Lithium Batteries Transport and Packaging Instructions United States Hazardous Materials Regulation (49 CFR Parts 100 – 180) 2025 MIKE PAGEL MARCO OTTAVIANI
All rights reserved ©. No parts of this publication can be reproduced without the express editor’s authorization. Even though the editor and the author have paid maximum attention to ensure accuracy, they do not accept any responsibility in the case of errors or omissions. “Illustrations have been prepared in collaboration with AUTEC s.r.l and S.E.VAL. s.r.l. “ Copyright © 2025 This instruction manual has been prepared by Mike Pagel and Marco Ottaviani. Publishing and delivery in partnership with Hyper srl via Bessarione 5b - 30173 tel.: +39 041976896 fax: +39 041985730 e-mail: info@hyperedizioni.com http://www.hyperedizioni.com Finished to print on June 2025
Table of Content Introduction 10 1. International Transport Regulations 11 1.1 How to use this instruction manual 13 1.2 Definitions 17 1.3 General requirements 19 1.3.1 Test requirements 19 1.3.1.1 Manual of Test and Criteria 19 1.3.1.2 Transitional measures 19 1.3.1.3 Exemptions from the testing requirements 20 1.3.2 Manufacturing Quality Control Program 20 1.3.3 Protection from short circuit: 20 1.3.4 Damaged and Defective Batteries 21 1.3.5 Packages with both lithium batteries "packed with" and "contained in" equipment 22 1.3.6 Lithium batteries containing both a combination of primary lithium metal cells and rechargeable lithium ion cells 22 1.4 Packaging 23 1.4.1 Table with Packaging Codes 24 1.5 Marking and Labelling 26 1.6 Documentation 28 1.7 Special Provisions 32 1.8 Packing instructions 33 1.9 Transport Mode specific requirements 34 1.9.1 49 CFR 173.6 – Materials of Trade 34 1.9.2 IATA - Restrictions in checked baggage and carry-on baggage 34 1.9.3 IATA - Restrictions on packing lithium batteries with other dangerous goods 35 1.10 Training requirements 36 1.11 Lithium batteries in vehicles 37 1.12 Lithium batteries Installed in Cargo Transport Unit 39 1.13 Lithium batteries contained in data loggers and cargo tracking devices 40 2. Shipping Modes Summary Sheets 41 List of Summary Sheets 42 2.1 LITHIUM METAL CELLS & BATTERIES (NEW) 45 2.1.1. LITHIUM METAL CELLS (including lithium alloy cells) – UN 3090 45 2.1.1_IA_Full Fully regulated cells 46 2.1.1_IA_Medium Medium cells regulated 48 2.1.1_IB_Small Small cells excepted 50 2.1.2. LITHIUM METAL CELLS CONTAINED IN EQUIPMENT (including lithium alloy cells) - UN 3091 53 2.1.2_I_Full Fully regulated cells 54 2.1.2_I_Medium Medium cells regulated 56 2.1.2_II_Small Small cells excepted 58 2.1.3. LITHIUM METAL CELLS PACKED WITH EQUIPMENT (including lithium alloy cells) - UN 3091 61 2.1.3_I_Full Fully regulated cells 62 2.1.3_I_Medium Medium cells regulated 64 2.1.3_II_Small Small cells excepted 66 Copyright © www.batteriestransport.org 5
2.1.4. LITHIUM METAL BATTERIES (including lithium alloy batteries) – UN 3090 69 2.1.4_IA_Full Fully regulated batteries 70 2.1.4_IA_Medium Medium batteries regulated 72 2.1.4_IB_Small Small batteries excepted 74 2.1.5. LITHIUM METAL BATTERIES CONTAINED IN EQUIPMENT (including lithium alloy batteries) - UN 3091 77 2.1.5_I_Full Fully regulated batteries 78 2.1.5_I_Medium Medium batteries regulated 80 2.1.5_II_Small Small batteries excepted 82 2.1.6 LITHIUM METAL BATTERIES PACKED WITH EQUIPMENT (including lithium alloy batteries) - UN 3091 85 2.1.6_I_Full Fully regulated batteries 86 2.1.6_I_Medium Medium batteries regulated 88 2.1.6_II_Small Small batteries excepted 90 2.2 LITHIUM ION CELLS & BATTERIES (NEW) 93 2.2.1 LITHIUM ION CELLS (including lithium ion polymer cells) - UN 3480 93 2.2.1_IA_Full Fully regulated cells 94 2.2.1_IA_Medium Medium cells regulated 96 2.2.1_IB_Small Small cells excepted 98 2.2.2 LITHIUM ION CELLS CONTAINED IN EQUIPMENT (including lithium ion polymer cells) - UN 3481 101 2.2.2_I_Full Fully regulated cells 102 2.2.2_I_Medium Medium cells regulated 104 2.2.2_II_Small Small cells excepted 106 2.2.3 LITHIUM ION CELLS PACKED WITH EQUIPMENT (including lithium ion polymer cells) - UN 3481 109 2.2.3_I_Full Fully regulated cells 110 2.2.3_I_Medium Medium cells regulated 112 2.2.3_II_Small Small cells excepted 114 