Annex B.

A detachable power supply is principally only needed when the charging circuitry is located in the detachable power supply. In other cases the charging circuitry is located in the battery, the appliance or the battery charger. Except for the latter the supply of a voltage is sufficient. This can be either an SELV supply, a renewable energy source, another battery.In fact there is inconsistency within this proposed Annex B (lines 337-339 versus lines 340-344)

44 DE08 115 Annex B Introduction, NOTE 3


Replace "Fig." by "Figure" Accepted – it was in the Word version submitted to project dashboard

45 SE01 115 Annex B ed Except for Fig B1 it is not completely clear when main part of standard or Annex B is applicable.

Move line 115 and insert it below line 106.This will make Fig B.1 normative.

To be discussed.

WG31: Accepted to move the line.Figures are always there to support text in understanding. Text is leading.

46 DE09 116 Annex B Introduction, NOTE 4

ed Wrong format of a non-defined term Print "Li-ion" in regular font See comment 18

47 US04 116 Introduction, Annex B

Note 4 ed The first two sentences of the Note are run together.

Add a period after “Li-ion battery systems” and capitalize “Other”

Accepted

WG31: Accepted in principle.Use a comma instead of a period. And do not capitalize ‘other’.

48 NL19 125-128 3.1.9 ed The sentence ‘...the appliance is operated to perform its intended function with a fully charged battery’ implies that the appliance must be tested with a battery that is to be kept fully charged during the test. Our proposal brings the text in line with that of the second dashed item (first two bullets) where also the word ‘initially’ is used.Further, the term ‘fully charged’ should be bold.

Modify the sentence as follows:…the appliance is operated to perform its intended function with a fully charged battery that is initially fully charged.

Accepted

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49 DK12 128 3.1.9 te The only specification of the battery required to be in the manual is the “battery type” as indicated in line 330. It is not clear if the requirement to provide the “battery type” is the same as required here to ensure that only the specific model of battery (including voltage, capacity etc) is being used.

Modify the proposed text to ensure that the requirement is clear and unambiguous

To align with the text in clause 7 in line 127 dd “or type reference: after “model”

50 JP02 129 3.1.9 1 te We propose modifying the 2nd dash to replace “non-replaceable integral batteries” with just “integral batteries” as the following reasons.

- All types of integral batteries have the same conditions of normal operation for daily use until the battery is replaced due to permanent deterioration.

- According to the proposal, user-replaceable integral batteries are covered by the 3rd dash (operated only by artificial source, not by the battery), and user-replaceable integral batteries are not subject to temperature rise test for cells.

In the 2nd dash, replace “non-replaceable integral batteries” with “integral batteries” as follows.

–for appliances operated with non-replaceable integral batteries or separable batteries not disconnected from the appliance for charging purposes, and that

Not accepted. The text aligns with the decision on comment 47 in 61/5721A/CC taking into account the instruction to EG1 in comment 101 in 61/5721A/CC

51 NL20 129-139 3.1.9 te NZ12 was accepted with modification, however the CDV is not reflecting this.Furthermore the term ‘user replaceable’ should not be bold.See yellow-highlighted text

Replace 2nd dashed item by:

- for appliances operated with non user-replaceable integral batteries or separable batteries not disconnected from the appliance for charging purposes, and that: • can perform their intended function while the batteries are being charged, the batteries shall initially be fully discharged with the battery-operated appliance performing its intended function. • cannot perform their intended function while the batteries are being charged, the batteries shall initially be fully charged and the battery-operated appliance shall perform its intended function • can perform their intended function while the batteries are being charged the fully discharged battery is charged without the battery-operated appliance performing its intended function.

Not accepted. Refer to the decision on comment 101 in 61/5721A/CC and the request to EG1.

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52 DK13 131-133 3.1.9 te This part of the definition relates to operation while connected to a supply source and does not belong in Annex B

Move this part of the requirement to the main part of the standard which in accordance with §5.17 cover operation of the appliance while connected to a supply source.

Not accepted. It aligns with the modification to 11.7 in the Annex.

WG31:In addition to the comments of the secretariat, Annex B covers also charging and the specific risks associated with that.

53 DK14 137-138 3.1.9 te This part of the definition relates to operation while connected to a supply source and does not belong in Annex B

Move this part of the requirement to the main part of the standard which in accordance with §5.17 cover operation of the appliance while connected to a supply source.

See comment 52

54 DE10 140 Annex B, 3.1.9

Last dashed item

ed Wrong format of a non-defined term Print "replaceable" in regular font See comment 18

WG31 When a definition concerns an adjective, the adjective and associated noun are also in bold.

55 DE11 140 Annex B, 3.1.9

Last dashed item

ed Comment JP6 on 61/5696/CD was accepted (see 61/5721A/CC) but not correctly implemented

Add after "replaceable batteries" the following text: ",other than non user-replaceable integral batteries,"

Not accepted – it was reviewed by EG1 in accordance with the decision on comment 101 in the referenced CC

56 JP03 140 3.1.9 1 te According to JP 1, to clarify the interpretation in 3rd dash, it is better to insert “other than integral batteries”.

In 3rd dash, insert “other than replaceable integral batteries” as follows.–for appliances operated with replaceable batteries, other than integral batteries, or non-rechargeable batteries, the appliance is operated with the artificial source described in 5.B.101 with the specified upper limit short circuit current capacity Isc (high) as indicated in Table B.101.

Not accepted. See comment 50

57 NL21 140-142 3.1.9 te In the understanding of NLNC replaceable batteries include both rechargeable and non-rechargeable batteries that are intended to be removed by the user for recharging or replacement in case of depleted non-rechargeable batteries. Therefore there is no reason to specifically mention non-rechargeable batteries in addition to replaceable batteries, unless the intention is to apply the artificial source also for integral batteries when they are non-rechargeable.(See also comment NL22 on the proposal on replaceable batteries clarification)

Modify the last dashed item as follows:-for appliances operated with replaceable batteries or non-rechargeable batteries integral batteries that are non-rechargeable, the appliance is operated with the artificial source described in 5.B.101 with the specified upper limit short circuit current capacity Isc (high) as indicated in Table B.101.

Not accepted. Refer to the decision on comment 48 in 61/5721A/CC) and the request to EG1 to EG1 as per comment 101 in 61/5721A/CC

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58 DK15 141 3.1.9 te When specifying the use of an artificial source instead of an actual battery, the effects of any heat development (including overheating) in an actual battery will not be included in the test. Such heating/overheating could result in melting or otherwise negatively affect the appliance; in particular the battery compartment.

As this effect may potentially affect the safety of the appliance it appears more correct to use an actual battery for the testing.This actual battery may be an “average” of what is available for purchase in the market.

Modify the proposal to prescribe testing with an actual battery taken from the market and for example pretested to show a defined minimum characteristic.

Not accepted. This is a test for normal operation and the artificial source is used for reproducibility purposes.

59 DK04 Annex B ge Following DK03, the indications throughout Annex B, how the text relate to the main part of the standard are confusing and not consistent The problem can be exemplified by the following: line 200 is an “addition” (to main standard) lines 209-212 is a “deletion” (of part of the

main standard) line 241 does not relate to the main

standard but appear to be separate line 361 exclude applicability of §8 for

some appliances and so assuming the §8 (in the main standard) apply in other cases

line 453 directly address parts (of the main standard) to apply.

line 650-664 (§21.1) is in essence a replication of the text (of the main standard), suggesting that the main part shall not be applied.

A full list of these inconsistencies is provided below

Discuss and decide when Annex B apply and how it relates to the rest of the standard and then modify the text accordingly.

