US CPSC Proposes Mandatory Battery Standard: UL 2849, 2271, 2272 Cover Packs and Kits

Lead: On 24 June 2026, the US Consumer Product Safety Commission published a notice of proposed rulemaking in the Federal Register (91 FR 38162, 66 pages, Docket CPSC-2025-0012) to establish a mandatory safety standard for lithium-ion batteries used in micromobility products and their electrical systems. The rule remains a proposal, not a final rule, but its scope alone is enough to change export product planning.

1. What the Rule Covers — the Most Important Part

The proposal would require micromobility electrical systems to comply with the applicable voluntary standards, with modifications:

• eBikes → ANSI/CAN/UL 2849-20;
• Other micromobility products (OMPs, including e-scooters, self-balancing scooters, e-skateboards, e-unicycles**)** → UL 2272-24;
• Battery packs → UL 2271-23.

The proposal also brings three categories of non-complete-vehicle products into scope:

1. User replaceable battery packs — replacement batteries sold separately;
2. eBike conversion kits — including the battery and electrical components in the kit;
3. Aftermarket battery chargers.

The regulated object is not the battery alone but the entire electrical system: cells, BMS, chargers, wiring and other electrical components.

2. The Risk Evidence CPSC Presents

Data disclosed in the preamble (five years, 2019–2023):

• CPSC is aware of 227 unique incidents involving fires, explosions, gas releases, burns, overheating and smoke inhalation;
• 90 incidents are associated with 39 fatalities and 181 injuries;
• 39 of the 227 incidents involved multiple deaths and injuries.

CPSC identifies thermal runaway as the core mechanism: a self-sustaining exothermic reaction inside the cell builds pressure, ejecting flame and combustible gas, which can ignite adjacent cells and nearby combustibles. That explains why chargers and conversion kits are in scope — accidents frequently occur in "accessories outside the original equipment."

3. Another Easily Overlooked Provision: Third-Party Testing

Because some micromobility products are children's products requiring third-party testing, the proposal would add this rule to the list of rules requiring testing by third-party conformity assessment bodies (16 CFR 1112). That means:

• Self-declaration is not enough; an NRTL (Nationally Recognized Testing Laboratory) report is required;
• Certification is performed per "model + electrical system configuration" — changing cells, BMS or charger may trigger re-evaluation.

4. Practical Impact on Exporters

1. Treat "system" as the certification unit: UL 2849 applies at the complete-vehicle electrical system level, UL 2271 at the pack level. Testing the pack without system-level matching is the most common cause of failure;
2. Put accessories on the BOM compliance list: supplier changes for chargers, harnesses or displays should go through change management to assess certification impact;
3. Labelling and traceability: permanent labels must carry manufacturer identification, model, rated voltage and capacity, and support traceability;
4. Mind the uncertainty of timing: this is an NPR; final content, effective date and transition periods may all change. Do not stop current shipments on the basis of it, but engineer to the likely strictness of the final rule;
5. State certification status in US quotations: US importers and retailers, especially large channels, already require UL 2849 evidence in purchase contracts. Declaring "certified / in certification / not certified" up front costs far less than explaining later.

5. One Caution

The real dividing line is not "whether to do UL" but "whether you have the engineering capability to validate battery, BMS and charger as one system." Low-cost programmes usually fail at system matching, not at the cell itself.