Lithium Ion Finished Products in ASRS What Must Be Verified Before Storage

Finished consumer products containing lithium-ion batteries—including many 3C electronics, toys, tools, small appliances, and accessories—can be stored in an ASRS, but they should not be treated as ordinary merchandise without confirming the applicable storage criteria.
Start with the finished product and state of charge
The first distinction is between a finished product with an installed battery and standalone cells, modules, battery packs, or replacement batteries. Finished products can be evaluated differently because the battery is part of a complete product. Returned, damaged, defective, recalled, used, or waste batteries are a separate hazard category and should not be included in the normal ASRS commodity mix.
For an ASRS evaluated under FM guidance, FM Data Sheet 7-112 directs the designer to classify the finished product excluding the battery hazard under FM Data Sheet 8-1, then to protect the ASRS under FM Data Sheet 8-34. This means the underlying commodity classification, packaging, container construction, storage geometry, and the protection arrangement still matter.
When finished products can be stored in an ASRS
Finished product battery SOC | FM 7-112 ASRS direction to verify |
|---|---|
30 percent or less | Classify the finished product without the battery hazard under FM 8-1 and protect the ASRS in accordance with FM 8-34 using a wet sprinkler system. |
More than 30 percent through 60 percent | Additional limitations apply: use only a horizontal-loading ASRS; use FM Approved non-flame-propagating containers or specified solid-walled metal or metal-lined containers; and provide both ceiling and in-rack wet sprinklers in accordance with FM 8-34. |
More than 60 percent | Do not store the finished products in an ASRS under the cited FM 7-112 guidance. |
Standalone cells, modules, or batteries | Do not treat these as finished products. ASRS storage is not permitted unless the specific formation-and-aging protection guidance in FM 7-112 is met. |
What this means for 3C finished products
For finished 3C consumer products with installed lithium-ion batteries, ASRS storage can be workable when the project meets the relevant FM 7-112 limitations, the finished product is classified under FM 8-1, and the proposed commodity falls within the protection options allowed by FM 8-34. It is not enough to say that the product contains a battery and is therefore acceptable; the documentation needs to show the state of charge, product form, packaging, container type, ASRS type, storage height, sprinkler arrangement, and water-supply basis.
The lower state-of-charge condition is generally the more straightforward path, but it still requires the ASRS to meet FM 8-34 and to use wet sprinkler protection. The 30-to-60-percent condition is substantially more restrictive. It is limited to horizontal-loading ASRS systems, requires specified non-flame-propagating or metal containment, and requires both ceiling and in-rack sprinklers.
Questions to resolve before final design
• Which SKUs contain lithium-ion batteries, and are all batteries installed in finished products?
• What maximum state of charge will be maintained during receiving, storage, and shipping?
• Are any returns, damaged units, recalls, loose batteries, or battery packs proposed for the same area?
• What is the FM 8-1 commodity classification excluding the battery hazard, and what packaging or tote materials are used?
• Is the proposed ASRS horizontal-loading, top-loading, vertical enclosed, or another arrangement, and is that arrangement within FM 8-34 scope?
• Do the ceiling and, where required, in-rack sprinkler arrangements meet the applicable protection criteria and water supply?
• Are the storage height, ceiling height, flue spaces, container construction, and operational controls consistent with the approved basis of design?
Plan before the warehouse is full
Commodity changes can trigger sprinkler modifications, high-piled storage permit questions, revised operational controls, or additional fire-department and insurer review. Identifying lithium-ion finished products before the ASRS layout and sprinkler design are finalized gives the project team time to select a compliant storage arrangement instead of trying to retrofit protection after installation.
This article summarizes early planning considerations from the model code and FM data sheets. The adopted building and fire code, local amendments, insurer requirements, current FM editions, commodity documentation, and AHJ interpretation govern the final design.
For any further inquiries regarding this topic, as well as for code consulting and fire engineering design support related to your project, please don’t hesitate to contact us via email at contact@engineeringfireprotection.com.