Line 200: Correct although it could be designated B.5.10x.Lines 209-212: Yes -in terms of an Annex it indicates a modification.

Line 241: It refers to the parts of the appliance designated “A” in Figure B.1 (b), (c), (d) and (f)Line 361: CorrectLine 453: Correct. The apply to the parts of the appliance designated “A” in Figure B.1 (b), (c), (d) and (f) and Figure B.1 (a) and (e) when they are operated on the battery supply.Line 650-664 Correct. It refers to the parts of the appliance designated “A” in Figure B.1 (b), (c), (d) and (f). For the appliance in Figure B.1 (a) apply the main part of the standard or Annex B whichever is more unfavourable

60 NL22 144-149 B.3.6.101 te The NLNC experiences difficulties the scope of the terms ‘integral battery’ and ‘replaceable battery’.1.Under the current definition an integral battery can be both a rechargeable or non-rechargeable battery. Non rechargeable because a non-rechargeable battery meets the condition that it is not removed for charging purposes (a non rechargeable battery is removed for disposal / replacement purposes).

Modify the definition as follows:integral batterybattery contained within the battery-operated appliance and not removed from the appliance for charging purposes not intended to be removed by the userNote 1 to entry: A battery that is only to be removed from the battery-operated appliance for disposal or recycling when the appliance is scrapped is still considered to be an integral battery.

Not accepted, A user can always remove an integral battery and replace it with something else unless it is of a type that cannot be removed without breaking the appliance.

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Considering that some appliances use non-rechargeable batteries integrated in the appliance for e.g. memory retention, it does actually make sense that non-rechargeable batteries fall under integral batteries.However some understand an integral battery to be limited to only rechargeable batteries.Therefore we propose to improve the definition.2.Annex B uses the term replaceable batteries without any further explanation or definition. When taking the general meaning of the word ‘replaceable’ all batteries (except those that are permanently integrated in the appliance and thus cannot be replaced by the user), are replaceable batteries. Even detachable and separable batteries can be replaced by the user and would thus be replaceable batteries. The requirements for replaceable batteries are however not written as such. Therefore a definition is to be introduced to define a clear scope on the term replaceable battery.3.A great group of batteries used worldwide are general purpose batteries in the form of AAA, AA, C, D, PP3 and coin cell batteries. These batteries can be present for energizing appliances or appliance parts (e.g. remote controls).These batteries can be either non-rechargeable or rechargeable and are typically removed by the user for the purpose of replacement (non-rechargeable batteries) or for recharging (rechargeable batteries). It is not clear under which group (term) such general purpose batteries fall. NLNC assumes that general purpose batteries intended to be removed by the user for the purpose of replacement (non-rechargeable batteries) or for recharging (rechargeable batteries) are to be considered replaceable batteries in the current meaning of Annex B.

And add new definition:B.3.6.103replaceable batterybattery contained in a battery-operated appliance or appliance part and removed from the appliance or appliance part by the user for the purpose of replacement or recharging.Note 1 to entry: Detachable batteries and separable batteries are not considered to be replaceable batteries in the meaning of this standardNote 2 to entry: General purpose batteries, such as widely available AAA, AA, C, D and PP3 batteries, placed in a battery compartment of a remote control are examples of replaceable batteries Note 3 to entry: Removal of a replaceable battery may require the use of a tool if indicated in the instructions

As a consequence to the above:-the word ‘non-replaceable’ in line 386 (11.7) should be changed to ‘rechargeable’.-In line 558 (B.19.105) the word ‘rechargeable’ should be added before the word ‘integral’.-In line 599 (B.19.106) the word ‘rechargeable’ should be added before the word ‘integral’.

Not necessary it is covered by the dictionary definition of replaceable.

These changes are not necessary.

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61 DE12 181 Annex B, B.3.101.5

NOTE 2 to entry

ed Wrong format of a non-defined term Print "rechargeable" in regular font See comment 18

WG31 When a definition concerns an adjective, the adjective and associated noun are also in bold.

62 FR01 219 B.5.8.101 te If the batteries are non user-replaceable batteries, there is no reason to connect them in the wrong way.

Add at the end of the sentence :"or if the batteries are non user-replaceable batteries".

Not accepted. Since such a connection is unlikely to occur due to the construction of the appliance.

63 DE13 225 Annex B, B.5

Table B.101

te Comment NZ22 on 61/5696/CD was accepted (see 61/5721A/CC) but not implemented

Add a superscript "d" at the end of the following entries in the first column: AAA, AA, C, D, PP3.Add the following new footnote:"d The non-rechargeable types specified are for alkaline types only.

Accepted

64 DK16 225 Table B.101

te The artificial source is generally referenced for use only in connection with appliances operated by non-rechargeable batteries.As such it is not understood why there are artificial source characteristics provided for rechargeable batteries?

Delete the row with “Rechargeable” from table B.101

Not accepted. Because they are replaceable the user could replace them with any suitable battery. One of the tasks of WG was cover this issue.

65 FR02 225 Table B.101

ed Following decision in Busan : 61/5721ea/CC, comment 64 was accepted to add a note d in the table

Add note dThe non-rechargeable types specified are for alkaline types only.

See comment 63

66 NL23 225 Table B.101

te In the third, fourth and fifth column of the second row the word ‘provided’ is used. However rechargeable batteries for which an artificial source is to be used are replaceable batteries as indicated in 3.1.9, last dashed item. Typically replaceable batteries will not be provided with the appliance. Also in the third, fourth and fifth column of the eight row the word ‘provided’ is used. However non rechargeable batteries for which an artificial source is to be used are typically replaceable batteries. Typically replaceable batteries will not be provided with the appliance. Therefore reference must be made to the battery type specified by the manufacturer instead of provided.

Replace the word ‘provided’ by ‘specified’ in the third, fourth and fifth column of the second row and of the eight row.

Not accepted. The document has been through further change stages 1DC, 2DC, 1CD and 2CD.withour any proposal to change. The text is consistent with lines 220-221 which clarifies the use of the short term provided.

WG31: Accepted to introduce

Note 3 As used in this table, “provided” means either the battery that is provided with the appliance or if not provided the battery that is intended or specified to be used with the appliance

67 DE14 230 Annex B, B.5.103

ed Typo Replace "0.5" by "0,5" Accepted – it was in the Word version submitted to project dashboard

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68 DK17 234 6.1 ed This term “powered by batteries” is not used elsewhere.

For consistency and alignment, the same terminology and verbiage should be used throughout.

Replace the term “appliance parts powered by batteries” with the term:“battery-operated appliances”

Not accepted. The parts referred to are the parts of the appliance designated “A” in Figure B.1 (b), (c), (d) and (f)

WG31: see comment 6969 NL24 234 6.1 te The requirement applies both for battery-

operated appliances and appliance parts operated by batteries.

Modify as follows:Battery-operated appliances and appliance parts that are powered by batteries are not classified with respect to protection against electric shock unless the battery-operated appliance or appliance part has a supply connection or where the battery circuit has an earth connection for functional purposes.

See comment 21

WG31: Simplify sentenceBattery-operated appliances without a supply connection or a functional earth connection are not classified with respect to protection against electric shock.

70 FR03 234-236 6.1 ed For good understanding :This clause involves that there will be no class III appliances anymore.Because if the appliance has a supply connection or an earth connection, it will be class I or class II appliance.An appliance powered by primary batteries or an appliance powered by batteries recharged by small solar cells with a voltage below 42V (without earth connection) will have no classification.Consequently the requirements of the Annex A.2 related to class III appliances are no longer considered for this appliance.

