Lithium Battery Shipping Compliance: Complete Guide for Electronics Importers

Lithium batteries are Class 9 Miscellaneous Dangerous Goods, but their specific classification depends on battery chemistry, size, and how they're shipped.

Battery Chemistry Types

• Lithium Ion (Li-ion): Rechargeable batteries found in phones, laptops, power tools. UN3480/3481.
• Lithium Metal: Non-rechargeable batteries (button cells, some specialty applications). UN3090/3091.

Shipping Configuration Classifications

Key Definitions

• Contained in equipment: Battery installed in the device (e.g., phone with battery inside)
• Packed with equipment: Battery and device in same package but not connected
• Section I: Fully regulated dangerous goods requiring full compliance
• Section II: Reduced requirements for smaller batteries meeting specific criteria

Watt-Hour Ratings

Battery size is measured in Watt-hours (Wh) for cells and batteries:

• Cell: Single electrochemical unit
• Battery: Two or more cells connected together

Section II thresholds: Li-ion cells ≤20Wh, Li-ion batteries ≤100Wh; Li-metal cells ≤1g lithium, Li-metal batteries ≤2g lithium.

Most consumer electronics qualify for Section II, which significantly reduces compliance burden while maintaining safety.

Section II Eligibility Requirements

• Cell/battery size within thresholds (Li-ion: ≤20Wh cell, ≤100Wh battery)
• UN38.3 testing completed
• Packaging meets specific requirements
• Quantity limits per package observed

Section II Quantity Limits

Section II Labeling

Packages must display the lithium battery handling label:

• Minimum size: 120mm x 110mm (smaller allowed on small packages)
• UN number(s) displayed on label
• Contact phone number for emergency response

Section II Documentation

• No Shipper's Declaration required
• Airway bill/bill of lading must state: "Lithium ion batteries in compliance with Section II of PI [xxx]"
• UN38.3 test summary available upon request

What Disqualifies Section II?

• Battery exceeds Wh or lithium content thresholds
• Package exceeds quantity limits
• Batteries are damaged or recalled
• Standalone batteries shipped by air at State of Charge >30%

Every lithium battery shipped internationally must have passed UN38.3 testing. This is non-negotiable and frequently checked at import.

What is UN38.3?

A series of eight safety tests defined in the UN Manual of Tests and Criteria that verify batteries are safe for transport:

1. T.1 Altitude simulation: Low pressure exposure
2. T.2 Thermal test: Temperature cycling
3. T.3 Vibration: Simulated transport vibration
4. T.4 Shock: Impact testing
5. T.5 External short circuit: Short circuit protection
6. T.6 Impact/crush: Mechanical damage resistance
7. T.7 Overcharge: Charging beyond limits (rechargeable only)
8. T.8 Forced discharge: Discharge beyond limits

Test Summary Document

Since 2020, a UN38.3 Test Summary must be available. It must include:

• Battery manufacturer name and contact
• Testing laboratory and report identification
• Battery description (type, Wh rating, physical dimensions)
• Reference to test report
• Results confirmation (pass/fail each test)

Obtaining Test Documentation

Request test summaries from your battery/product supplier:

• Should be provided with first shipment
• Keep on file for all battery types in your product line
• Verify Wh ratings match your actual products
• Update when battery designs change

What Happens Without UN38.3?

• Shipment rejection by carrier
• Customs detention and examination
• Potential seizure and destruction
• Fines for shipping non-compliant dangerous goods

Proper packaging is critical for battery safety. Regulations specify detailed requirements to prevent short circuits, damage, and thermal events.

Core Packaging Principles

• Short circuit prevention: Terminals must be protected from contact with conductive materials
• Movement prevention: Batteries must not shift within packaging
• Rigid outer packaging: Strong containers that resist damage during handling

Short Circuit Prevention Methods

• Tape over terminals
• Individual plastic bags for each battery
• Foam inserts separating batteries
• Original retail packaging
• Battery caps or covers

Outer Packaging Requirements

Section II shipments require:

• Strong outer packaging (corrugated fiberboard, wood, or plastic)
• Capable of withstanding 1.2m drop test in any orientation
• For cells/batteries only: Must be capable of withstanding 24kg stacking test

Section I shipments require:

• UN specification packaging
• Specific packing instructions (PI965, PI966, PI967 for Li-ion)
• More stringent performance standards

Equipment Packaging Considerations

• Devices must be protected from accidental activation
• Power switches should be in OFF position or protected
• Packaging must prevent device from moving and activating

Overpacks

When consolidating multiple packages:

• Overpack must be marked "OVERPACK"
• All package marks and labels must be visible or reproduced on overpack
• Total quantities must not exceed aircraft/vessel limits

Air freight of lithium batteries has the most stringent requirements due to the consequences of in-flight thermal events.