2.2.4 LITHIUM ION BATTERIES (including lithium ion polymer batteries) - UN 3480 117 2.2.4_IA_Full Fully regulated batteries 118 2.2.4_IA_Medium Medium batteries regulated 120 2.2.4_IB_Small Small batteries excepted 122 2.2.5 LITHIUM ION BATTERIES CONTAINED IN EQUIPMENT (including lithium ion polymer cells) - UN 3481 125 2.2.5_I_Full Fully regulated batteries 126 2.2.5_I_Medium Medium batteries regulated 128 2.2.5_II_Small Small batteries excepted 130 2.2.6 LITHIUM ION BATTERIES PACKED WITH EQUIPMENT (including lithium ion polymer batteries) - UN 34811 133 2.2.6_I_Full Fully regulated batteries 134 2.2.6_I_Medium Medium batteries regulated 136 2.2.6_II_Small Small batteries excepted 138 2.3 WASTE LITHIUM BATTERIES 141 2.3.1. LITHIUM METAL CELLS FOR DISPOSAL OR RECYCLING (including lithium alloy cells) – UN 3090 143 2.3.1_Full Fully regulated cells 144 2.3.1_Medium Medium cells regulated 146 2.3.1_Small Small cells excepted 148 6 Copyright © www.batteriestransport.org
2.3.2. LITHIUM METAL CELLS CONTAINED IN EQUIPMENT FOR DISPOSAL OR RECYCLING (including lithium alloy cells) - UN 3091 151 2.3.2_Full Fully regulated cells 152 2.3.2_Medium Medium cells regulated 154 2.3.2_Small Small cells excepted 156 2.3.3. LITHIUM METAL BATTERIES FOR DISPOSAL OR RECYCLING (including lithium alloy cells) – UN 3090 159 2.3.3_Full Fully regulated batteries 160 2.3.3_Medium Medium batteries regulated 162 2.3.3_Small Small batteries excepted 164 2.3.4. LITHIUM METAL BATTERIES CONTAINED IN EQUIPMENT FOR DISPOSAL OR RECYCLING (including lithium alloy cells) - UN 3091 167 2.3.4_Full Fully regulated cells 168 2.3.4_Medium Medium cells regulated 170 2.3.4_Small Small cells excepted 172 2.3.5. LITHIUM ION CELLS FOR DISPOSAL OR RECYCLING (including lithium ion polymer batteries) - UN 3480 175 2.3.5_Full Fully regulated cells 176 2.3.5_Medium Medium cells regulated 178 2.3.5_Small Small cells excepted 180 2.3.6. LITHIUM ION CELLS CONTAINED IN EQUIPMENT FOR DISPOSAL OR RECYCLING (including lithium ion polymer cells) - UN 3481 183 2.3.6_Full Fully regulated cells 184 2.3.6_Medium Medium cells regulated 186 2.3.6_Small Small cells excepted 188 2.3.7. LITHIUM ION BATTERIES FOR DISPOSAL OR RECYCLING (including lithium ion polymer batteries) - UN 3480 191 2.3.7_Full Fully regulated batteries 192 2.3.7_Medium Medium batteries regulated 194 2.3.7_Small Small batteries excepted 196 2.3.8. LITHIUM ION BATTERIES CONTAINED IN EQUIPMENT FOR DISPOSAL OR RECYCLING (including lithium ion polymer cells) - UN 3481 199 2.3.8_Full Fully regulated batteries 200 2.3.8_Medium Medium batteries regulated 202 2.3.8_Small Small batteries excepted 204 2.4 CELLS & BATTERIES DAMAGED & DEFECTIVE 207 2.4.1. LITHIUM METAL CELLS AND BATTERIES DAMAGED & DEFECTIVE 207 2.4.2. LITHIUM ION CELLS AND BATTERIES DAMAGED & DEFECTIVE 211 2.5 PRE-PRODUCTION PROTOTYPES & PRODUCTION RUNS ≤ 100 CELLS AND BATTERIES 2.5.1. LITHIUM METAL PRE-PRODUCTION PROTOTYPES & PRODUCTION RUNS ≤ 100 CELLS AND BATTERIES 216 2.5.2. LITHIUM ION PRE-PRODUCTION PROTOTYPES & PRODUCTION RUNS ≤ 100 CELLS AND BATTERIES 218 Copyright © www.batteriestransport.org 7
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Copyright © www.batteriestransport.org 9 Foreword When they are offered for transport, lithium batteries are regulated as hazardous materials/Dangerous Goods by the United States Department of Transportation (DOT) and other international transport authorities. This regulation is being permanently adapted to take into consideration the evolution of lithium battery technologies. Indeed, lithium metal battery markets have seen significant developments in the last twenty years. More recently, a similar evolution has been observed with the increasing role played by rechargeable Lithium-ion batteries in electrical and electronic equipment. Battery technology innovation and development helps an increasing number of technicians and engineers to design new equipment powered by portable sources of energy such as lithium batteries. The innovation capacity offered by lithium batteries opens the way to an increasing use of advanced rechargeable batteries in our modern society. The necessity for an increasing number of economic actors