Please clarify Referred to WG31

WG31: TO BE DISCUSSED

This is linked with the topic of comment 43

71 NL25 236 6.1 ed The word ‘circuit’ should not be bold as battery circuit is not a defined term.

Unbold the word circuit. Accepted

72 DK18 241 7.1 ed Some of the markings are already mentioned in the main standard and it is unclear if this is a replacement, addition or what.

Please make it clear if this is a replacement or an addition

It is a modification – see line 98.

73 NL26 241 7.1 Te The marking requirements should also apply to parts of appliances containing batteries (e.g. remote control).

Modify as follows:7.1 Battery-operated appliances and parts of appliances containing batteries shall be marked with

See comment 21


To add in line 102:When the term “battery operated appliance” is used it also applies to parts of the appliance.

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74 DK19 242 7.1 te Marking with the voltage would also be relevant in other cases than what is covered here. For example, for appliances using separable batteries and in cases where appliances can be used with more than one specific battery as suggested in line 247-249.Therefor it would be more appropriate to include this in the list of items always required in the marking of the appliance.

Add a new dashed item after line 242:Rated voltage

To be discussed. See current Annex S that requires the battery voltage to be marked. This would equate to Figure B.1 (e) type.

WG31: Not acceptedTo make the judgement of the proper battery there is already a requirement see lines 245-250.

75 NL27 250 7.1 ed Unnecessary capital letters are used. Modify as follows:See instruction manual for additional battery types

Accepted. However note that the document has been through further change stages 1DC, 2DC, 1CD and 2CD.withour any proposal to change.

76 NL28 251 7.1 ed The term ‘replaceable batteries’ can be used here.

Appliances incorporating replaceable batteries that are intended to be replaced by the user shall be marked….

Accepted

77 DK20 255 7.1 te This note appears to be out of context. It is assumed that it relates to the specification in line 274 instead.

Move the note to just after line 274 See comment 79

78 NL29 255 7.1 ed The note does not make sense as in the normative text above the note there is no any reference to general purpose batteries. The note seems to be a legacy from earlier document versions.

Delete the note. See comment 79

79 US05 255 7.1 Note ed The wording in the paragraph above referring to general purpose batteries was deleted, so this Note should be relocated after line 277, which is now the first mention of general purpose batteries.

Relocate line 255 after line 277 Accepted

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80 NL30 261-263 7.1 te In the CD re-write the relation between the symbol and the type reference is completely gone.Use similar wording as done for detachable and separable batteries.

Replace by:

Appliances intended to be supplied from a detachable power supply part for the purposes of recharging the battery shall be marked with symbol ISO 7000-0790 (2004-01). They shall also be marked with symbol IEC 60417-6181 (2013-03) and the model or type reference of the detachable power supply or with the substance of the following:

Use only with <model or type reference> supply unit.

Not Accepted. The text needs to be read in conjunction with the lines 340-343. It is consistent with the text requested by FR 9 and decision 111 in 61/5721A/CC)

WG31: Accepted7.1 is a requirement on marking which has nothing to do with 7.12. Decision on comment 111 (FR9) in 61/5721A/CC was related to the instructions coming from 11.B.101 with the need to clarify the charging system.The NL30 comment is related to the symbols being placed together was accepted also but not found back in the text as written currently.

81 NL31 261-263 7.1 te Separable batteries are in some constructions also intended to be charged via a detachable power supply part. E.g. when the separable battery is not designed to be inserted into a battery charger.In this case the separable battery shall also bear symbol IEC 60417-6181 and symbol ISO 7000-0790 or the text ‘use only with <model or type reference> supply unit’.

Add ‘and separable batteries’ after the word ‘appliances’ in the first sentence.

Not accepted – the current text covers this case.

82 NL32 272 7.1 ed The sentence should end with a colon. Add ”:” at the end of the sentence Accepted83 JP04 273 7.1 9 te This paragraph needs correction.

Due to editing mistake, the text “or Use only with the designated battery charger” is omitted. The omission was not decided in the Busan meeting.

Correct the sentence to add the underlined test as follows.

They shall also be marked with symbol IEC 60417-“battery charger” (2019-xx) and the model or type reference of the battery charger or with the substance of the followingUse only with <model or type reference> battery charger or Use only with the designated battery charger

Not accepted EG1 considered that the underlined was a tautology.

WG31: Accepted in principleIn case of multiple battery chargers it makes sense to have a general statement, as also is done in line 247-250.

Refer to EG1 for drafting the text.

84 DK21 274 7.1 te See DK20 Noted

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85 NL33 274-277 7.1 te In practice no batteries are used that are user replaceable but that are not general purpose batteries (e.g. AAA, AA, etc). Therefore the requirement can be deleted.But most important in IEC 60335 we have no control on user replaceable batteries as these are disposables and replaced by a batteries bought by the user during the appliance life time. Therefore we cannot set requirements for such batteries.

Delete 274-277.

If deletion is not accepted is must be noted that the marking requirements indicated are insufficient for batteries that are user replaceable when it concerns rechargeable batteries that are recharged outside the appliance. The charger symbol and charger model shall be marked similar to detachable batteries and separable batteries that are disconnected from the appliance for charging the battery.

Not accepted. The document has been through further change stages 1DC, 2DC, 1CD and 2CD.withour any proposal to change except for the addition of the last dashed item that was added based on the decision for comment 84 in 61/5532A/INF

86 DK22 277 7.1 te The reference to “voltage” as it relates to batteries is not using a uniform verbiage; “rated voltage”, “battery voltage” and “nominal voltage” seem to be randomly used.

Modification is needed to use same verbiage throughout

Not understood. Only the term nominal voltage is specifically used. But see comment 74 . See also the decision on comment 84 in 61/5532A/INF

87 DE15 297 Annex B, 7.12

ed Non-defined term used, wrong format used Replace "lithium-ion" by "metal-ion" Not accepted – see the decision on comment 162 in the referenced CC

WG31: Accepted88 FR04 297 7.12 te [Line 297 to 302 were added from CD to

CDV without any rational]For integral batteries, these parameters are managed by the BMS (Batteries Management System), which is part of the appliance and then evaluated.These information have no meaning and value for the user in case of non user-replaceable batteries as the user cannot "interfere" with the batteries.

Modify sentence as following :"For appliances intended for use with lithium-ion batteries, unless batteries are non user-replaceable batteries, the instructions shall state:"

Not accepted -see comment 87

WG31: See comment 89

89 DE16 298-302 Annex B, 7.12

te Wrong implementation of comment FR9 on 61/5696/CD was accepted (see 61/5721A/CC):- The 2nd sentence in lines 298/299 is not a marking requirement. In addition, IEC 62133-2 does not require that charging may only take place within the region in between T2 and T3.- The 2nd, 3rd and 4th dashed items are not relevant for the user to be mentioned in the instruction manual. These values are relevant for type testing purposes only and do not need to be mentioned in the instruction manual.

Delete the 2nd sentence in lines 298/299.

Delete the text of lines 300 - 302 completely.

FR9 was implemented correctly – see lines 340 -349

See comment 87

WG31: Accepted

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90 JP05 297-302 7.12 6 te We do not support the additional paragraph for the following reasons.- These markings are technical matters for

manufactures so it is not effective for users.

- The 1st dash of the additional paragraph is covered by the 2nd dash of the next paragraph.

Delete the additional paragraph. (Line 297-302)

Not accepted – see the decision on comment 162 in 61/5721A CC

WG31: See 89

91 NL34 303-304 7.12 te The requirement applies both for battery-operated appliances and appliance parts operated by batteries.

