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In page Nickel–metal hydride battery:

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Another option is to monitor the change of voltage with respect to time and stop when this becomes zero, but this risks premature cutoffs.[1] With this method, a much higher charging rate can be used than with a trickle charge, up to 1 C. At this charge rate, Panasonic recommends to terminate charging when the voltage drops 5–10 mV per cell from the peak voltage.[2] Since this method measures the voltage across the battery, a constant-current (rather than a constant-voltage) charging circuit is used.[citation needed]