to respect the UN Dangerous Goods Regulation requires modern communication tools to inform the shippers of batteries about their duties and responsibilities when offering them for transport. The aim of this manual is to offer a simple and visual means to access the US DOT’s Pipeline and Hazardous Materials Safety Administration’s (PHMSA) Hazardous Materials Regulations (49 CFR Parts 100 – 180). via a modern multimedia communication tool. The regulation is presented in a summarized format covering ground, air and maritime transportation modes. In a page opposite the various regulations, the packaging and labelling instructions are illustrated to facilitate the implementation of the transport regulation as well as the packaging and labelling requirements by the shipper of lithium batteries. The objective of the funding Associations is to offer access to PHMSA’s hazardous materials regulations to the largest number of interested parties in order to make them aware of their duties and responsibilities when shipping lithium metal or lithium ion batteries. We thank Dr. Marco Ottaviani for preparing this exhaustive document with the most updated information and Emanuele Fanizzi, the Editor, who has accepted to translate the information into modern multimedia tools accessible to the largest number of users. June 2025
Introduction The complexity of the US DOT PHMSA’s hazardous materials regulations requires an increasing attention from those who are shipping these batteries. Lithium batteries are classified as “Class 9” Dangerous Goods in accordance with PHMSA’s regulations. The regulations may frequently change anyway depending on the transport model utilized. This Manual is aimed at delivering basic information to those who are not yet familiar with these Hazardous Materials Regulations. The manual is divided into two parts. Part 1 is summarizing the main regulation requirements for road, sea and air transport. Part 2 contains 40 Summary Sheets where the different transport modes requirements are summarized in one page. On the opposite page, an illustration of the packaging instructions is offered to the reader and presented with illustrative examples to guide the reader. The Manual is organised according to the UN Number of lithium batteries, considering "new" and "waste" batteries, the “quantities” of batteries that are shipped, starting from the largest “fully regulated” and ending with the small “excepted” quantities. In case of “used” batteries they have to be evaluated individually, as well as “damaged or defective” batteries. This manual is only a guide to assist the reader in preparing lithium batteries shipments for transportation by road, sea and air. It doesn’t replace any of the regulations manual that are applicable to the shipment of lithium batteries. If you have any comment on the content of this Manual, we would be pleased to take them into consideration for any further improvement of its content and its practical use. 10 Copyright © www.batteriestransport.org
1. International Transport Regulations Copyright © www.batteriestransport.org 11 UN Model Regulations The Recommendations concerning the transport of all type of dangerous goods have been developed by the United Nations Economic and Social Council’s Committee of Experts on the Transport of Dangerous Goods with the aim to ensure the safety of people, property and the environment. They are applicable to all modes of transport and are addressed to governments and international organizations concerned with the regulation of the transport of dangerous goods. They are published in the “Recommendations on the Transport of Dangerous Goods—Model Regulations”. Edition applicable → 23nd revised edition UN Manual of Tests and Criteria UN Manual of Test and Criteria are developed by the United Nations Economic and Social Council’s Committee of Experts on the Transport of Dangerous Goods and published as a separate manual in the “Recommendations on the Transport of Dangerous Goods— Manual of Tests and Criteria”. Edition applicable → Revision 8 PHMSA HMR The US DOT’s Pipeline and Hazardous Materials Safety Administration promulgates regulations on the transport of hazardous