Modify as follows:The instructions for battery-operated appliances and parts of appliances containing batteries shall contain the following information, as applicable…

See comment 21

92 DE17 306 Annex B, 7.12

te The information concerning the recommended temperature range for charging is not relevant for all types of battery operated appliances, only for metal-ion battery operated ones. For metal-ion battery operated appliances, this requirement is already mentioned in line 298.

Delete line 306 completely See comment 87

WG31: Accepted to delete line 306. Temperature ranges for Metal-ion are already covered in line 298. Other battery types are considered not to present a hazard with respect to charging temperature..

93 DK23 330 7.12 te It is unclear what this means. Does this refer to the general types of batteries (Li-Ion, NiMH etc) or to the type of battery as the term is used in table B.101 or does it refer to a unique type reference for the specifically intended battery to be used with the appliance?

Change the text to more clearly indicate what is meant.

If it helps use model or type reference

WG31: AcceptedAdd after “battery type” the words “or battery type reference”

94 DK24 337-339 7.12 te The specification relates to aspects of charging the battery from the supply mains. According to figure B.1, Annex B apply to battery-operated appliances when operated by the battery only. Operation while connected to the mains and any related requirements are contained in the main part of the standard

Move the proposed text to the main part of the standard

Not accepted. Annex B applies when recharging the battery.

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95 JP06 337-339 7.12 14 te We do not support the additional paragraph for the following reasons.- The decision in the Busan meeting did not

include adding this paragraph. .- The content of the additional paragraph can covered by ordinary user instructions under common-sense, so it need not be specified in a safety standard.

Delete the additional paragraph (Line 337-339)

Not accepted, See the decision on comment 111 in 61/5721A/CC


Comment 111 in 61/5721A/CC is addressed in lines 340-343

However as other forms of supply, such as renewable energy sources are covered a statement makes sense. See comment 96.

96 NL35 337-339 7.12 te The requirement is applicable for appliances intended to be connected to any supply. It is not limited to mains supply or renewable energy source supply.Furthermore the supply shall be further specified with regard to electrical specifications because, similar to when using a detachable power supply, an incorrect supply may affect safety.

For appliances intended to be connected to the supply mains or renewable energy source a supply for the purposes of recharging the battery, the instructions shall state the substance of the following:WARNING: Use only an external supply with the following specifications:<voltage and nature of supply><power / current of supply>

Not accepted – see comment 43

WG31: Accepted

97 JP07 345-348 7.12 17 te We do not agree with the additional paragraph for the following reasons.

- In this CDV, clause 7.1 requires the same marking to be marked on battery body.“They shall also be marked with symbol IEC 60417-“battery charger” (2019-xx) and the model or type reference of the battery charger or with the substance of the followingUse only with <model or type reference> battery charger or Use only with the designated battery charger”

If our comment is not accepted, add the text according to JP 3.

WARNING: Use only with <model or type reference> battery charger or Use only with the designated battery charge.

Delete the additional paragraph. (Line 345-348)

If our comment is not accepted, add the text as follows, according to JP 3

WARNING: Use only with <model or type reference> battery charger or Use only with the designated battery charge.

To be discussed

WG31: Not Accepted

As the markings are not specific for multiple battery chargers the instructions should be specific to guide to user in making the proper selection.

98 DK25 354 7.15 ed Here “general purpose battery” is differently explained than in the note in line 255

Delete the text in parenthesis. Not accepted – the text is normative and the text in line 255 just gives some examples.

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99 NL36 361 8 ed Inconsistent text. Throughout the annex the term battery-operated appliance is used even when only the battery-powered part of the appliance is meant. It is nowhere referred to as appliance functional part.

Delete the words ‘the appliance functional part’

Not accepted. It is applicable to the power supply part for types in Figure B.1 (b), (c), (d) and (f

100 NL37 371 11.1 te Detachable power supply part is to be covered by main text of the standard. See also 5.17 where it is indicated that when the battery-operated appliance is connected to a supply the main part of the standard applies.

Delete the words ‘detachable power supply parts’

Not accepted. This has to be tested also while the battery is being charged. for the tests of clause 11.

WG31: Accepted

Annex B does not contain actual requirements with regards to temperature of the detachable power supply part itself. This is covered by the main body of part 1.

101 DK26 379 11.7 te This completely ignore the normally expected use of the appliance and any defined operating times and conditions as specified for the same, non-battery-operated appliance.This makes no sense at all and several existing battery-operated appliances may not be able to comply.Additionally, there is no relevant loading of the appliance is specified. Shall all battery-operated appliances operate under no load/idle conditions? If these conditions are left for each part-2 to identify, then no relevant requirements will exist until the part-2s have been adapted and published This is likely to take years.This comment also applies to lines 388 – 389 and to lines 396 - 398

Propose: Keep the existing reference to operating conditions and times as defined in the main part of the standard (including the part-2’s) and then add the proposed text for situations/appliances where no other specification apply

Not accepted. When taken in conjunction with a part 2 – the loading conditions are clear and specified in 3.1.9. The text in the annex states where relevant- the appliance is performing its intended function.

WG31: Not acceptedBy default for battery operated appliances Annex B 3.1.9 and 11.7 applies. To address specifics for a particular appliance the Part 2 has to address these differences in Annex B 3.1.9 and 11.7 with regards to loading and time duration.

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102 NL39 379-385 11.7 te Detachable batteries and separable batteries that are disconnected from the appliance during charging are in this proposal not tested during the charge cycle while separable batteries that are not disconnected from the appliance during charging, are also tested during the charge cycle (3rd dash, lines 393-395). This is an inconsistent approach. Also detachable batteries and separable batteries that are disconnected from the appliance during charging shall remain safe during the charging and thus require testing during charging.

Either add requirements for heating test during charging for detachable batteries and separable batteries that are disconnected from the appliance during charging, or add those to a future revision of IEC 60335-2-29.

Not accepted. It is covered by B.11.101 and the charging system to be used is specified in 7.12 lines 337-349.

WG31: Not accepted The purpose of this requirement is to evaluate the heating of the appliance during a discharge period that is lengthened by the simultaneous charging of the batteries during discharge and not to evaluate the heating of the battery itself.

103 JP08 386 11.7 3 te We propose modifying the 3rd paragraph to replace “non-replaceable integral batteries” with just “integral batteries” as the following reasons.- All types of integral batteries have the same

conditions of normal operation for daily use until the battery is replaced due to permanent deterioration.

- According to the proposal, user-replaceable integral batteries are covered by the 4th paragraph (operated only by artificial source, not by the battery), and user-replaceable integral batteries are not subject to temperature rise test for cells.

In 3rd paragraph, replace “non-replaceable integral batteries” with “integral batteries” as follows.

For appliances incorporating non- user-replaceable integral batteries or separable batteries not disconnected from the appliance for charging purposes, and that


104 NZ04 388-389 Annex B11.7

2nd para first dashed item

te It is not clear that during this test the battery is also being charged. The text needs to align more clearly with 3.1.9 2nd dashed item 1st dot item.

Replace the text by

can perform their intended function while the batteries are being charged, the battery is charged while the appliance is operated continuously performing its intended function for 1 h;

Accepted in principle – referred to EG1


can perform their intended function while the batteries are being charged, the initially fully discharged battery is charged while the appliance is operated continuously performing its intended function for 1 h;

105 DE18 390 Annex, 11.7

2nd dashed item


Replace "," by "charged," Accepted – it was in the Word version submitted to project dashboard

106 JP09 390 11.7 3 ed The word “charged” is omitted. Add “charged” as follows.

“cannot perform their intended function while the batteries are being charged”

See comment 105

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107 NZ05 390 Annex B11.7

2nd para 2nd dashed item

ed The word “charged” is missing after “being” Add the word “charged” after “being” See comment 105

108 US06 390 11.7 ed Missing word Add “charged,” after “being” See comment 105109 NL38 390-392 Annex B

11.7ed NZ32 was accepted with modification,

however the CDV is not reflecting this.See yellow-highlighted text

Replace the 2nd dashed item:

cannot perform their intended function while the batteries are being charged, the appliance is operated continuously until it cannot perform its intended function due to the depletion of the batteries.

