Are lithium batteries classified as dangerous goods?

Yes, lithium batteries are classified as dangerous goods.

According to international regulations such as the Recommendations on the Transport of Dangerous Goods (TDG), the International Maritime Dangerous Goods Code (IMDG Code), and the Technical Instructions for the Safe Transport of Dangerous Goods by Air published by the International Civil Aviation Organization (ICAO), lithium batteries fall under Class 9: Miscellaneous dangerous substances and articles, including environmentally hazardous substances.

There are 3 major categories of lithium batteries with 5 UN numbers classified based on operating principles and transportation methods:

• Standalone lithium batteries: They can be further divided into lithium metal batteries and lithium-ion batteries, corresponding to UN numbers UN3090 and UN3480, respectively.
• Lithium batteries installed in equipment: Similarly, they are categorized into lithium metal batteries and lithium-ion batteries, corresponding to UN numbers UN3091 and UN3481, respectively.
• Lithium battery-powered vehicles or self-propelled devices: Examples include electric cars, electric bicycles, electric scooters, electric wheelchairs, etc., corresponding to UN number UN3171.

Do lithium batteries require hazardous goods packaging?

According to TDG regulations, lithium batteries that require hazardous goods packaging include:

• Lithium metal batteries or lithium alloy batteries with a lithium content greater than 1g.
• Lithium metal or lithium alloy battery packs with total lithium content exceeding 2g.
• Lithium-ion batteries with a rated capacity exceeding 20 Wh, and lithium-ion battery packs with a rated capacity exceeding 100 Wh.

It is important to note that lithium batteries exempt from hazardous goods packaging still need to indicate the watt-hour rating on the outer packaging. Additionally, they must display compliant lithium battery markings, which include a red dashed border and a black symbol indicating the risk of fire for battery packs and cells.

What are the testing requirements before the shipment of lithium batteries?

Before the shipment of lithium batteries with UN numbers UN3480, UN3481, UN3090, and UN3091, they must undergo a series of tests as per Subsection 38.3 of Part III of the United Nations’ Recommendations on the Transport of Dangerous Goods – Manual of Tests and Criteria. The tests include: altitude simulation, thermal cycling test (high and low temperatures), vibration, shock, external short circuit at 55 ℃, impact, crush, overcharge, and forced discharge. These tests are conducted to ensure the safe transportation of lithium batteries.

What are the export procedures for lithium batteries?

According to Article 17 of the Law of the People’s Republic of China on Import and Export Commodity Inspection, enterprises producing packaging containers for exporting dangerous goods must apply to the inspection and quarantine authorities for the performance appraisal of the packaging containers. Enterprises producing and exporting dangerous goods must apply for the use appraisal of the packaging containers from the inspection and quarantine authorities. Therefore, for lithium batteries packed in hazardous goods packaging, the enterprise should apply to the local customs for packaging performance inspection and use appraisal before export. The enterprise needs to obtain the Outbound Goods Transportation Packaging Performance Inspection Result Form and the Outbound Dangerous Goods Transportation Packaging Use Appraisal Result Form. The documentation process can be simplified according to relevant regulations such as the Announcement on Digitization of Inspection and Quarantine Documents.

Enterprises producing packaging for exporting hazardous goods should apply to local customs for the Outbound Goods Transportation Packaging Performance Inspection Result Form. The form’s validity period is determined based on the material nature of the packaging container and the nature of the goods it carries, generally not exceeding 12 months from the date of container production. If the goods are not shipped within the validity period, and the outer packaging is in good condition, the enterprise can reapply for packaging performance inspection. After passing the inspection, the renewed form can be used for export and will remain valid for up to 6 months from the inspection completion date.

Enterprises producing hazardous goods (i.e., lithium battery manufacturer or exporter) should apply to the local customs for the Outbound Dangerous Goods Transportation Packaging Use Appraisal Result Form. The lithium batteries must indicate the rated energy (W·h). During the implementation of the outbound dangerous goods transportation packaging use appraisal, the customs will consider the following criteria for qualification:

• Clear, secure, and correct UN packaging marks, batch information, and dangerous goods symbols must be printed on the packaging container. The markings, symbols, and packaging should comply with relevant requirements.
• The external appearance of the packaging should be clean, with no residues, contamination, or leakage allowed.
• When securing wooden or fiberboard boxes with nails, they should be firmly nailed, and the nail tips should be bent down. Nail tips and caps should not protrude. The box body should be intact, and strapping should be tight around the box. Corrugated paper boxes should be undamaged, with a smooth and sturdy sealed closure, and strapping should be tight around the box.
• There should be non-conductive materials between individual batteries or battery packs and stacked batteries to prevent mutual contact.
• Batteries should have short-circuit protection devices.
• The electrodes of the batteries must not support the weight of other stacked batteries.
• Special provisions for the packaging of lithium batteries or battery packs are in international regulations should be met.

Common Violations

From common violations in the export of lithium batteries, the main issues identified by customs include: companies failing to apply for a Outbound Dangerous Goods Transportation Packaging Use Appraisal Result Form without meeting exemption conditions; lithium battery markings on the outer packaging being covered or not displayed as required.

Labeling Issues

• Can lithium battery transport labels be printed on A4 paper?

It is not recommended to print on A4 paper as it can easily lead to damage or detachment. For  transport by sea, transport labels should remain clear and visible even after soaking in seawater for more than three months.

• Do Class 9 transport labels in the TDG include a dashed outline? Are labels without a dashed line considered non-compliant?

According to label regulations in Section 5.2.2.2, TDG Volume 2, if the label is affixed to a contrasting background, there is no need to outline the outer edge with a dashed line.

How to conduct a use appraisal for lithium battery energy storage cabinets with a size exceeding the scope of dangerous goods packaging use appraisal?

For energy storage cabinets with built-in lithium batteries, as they lack external packaging, they do not fall within the scope of dangerous goods packaging inspection. Therefore, there is no need to submit documentation to customs for dangerous goods packaging use appraisal.

Requirements for the import of lithium-ion batteries?

dangerous goods packaging inspection.

For the import of lithium batteries, UN38.3 report is sufficient, and there is no need to undergo.