materials, including lithium batteries. These regulations are found in 49 CFR Parts 100 – 180 and are applicable in all US States and territories. These regulations allow for the voluntary use of international standards (e.g., ICAO, IMDG) under certain conditions. In this manual, we will use the HMR for highway and rail shipping requirements within the United States. For air and ocean regulations, we will use the international standards, the ICAO Technical Instructions and IMDG Code. Regulations update when rulemakings go final IMDG International Maritime Dangerous Goods (IMDG) Code is prepared by International Maritime Organization - IMO and is consistent with the United Nations “Recommendations on the Transport of Dangerous Goods—Model Regulations”. IMDG Code harmonizes the practices and procedures followed in the carriage of dangerous goods by sea and ensures compliance with the mandatory provisions of the SOLAS Convention (International Convention for the Safety of Life at Sea) and of Annex III of MARPOL (International Convention for the Prevention of Pollution from Ships). Edition applicable → IMDG Code 41-22 On a voluntarily base → IMDG Code 42-24 IATA ICAO The International Civil Aviation Organization (ICAO) develops the regulations for the safe transport of dangerous goods by air by any aircraft (including both internal and external carriage) on the basis of the Recommendations on the Transport of Dangerous Goods—Model Regulations. The ICAO regulations are codified in Annex 18 to the Convention on International Civil Aviation and in its Technical Instructions for the Safe Transport of Dangerous Goods by Air (ICAO – TI’s) and are recognized as the sole authentic legal source material in the air transport of dangerous goods. Edition applicable → ICAO Technical Instruction 2025-2026 edition The International Air Transport Association (IATA) publishes the Dangerous Goods Regulations (IATA DGR) based on the requirements of Annex 18 to the Convention on International Civil Aviation and the associated Technical Instructions for the Safe Transport of Dangerous Goods by Air, published by ICAO. IATA DGR constitute a manual of industry carrier regulations to be followed by all IATA Member airlines. There are certain differences between the IATA and ICAO regulations which stem from operational considerations and result in a regulatory regime which is necessarily more restrictive than the ICAO requirements. The IATA Regulations also incorporate additional material of practical assistance to users. Edition applicable → IATA Dangerous Goods Regulations 2025 – 66th Edition
12 Copyright © www.batteriestransport.org Periods of applications of International Transport Regulations This edition refers to the year 2025
1.1 How to use this instruction manual This manual is designed to provide a quick and effective guide to personnel who needs to prepare a shipment of lithium cells and batteries, either new or waste, by road, maritime and air transport modes. It consists of two parts. The first part describes and summarizes the regulatory aspects applicable to the transport of lithium batteries, introducing the basic concepts of the transport of dangerous goods, the duties they impose on producers, distributors and users; it also provides a guide to using the manual in order to give to the user the necessary information. In the second part Summary Sheets are provided for the three modes of transport. This information is condensed into one page. On the opposite page, images and flow charts illustrating how to perform in practice the packaging requirements, guiding the user step by step to prepare the correct shipment, in accordance with the regulation. The battery manufacturers have specific compliance obligations during production and only batteries successfully tested in accordance with the UN Manual of Tests and Criteria can be transported and placed on the market. The United Nations Manual of Tests and Criteria, updated periodically, imposes several requirements to be observed by shippers of Lithium Metal and Lithium Ion Batteries. Producers, distributors, users, waste managers, recyclers, all those who ship lithium batteries new or waste or even