See comment 105

110 DE19 393 Annex, 11.7

3rd dashed item

ed Defined term with wrong format used Print "fully discharged" in bold Accepted

111 JP10 393 11.7 3 te According to 3.1.9, both appliances that “can” and appliances that “cannot” need have charging cycle. Therefore, a charging time should be specified by 3rd dash, not only for appliances that “can perform” but also for appliances that “cannot perform”

Delete the text as follows.can perform their intended function while the batteries are being charged, the fully discharged battery is charged, for a duration of 24 h or until it is fully charged whichever is shorter, without the battery-operated appliance performing its intended function;

Not accepted. The text aligns with the decision on comment 128 in 61/5689A/CC

112 US07 393 11.7 ed Missing comma Add a comma after “charged” Accepted113 DK27 393-395 11.7 te According to figure B.1 appliances are tested

to the main part of the standard while operated or charged by mains and tested to Annex B when operated on battery power onlyTherefor this test should not be included in Annex B.

Move this specification to the main part of the standard.

Not accepted. Charging the battery is an Annex B matter.

114 JP11 396 11.7 4 te According to JP 8, to clarify the interpretation for 4th paragraph, it is better to insert “other than integral batteries”.

In 4th paragraph, insert “other than replaceable integral batteries” as follows.For appliances operated with replaceable batteries, other than integral batteries, and or non-rechargeable batteries, the appliance is operated until the minimum capacity of the battery as specified in Table B.101 has been delivered or until steady conditions are established, whichever occurs first.


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115 DK28 399-407 11.8 te Temperature rises for internal components such as switches, thermostats etc seem to be safety-relevant as well. Otherwise such components may exceed their temperature capabilities and no longer function correctly and as intended.In the same way also, the temperature of the wood/test wall remain relevant also for battery operated appliances.As such temperature limit need to be specified for these parts as wellAdditionally, the temperature rises of the batteries themselves must be relevant as well.This may result both from the “self-heating” of the battery itself resulting from current flow through internal resistance as well as any conducted or radiated heat from other parts of the appliance.

Add the following to the list of dashed items after line 398: Ambient of switches, thermostats and

temperature limiters Outer surface of capacitors Wooden supports, walls, ceiling and floor

of the test corner and wooden cabinet

Additionally, add a specification for temperature limits of the batteries or cells.

The dot items to be discussed

For temperature limits of batteries refer to lines 414 – 415 in 61/5178/DC and the decision on comment 245 in 61/5248A/INF


Change line 399-400 into:

During the test, the temperature rises are monitored continuously and shall not exceed the values shown in Table 3.

Delete lines 401-407

The temperature limits for batteries or cells are addressed elsewhere in the standard.

116 NL40 399-407 11.8 te The requirements (T-limits) for enclosures of detachable batteries and separable batteries are not indicated while B.22.102 refers to those requirements.Detachable batteries and separable batteries are often held / touched for longer periods and should therefore be regarded as surfaces which are held continuously.

Delete in line 407 ‘and detachable batteries when removed for recharging’Add the following new sentence after the last dashed item:Enclosures of detachable batteries and separable batteries are regarded as surfaces of handles which are continuously held in normal use.

To be discussed


117 DE20 415 Annex B, B.11.101

ed Wrong order Replace "°C 5" by "5 °C" Accepted – it was in the Word version submitted to project dashboard

118 NL41 415 B.11.101 ed Typo Change “20 °C ± °C 5” into “20 °C ± 5 °C” See comment 117

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119 NL42 437 B.11.101 te Batteries with a maximum ambient temperature for charging of 40 degs C are to be tested at an ambient temperature of 20 degs C according the proposal. The measured surface temperature (absolute value) shall be then be lower then the surface temperature (absolute value) specified by the cell manufacturer.However the difference in ambient temperature and the max specified ambient temperature needs to be taken into account.Example:Specified max Ta during charging: 40 CSpecified max cell temperature: 60 CTa during test (according current proposal): 20 CT cell surface measured: 59 C.Then according current proposal the cell surface temperate would be accepted ( 59 C < 60 C) while when charging the same battery in 40 C ambient (specified max Ta for charging) the cell would reach 79 C which exceed the max specified cell temperature.

Modify the text of line 437 as follows:the surface temperature minus the difference between the ambient temperature during the test and the max specified ambient temperature during charging

To be discussed

WG31: Not accepted

This test is not to be considered a heating test which would be subject to the conditions that the commenter suggests but rather establishes a standardized condition on a “normal” range of temperatures. Temperature extremes are handled by exception, see 416-419.Moreover, this test, with these conditions has been present in this form since the very first DC

120 DK29 456-458 19.1 te This specification is different from the proposed approach for intentionally weak parts given in 61/5734/CDV (FRAG 5)

Modify the text to ensure alignment with the comparable text proposed for the main part of the standard.

See comment 121

121 NL43 457-458 19.1 te The test need to be adapted the text from 19.1 in fragment 5, 61/5734/CDV.

WG31:

Replace the fourth paragraph of 19.1 by the following:Unless otherwise specified, the tests are continued until a non-self-resetting thermal cut- out operates or until steady conditions are established. If a heating element or an intentionally weak part becomes permanently open-circuited, the relevant test is repeated on a second appliance. If in the first test a heating element or intentionally weak part becomes permanently open-circuited that same part on the second appliance shall also become permanently open-circuited in the second test, unless a non-self-resetting thermal cut-out operates or steady conditions are established

Not necessary since the text is a modification to the main part of the standard. The comment could be handled by deleting the 4th paragraph in this Annex.

WG31: Accepted

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122 DK30 461-462 19.2 te The way to obtain restricted heat dissipation is only described in the part-2’s.However, following §5.17 (DK03) only Annex B apply and therefor the text of the “main part” of the part-2’s does not apply to battery appliances without a supply connection. How is restricted heat dissipation obtained for these appliances?

Modify the text to clarify how to obtain restricted heat dissipation.

Not accepted. This a modification to the main part of the standard because it is not possible to apply the 2nd and 3rd sentences in the main part of the standard when performing its function.

123 DK31 469-470 19.7 te According to figure B.1 appliances are tested to the main part of the standard while operated or charged by mains and tested to Annex B when operated on battery power onlyTherefor this part of the specification should not be included in Annex B.

Move the part of the specification to the main part of the standard.

To be discussed. It is important that 3.1.9, 11.7 and Figure B.1 examples are compatible with each other.Would it help if in Figure B.1 it is made clear that when reference is made to testing to Annex B it refers to either “CA” or “A” as applicable.


124 US08 469-470 19.7 te This is true of many tests in Annex B and is already covered by 5.17 (lines 68-69)

Delete Lines 469-470 To be discussed

WG31: Accepted

125 DE21 472 Annex B, 19.7

ed Wrong reference Replace "5.B.101" by "B.5.101" Accepted

126 NL44 498 19.11.4 ed The term rated voltage is inappropriate here. Throughout the annex the term fully charged battery is used.

Replace the words ‘at rated voltage’ by ‘ by a fully charged battery’.

This does not take account of the functional part being connected to detachable power supply part. In this case rated voltage is the appropriate term. When the functional part is operated by its battery then the fully charged battery can be used.