State of Charge Requirements

Standalone batteries (UN3480/UN3090) shipped by air:

• State of Charge (SOC) must not exceed 30% of rated capacity
• Applies to Section I and Section II air shipments
• Manufacturer must provide SOC verification
• Does not apply to batteries in or with equipment

Cargo Aircraft Only (CAO)

Some battery shipments are restricted to CAO:

• Section I lithium ion batteries (standalone)
• Section I lithium metal batteries (standalone)
• Batteries exceeding 35kg gross per package
• Damaged or recalled batteries (if shippable at all)

Passenger Aircraft Allowed

Section II batteries with equipment are generally permitted on passenger aircraft:

• Contained in equipment: Most consumer electronics
• Packed with equipment: With quantity limits
• Standalone batteries: Prohibited on passenger aircraft in most cases

Quantity Limits Per Aircraft

Airlines enforce limits on total lithium batteries per flight:

• Varies by carrier and aircraft type
• May require advance booking and approval
• Peak season may have reduced allocations

Airline-Specific Requirements

• Many airlines have stricter policies than IATA minimums
• Some refuse all lithium battery shipments
• Check carrier-specific requirements before booking
• Get written confirmation for large battery shipments

Ocean freight is generally more accommodating for lithium batteries, but still has specific requirements and practical challenges.

IMDG Code Requirements

• Less restrictive than IATA for most shipments
• No 30% SOC requirement for ocean freight
• Higher quantity limits per package
• Section II provisions similar to air

Container Stowage Requirements

• Lithium batteries: Stowage away from heat sources
• Standalone batteries: Some carriers require deck stowage only
• Documentation: Container packing certificate may be required

Practical Considerations

Ocean transit introduces other challenges:

• Temperature exposure: Containers can reach 60°C+ on tropical routes
• Humidity: Condensation risk during temperature swings
• Transit time: Longer exposure to environmental conditions
• Handling: More loading/unloading points than air

Mixed Cargo Considerations

• Batteries may have segregation requirements from other dangerous goods
• Some products cannot be consolidated in same container
• Verify compatibility before combining shipments

Port and Customs Inspections

• Battery shipments may be targeted for examination
• Have documentation readily available
• Labels must be clearly visible on packages
• UN38.3 test summaries should be in customs documentation

Here's how common consumer electronics products are typically classified for shipping purposes.

Mobile Phones and Tablets

• Battery type: Lithium ion, typically 5-20Wh
• Classification: UN3481 (contained in equipment)
• Section: Section II eligible
• Notes: Ensure devices cannot activate during transport

Laptops and Notebooks

• Battery type: Lithium ion, typically 40-100Wh
• Classification: UN3481 (contained in equipment)
• Section: Section II if battery ≤100Wh
• Notes: Batteries over 100Wh require Section I handling

Power Banks

• Battery type: Lithium ion, varies widely (5-100+Wh)
• Classification: UN3480 (batteries only) since not part of equipment
• Section: Section II if ≤100Wh, quantity limits apply
• Notes: Power banks are standalone batteries, not equipment

Wireless Earbuds and Headphones

• Battery type: Lithium ion, typically <5Wh
• Classification: UN3481 (contained in equipment)
• Section: Section II eligible
• Notes: Often eligible for "Button Cell" exemption if very small

Power Tools

• Battery type: Lithium ion, 20-100+Wh
• Classification: UN3481 (packed with or in equipment)
• Section: Section II if batteries ≤100Wh
• Notes: High-power batteries may exceed thresholds

Electric Vehicles and E-bikes

• Battery type: Lithium ion, typically 300-1000+Wh
• Classification: UN3481 (contained in equipment)
• Section: Section I (batteries exceed 100Wh)
• Notes: Special vehicle provisions may apply

Systematic compliance management prevents shipment delays and regulatory issues.

Product Database Requirements

Maintain records for every battery-containing product:

• Battery type (Li-ion or Li-metal)
• Wh rating or lithium content
• UN number and proper shipping name
• Section I or Section II classification
• UN38.3 test summary (on file)
• Approved packaging specifications

Supplier Requirements

Mandate the following from battery/product suppliers:

• UN38.3 test summary for all battery types
• Wh rating marked on batteries
• SDS (Safety Data Sheet) for battery products
• Certification of compliance with transport regulations

Training Program

Personnel must be trained on:

• Battery identification and classification
• Packaging requirements
• Documentation preparation
• Emergency procedures

Training must be renewed every 2-3 years depending on mode.

Documentation Templates

Standardize your shipping documents:

• Shipper's Declaration (Section I shipments)
• Section II statements for airway bills
• Packing instructions
• Emergency contact information

Carrier Relationships

• Pre-qualify carriers for battery acceptance
• Document carrier-specific requirements
• Establish procedures for advance booking
• Know escalation paths when issues arise