WG31: Accepted(the functional part being connected to the supply via the detachable power supply is covered by the main body)

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127 DK32 503 19.11.4.8 te Here the term “supplied from a fully charged battery” is used. However, in line 498 the specification to test while “supplied at rated voltage”According to B.5.8.101 in line 213 “rated voltage” means supplied from a fully charged battery – in other words the two different specifications have the same meaning.For consistency the same verbiage should be used throughout

Modify the text to use the same verbiage/terminology in all places throughout

Not necessary. The text means: When tested to Annex B the functional part is operated with a fully charged battery. When tested to the main part of the appliance rated voltage is applied at S in Figure B.1 (note that S is missing in Figure B.1 (f))


128 DK33 547-549 B.19.103 te According to figure B.1, Annex B apply to battery-operated appliances when operated by the battery only. Operation while connected to the mains and any related requirements are contained in the main part of the standard.

Move this requirement to the main parts of the standard

To be discussed. It does mean that normal operation in the main part of the standard is applied with respect to the functional part.

WG31: Not accepted

This test specifically evaluates if the absence of batteries creates an unsafe condition under mains operation. Removing it from Annex B, would remove this test entirely, unless it was moved to the main part of the standard

129 DK34 551-552 B.19.104 te In B.19.105 line 560 a specification of the max resistance of the short-circuit is given.Are the same requirements not relevant here?

Include a specification of the maximum resistance of the short-circuit.For example:“the resistance of the short-circuit shall not exceed 10mOhm”

OK see comment 139

WG31: Accepted

130 DE22 558 Annex B, B.19.105

te In our understanding, the introduction of the short circuit represents severe operating conditions. It is very well possible that protective circuitry inside the battery system prevents further operation of the battery-operated appliance if a certain imbalance occurs. If further operation of the appliance is prevented and the battery terminals are not accessible, the test is not justified since the introduction of the short circuit would then represent a misuse condition.

Add after line 558 the following:"If the appliance is still further operational or the battery terminals are accessible with test probe B or test probe 18 of IEC 61032, the following test is performed:"

Not accepted – refer to the 2nd paragraph of 5.3 that states “If it is evident from the construction of the appliance that a particular test is not applicable, the test is not carried out”

131 DK35 559 B.19.105 te This short-circuit test specification is specified for metal-ion batteries only. Is a short circuit test however not relevant for appliances using only a single metal-Ion cell?

Yes

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132 DK36 565-602 B.19.106 te According to figure B.1 appliances are tested to the main part of the standard while operated or charged by the mains and tested to Annex B when operated on battery power only.Therefor this test should not be in Annex B.

Move this part of the proposal to the main part of the standard.

To be discussed. Taking into account Figure B.1 text it depends where CC is situated.

WG31: Not accepted

Charging is related specifically to a battery operated appliance.

133 SI01 574, 575

Annex B, B.19.106

a) te

To our understanding, a control function that fulfils the requirements of:Clause 19.11.3 and Annex Rreduces the risk of exceeding the upper limit charging voltage to a sufficient degree.

Replace lines 574 & 575 by:"The charging system is conditioned so that the state of the battery is as follows:"

Not Accepted. The test specification is clearly stated taking into account the definition of charging system.

WG31: Accepted

The intention is to assess that the charging circuitry is tolerant to component faults and this can be achieved by considering the circuit to be a PEC.

134 DK37 606 B.19.107 te The term “shorted” is ambiguous and the meaning may not be clear.

Replace “shorted” with “short-circuited”This apply also to line 611.

Accepted

135 DK38 607-609 B.19.107 te This requirement and test do not seem to relate to the presence of a cord as specified in line 603-604

Separate this requirement from B.19.107 and located separately as a new clause.

Not accepted. The text is clear.

136 DK39 613-615 B.19.107 te This requirement is unclear. Shall accessibility be determined by test probe 13 of IEC 61032 OR shall the actual short-circuit be made using the probe?It is unclear if/how this requirement is technically different from the requirement in line 607-609?Additionally, this requirement and test does not seem to relate to the presence of a cord as specified in line 603-604

Delete or rephrase so that the meaning is clear.


Not accepted but add “one at a time” at the end of line 604WG31 to clarify how the terminals are short-circuited.

WG31: Agree with secretary observation.

Additionally:

- charging terminals of the battery-operated appliance that are simultaneous accessible with test probe 13 of IEC 61032 are short circuited so as to produce the mist unfavourable results.

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137 DK40 616-618 B.19.107 te This requirement and test do not seem to relate to the presence of a cord as specified in line 603-604


To be discussed. Line 616 is a separate test. Lines 617 and 618 are separate paragraph that applies to the whole clause.

WG31: this sub clause includes both situations associated with cords and without. If needed to separate the two situations, refer to EG1

Add ad the end of the clause:

The resistance of the short-circuit shall not exceed 10 mΩ.

138 DK41 623 B.19.108 te This requirement is vague and unclear. Elsewhere a max. resistance of 10mOhm is specified for the short-circuit. This is clear and unambiguous and should be appropriate here as well. This would also serve to provide consistency in both phrasing and requirements throughout the standard.

Replace the text “The means of short-circuiting shall not affect the test results”with “the resistance of the short-circuit shall not exceed 10mOhm”

See comment 139

139 NL45 623 B.19.108 te The indication ‘The means of short circuiting shall not affect the test results’ does not lead to reproducible results.In other clauses of the annex where a short circuit is to be applied the max short circuit resistance is specified.

Replace the sentence ‘The means of short circuiting shall not affect the test results.’ By:The resistance of the short shall not exceed 10 mΩ.

To be discussed


The resistance of the short-circuit shall not exceed 10 mΩ.

140 US09 625-626 B.20.101 ed The “-“ in Tables B.102 and B.103 implies that this compliance criteria is not applicable to batteries with a capacity of less than 0,2 Ah. This should be clarified so that the compliance criteria is defined for these batteries.

Compliance is checked by inspection after the tests of Clause 19 for batteries with a capacity less than 0.2 Ah, measurement in the case of a) or test of b).

Delete the first rows of Table B.102 and Table B.103.

If accepted, the same should be done for B.20.102.

Accepted

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141 NL46 635 Annex BB.20.101

Table B.102

ed/te The clause deals with the enclosure of the integral battery. But the table referred to, is speaking about cell capacity. However an enclosure can contain multiple cells.To clarify change cell into battery in the title and table,

Change in the title of the table “cells” into “batteries”.

Change in the table “cell” into “battery

Accepted. We could also delete for metal-ion cells from the Table title.

WG31: Not accepted.

Not all cells will vent simultaneously. The enclosure shall be able to release the gasses during the venting of a cell in a timely manner so that if multiple cells vent in turn the overpressure can drop also.

142 DE23 635, 636

Annex B, B.20.101

Table B.102, Table B.103

te The titles chosen for the left columns of Table B.102 and Table B.103 are misleading. It is unclear which capacity is meant (total battery vs. single cell). Also, batteries consisting of cells with different single cell capacities are not taken into account.

Replace title of left column of Table B.102 and Table B.103 by "Capacity of the single metal-ion cell with the highest capacity (Ah)"

See comment 141 and comment 144

WG31: Accepted

143 JP12 635636

B.20.101 Table B.102Table B.103

ed We propose modification to clarify that metal-ion cell capacity means capacity of one cell.

Change “Metal-ion cell capacity” to “Capacity of each metal-ion cell” in the column title of Table B.102 and Table B.103.

See comment 141 and comment 144

WG31: see 142

144 NL47 636 Annex BB.20.101

Table B.103

ed/te The clause deals with the enclosure of the integral battery. But the table referred to, is speaking about cell capacity. However an enclosure can contain multiple cells.To clarify change cell into battery in the table.

Change in the table “cell” into “battery”. Accepted

WG31: see 141

145 DE24 637 Annex B, B.20.102

ed Wrong format Print two times "metal-ion" not in bold See comment 18

146 DE25 640 Annex B, B.20.102

ed Wrong reference Replace "c)" by "a)" Accepted

147 US10 640-642, 647 – 648

B.20.102 ed Table number B.103 is already used in the clause above.

Renumber Tables as B.104 and B.105

Update reference to tables in lines 641 and 642

Change “c)” and “d)” in lines 640 and 642 to “a)” and “b)”

Accepted.

148 DE26 641 Annex B, B.20.102

ed Wrong reference, see also comment DE29 Replace "Table B.103" by "Table B.104" Accepted

149 FR05 641, 642647, 648

Table B.103Table B.104

ed There are 2 Table B.103 (lines 636 and 647).The text in lines 641 and 642 shall also be modified accordingly.

Renumber correctly the Table and modify the text accordingly:2nd "Table B.103"--> "Table B.104""Table B.104" --> "Table B.105"

Accepted

150 DE27 642 Annex B, B.20.102

ed Wrong reference Replace "d)" by "b)" Accepted

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151 DE28 642 Annex B, B.20.102

ed Wrong reference, see also comment DE29 Replace "Table B.104" by "Table B.105" Accepted

152 DE29 647 Annex B, B.20.102


ed Wrong numbering of tables Replace "B.103" by "B.104"Replace "B.104" by "B.105"

Accepted

153 NL48 647 Annex BB.20.102

Table B.103

ed/te There are two table 103.Besides that the content is exactly the same as with table B.102 as mentioned in clause B.20.101, and thus redundant.

Delete Table B.103 in clause B.20.102. And change reference in c) of clause B.202.102 from ”Table B.103” to ”Table B.102 in clause B.20.101”.

Accepted

WG31: see comment 147

154 DE31 647, 648

Annex B, B.20.102


te The titles chosen for the left columns of Table B.103 and Table B.104 are misleading. It is unclear which capacity is meant (total battery vs. single cell). Also, batteries consisting of cells with different single cell capacities are not taken into account.

Replace title of left column of Table B.103 (line 647) and Table B.104 (line 648) by "Capacity of the single metal-ion cell with the highest capacity (Ah)

See comment 142

WG31: Accepted

155 JP13 647648

B.20.102 Table B.103Table B.104

ed We propose modification to clarify that metal-ion cell capacity means capacity of one cell.

Change “Metal-ion cell capacity” to “Capacity of each metal-ion cell” in the column title of Table B.103 and Table B.104.

See comment 143

WG31 see:comment 154

156 NL49 648 Annex BB.20.102

Table B.104

ed/te The content of table B.104 is exactly the same as with table B.103 as mentioned in clause B.20.101, and thus redundant.

Delete Table B.104 in clause B.20.102. And change reference in d) of clause B.202.102 from ”Table B.104” to ”Table B.103’ in clause B.20.101”.

Accepted

WG31: see comment 147

157 NL50 665-668 21.1 ed/te Unclear what is meant with the sentence ‘with and without the detachable battery.’Further it is unclear what the state of charge of the batteries must be during the test.

Modify the fifth paragraph of the test specification as follows:Hand-held battery-operated appliances, with and without any detachable battery, shall also be subjected to test free-fall – procedure 1, of IEC 60068-2-31. They shall be dropped three times from a height of 1 m onto a concrete surface. The sample shall be positioned to vary the point of impact. Batteries shall be fully charged prior to the test. Hand-held battery-operated appliances employing detachable batteries are tested with and without the detachable battery.

Accepted in principle – referred to EG1

158 DE30 671 Annex B, 21.1

ed Comment DE31 on 61/5696/CD was accepted (see 61/5721A/CC) but not correctly implemented

Replace "B.22.105" by "B.22.105.1" Accepted

159 US11 671 21.1 ed B.22.105 should be B.22.105.1 Refer to B.22.105.1 Accepted

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160 NL51 694-695 B.21.101 te The compliance criteria from this clause B.21.101 are completely different than those from IEC 62133-x where the compliance criteria are limited to no fire and no explosion.

Delete the last sentence of the fourth paragraph of the test specification.

To be discussed. The decision should be referred to SC 21B for their further action

WG31: Accepted

161 NL52 711-712 B.21.101 te Meaning of the requirement is unclear. Replace ‘cell vents’ in line 711 by ‘cell’. Accepted162 DK42 749-750 B.22.101 ed Mains connections are excluded from Annex

B according to figure B.101 and need not be additionally mentioned here.

Delete the text in parenthesis. Not accepted – taking into account the definition of battery system

163 DK43 769-771 B.22.102 te Requirement and test conditions are vague. Add specific temperature limit/max temperatures and points of measurements.

Not accepted. It can be checked as specified through the stages 1DC, 2DC, 1CD, 2CD without proposals to change.

164 NL53 773-793 22.103.1 & 22.103.2

ed There seems to be no reason to split 22.105 into two subclauses 22.103.1 and 22.103.2. For ease of reading the two subclauses should be merged into a single subclause.

Merge the clauses 22.103.1 and 22.103.2 into a single clause 22.103.

….Compliance is checked by inspection and the following test:…

Accepted

WG31: Refer to EG1To correct the references from B.22.103.1 to B.22.103

165 NL54 773-775 B.22.103.1 te The intention of the clause is that hazardous conductive parts are inaccessible.

Delete the word ‘accessible’ in line 774. Accepted

WG31: Not accepted

166 NZ06 777-778 Annex B22.103.1

1st para 2nd dashed item

te Some indication is needed on how to measure the current.

Add the following to line 779The current is measured using the circuit in Figure 4 of IEC 60990.

Accepted

167 DK44 780-793 B.22.103.2 te This is a test specification, but it has no compliance criteriaIn particular it is not understood what is meant by “simultaneous contact”

Add a compliance criterion“…there shall be no contact….”

See comment 168

168 NL55 780-793 B.22.103.2 te The test specification does not clearly specify what should be met and therefore does not reflect the requirements of B.22.103.1

Add at the end of the test specification:

It shall not be possible to touch two or more conductive parts of opposite polarity with the probes.

Accepted. It also needs to made clear that two probes are used when making each assessment. Referred to EG1

169 NL56 794-812 22.104.1 & 22.104.2


Merge the clauses 22.104.1 and 22.104.2 into a single clause 22.104. ….Compliance is checked by inspection and the following test:…

Accepted

WG31: Refer to EG1To correct the references from B.22.104.1 to B.22.104

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170 NL57 794-796 B22.104.1 te The intention of the clause is that hazardous conductive parts are inaccessible.

Delete the word ‘accessible’ in line 796. Accepted

WG31: Not accepted171 NZ07 798 Annex B

22.104.11st para 2nd dashed item

te Some indication is needed on how to measure the current.

Add the following to line 799The current is measured using the circuit in Figure 4 of IEC 60990.

Accepted

172 NL58 800-812 Annex B B.22.104.2

te The test specification does not clearly specify what should be met and therefore does not reflect the requirements of B.22.104.1.

Add at the end of the test specification:

It shall not be possible to touch two or more conductive parts of opposite polarity with the probes.

See comment 168

WG31: Accepted

173 DK46 800-812 B.22.104.2 te This is a test specification, but it has no compliance criteria.

Add a compliance criterion See comment 172

174 DK45 801-802 B.22.104.2 te When evaluating the possibility of “simultaneous contact” for batteries, the mass is not relevant. Even batteries having a mass of more than 40 kg are likely to be moved, lifted, tilted or otherwise manipulated during use.

Delete the part of the sentence that reads“except that batteries having a mass exceeding 40kg are not tilted”

To be discussed

WG31: Not acceptedWhy should a battery operated appliance in this sense be treated differently than an ordinary mains connected appliance. The weight limit as mentioned in this annex is identical to that of the main body.

175 NL59 809-810 22.104.2 te The clause concerns batteries only so the reference to appliance is not correct.

Change the text as follows:

– test probe 18, the appliance shall be fully assembled as in normal use without any parts removed.

Accepted

176 NL60 811-812 22.104.2 te The clause concerns batteries only so the reference to appliance is not correct.

Add the words ‘batteries for’ before the word ‘appliances’ in line 811.

Accepted but how it is known that the battery is for commercial appliances.

WG31:AcceptedHow is it known that appliances are for commercial applications? It is described in the instructions.

177 NL61 813-827 22.105.1 & 22.105.2


Merge the clauses 22.105.1 and 22.105.2 into a single clause 22.105.….Compliance is checked by inspection and the following test:…

Accepted

WG31: Refer to EG1To correct the references

from B.22.105.1 to B.22.105

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178 NL62 816 22.105.1 te The requirement needs to be extended with values for current, similar to 22.103.1.

Add a third dashed item:– the current between the accessible parts exceeds 2 mA for d.c. or 0,7 mA peak for when ripple exceeds 10 %.

And add the word ‘; and’ at the end of the second dashed item.

Accepted and make reference to Figure 4 of IEC 60990 for the circuit to measure the current.

179 NZ08 832 Annex B22.3

ed Incorrect clause number and Style correction Replace the text by23.3 Instead of the electric strength test of 16.3, battery-operated appliances shall comply with B.22.103.1.

Accepted

180 NZ09 839-841 Annex B24.1

Note te The text in the note is irrelevant. It is covered by the requirement in lines 837-838

Delete the NOTE Accepted

181 DE32 869 24.1.3 ed To be in line with the decision taken at the last MT 23-Meeting held on 29th and 30th October 2018 in Singapore

Add the following text after line 869:Electronic switches according to 61058-1-2 shall additional be tested as part of the appliance according to this standard.

Not necessary – all components must also comply with the 60335 requirements as per 24.1. See also the decision on comment 154 in 61/5721A/CC)

182 NL63 893 27.1 ed Inconsistent text. Throughout the annex the term battery-operated appliance is used even when only the battery-powered part of the appliance is meant. It is nowhere referred to as appliance functional part.

Delete the words ‘functional part’. See comment 23

WG31: Accepted

The battery-operated appliance functional part shall have no provision for a protective earth but may incorporate an functional earth for functional purposes.

183 NZ10 893-894 Annex B27.1

te There is no test specification Add “Compliance is checked by inspection” Accepted

184 DK47 897-898 29.1 te Reference to “rated impulse voltage” does not appear to be relevant for battery operated appliances.Following the definition in §3.1.10 the term relates to the overvoltage category of the appliance which again refer to the transient conditions that may occur on the supply network and so it not relevant in Annex B

In line 897 delete the part of the sentence after the comma, so that the sentence reads:“Clearances shall not be less than the values in table 16. For battery operated appliances….”

Not accepted. It is needed for correct application of the Table 16

185 DK48 902 29.1 te The part of the specification that reads “…1500V and above” is confusing considering that line 899 specify that the rated impulse voltage is 1500V for all working voltages above 50V. As such there should be nothing

Delete the words “and above” Accepted

186 DK49 924-926 30.2 te Mains connections are excluded from Annex B according to figure B.101 and should not be additionally mentioned here.

Delete the text Not accepted. The words mains connections are not mentioned.

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187 DK50 937 Fig B.1 – f) te It seems that the type of dotted line between the power supply and the battery is neither the “non-detachable connection” nor the “detachable connection” If the connection is non-detachable, the figure is hard to understand, so we assume the connection is a detachable.

If the connection is non-detachable, then please give an example of such appliance.If the connection is a detachable type, then correct the figure.

Refer to the key – it is detachable. Agreed that the figure is not clear. The line between the battery and the functional part should be coloured other than black and so indicated in the key.

188 DE33 951 Annex L, L.3

ed Wrong reference Replace "29.B.101" by "B.29.1.101" Accepted

189 US12 951, 957

L.3 ed Correct reference Replace “29.B.101” with “B29.1.101 and B29.2.101” in two places

Accepted

190 DE34 957 Annex L, Figure L.3

Key ed Wrong reference Replace "29.B.1.101" by "B.29.1.101" Accepted

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Annex A

For comments 164 to 168

B.22.103.1 Battery-operated appliances shall be so constructed and enclosed that there is 773 adequate protection against simultaneous contact with two or more conductive accessible parts 774 where 775

– the voltage between them exceeds 42,4 V; and 776 – the current between the accessible parts exceeds 2 mA for d.c. or 0,7 mA peak for when 777 ripple exceeds 10 %.

Compliance is checked by inspection and the following test:

Test probe B and test probe 18 of IEC 61032 are applied with a force not exceeding 1 N, the appliance being in every possible position except that appliances normally used on the

floor and having a mass exceeding 40 kg are not tilted. The test probe is applied through 782 openings to any depth that the probe will permit and is rotated or angled before, during and after 783 insertion to any position. If the opening does not allow the entry of the probe, the force on the 784 probe in the straight position is increased to 20 N when probe B is used or 10 N when probe 18 is 785 used. If the probe then enters the opening, the test is repeated with the probe in the angled 786 position. 787 During the tests with: 788 – test probe B, all detachable parts are removed; 789 – test probe 18, the appliance shall be fully assembled as in normal use without any parts 790 removed. 791

However, test probe 18 is not applied to appliances for commercial use unless they are intended 792 to be installed in an area open to the public.

The voltage between any two parts simultaneously accessible by the probes shall not exceed 42,4 V; and the current between them shall not exceed 2 mA for d.c. or 0,7 mA peak for when the ripple exceeds 10 % when measured using the circuit of Figure 4 of IEC 60990

B.22.104.1 Separable batteries and detachable batteries shall be so constructed and 794 enclosed that there is adequate protection against simultaneous contact with two or more 795 conductive accessible parts where 796 – the voltage between them exceeds 42,4 V; and 797 – the current between the accessible parts exceeds 2 mA. 798

Compliance is checked by inspection, measurement and the following test:

Test probe B and test probe 18 of IEC 61032 are applied with a force not exceeding 800 1 N, the battery being in every possible position except that batteries having a mass exceeding 801 40 kg are not tilted. The test probe is applied through openings to any depth that the probe will permit and is rotated or angled before, during and after insertion to any position. If the opening does not allow the entry of the probe, the force on the probe in the straight position is increased 804 to 20 N. If the probe then enters the opening, the test is repeated with the probe in the angled 805 position.

During the tests with: 807 of 43

61/5831/RVC

– test probe B, all detachable parts are removed; 808 – test probe 18, the battery shall be fully assembled as in normal use without any parts 809 removed. 810

However, test probe 18 is not applied to batteries for appliances for commercial use unless they are intended to be installed in an area open to the public.

The voltage between any two parts simultaneously accessible by the probes shall not exceed 42,4 V; and the current between them shall not exceed 2 mA for d.c. or 0,7 mA peak for when the ripple exceeds 10 % when measured using the circuit of Figure 4 of IEC 60990

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