damaged and defective, or that forward them, with or without re-packing, have the obligation to comply with the applicable regulations depending on the different modes: road, maritime and air. It is therefore necessary to know, for each shipment, how to prepare the batteries, which packaging is allowed, how to mark and label packages and which documents to prepare to accompany the shipment. In additions shippers must take into account specific requirements of each transport mode. The provisions applicable in the various transport modes may differ because they are adapted to ensure maximum safety during transport. This means that regulators have introduced special provisions, restrictions and limitations, or other exemptions and exclusions, with the result of making even more complex the regulatory framework for the transport of Lithium Batteries. This manual will propose a decision path that, in six steps, allows users to access the information needed to prepare lithium batteries for transport with the appropriate packaging shipping papers, markings, and labels. These six steps are schematically presented, for new batteries, in the next flowchart. • Cell or battery Cell : a single encased electrochemical unit (one positive and one negative electrode) which exhibits a voltage differential across its two terminals. Battery: two or more cells which are electrically connected together. Step 1 Lithium Metal or Lithium Ion There are many types of lithium batteries which differ by the nature and composition of the electrode materials, the substances present in the electrolyte and the capacity to convert chemical energy into electricity. For the purposes of dangerous goods transport regulations, however, lithium batteries classification has been reduced to two groups: lithium metal and lithium ion. Copyright © www.batteriestransport.org 13
Lithium metal batteries, also including lithium metal alloys, consists of cells and batteries containing lithium in the metallic form. They are used to power small consumer electrical appliances and devices such as watches, cameras, calculators etc. They can also be assembled into large batteries e.g., in the oil rig drilling heads. Lithium ion batteries including lithium ion polymer battery consists of cells and batteries containing lithium in the ionic form. They are used in consumer electronics, such as mobile phones, laptops, tablets, and MP3 players. In the larger sizes they are being used to power cordless power tools, e-bikes, electric or hybrid electric vehicles, energy storage and many other industrial applications. The two groups of Lithium Batteries, the Lithium-Metal and the Lithium-Ion show different hazards and therefore are assigned to two different entries in the UN Dangerous Goods Regulations. The Regulations take also into consideration the transport and packaging requirements of such batteries installed in equipment or packed with equipment: UN 3090 LITHIUM METAL BATTERIES UN 3091 LITHIUM METAL BATTERIES CONTAINED IN EQUIPMENT UN 3091 LITHIUM METAL BATTERIES PACKED WITH EQUIPMENT UN 3480 LITHIUM ION BATTERIES UN 3481 LITHIUM ION BATTERIES CONTAINED IN EQUIPMENT UN 3481 LITHIUM ION BATTERIES PACKED WITH EQUIPMENT 14 Copyright © www.batteriestransport.org
Step 2 Evaluate and confirm – The content in grams of lithium in the lithium metal cells and batteries – The Wh rating of lithium ion cells and batteries Step 3 Decide if you ship: – Cells or batteries as batteries, – Cells and batteries contained in equipment or – Cells and batteries packed with equipment Step 4 Go to chapter § 2 of this manual and following the chart with the characteristics of your batteries, identify your transport requirements in accordance with the 22 groups listed under Step 4 in the Table. Step 5 Go to the first sheet of the identified group and according to the Flow Chart with the data collected, identify the specific Summary Sheet related to your transportation requirements for the given types of batteries to be shipped. Step 6 LEFT page of Summary Sheet: Use the information of the Summary Sheet from top to bottom, the relevant provisions have been included in the Summary Sheet according to a logical and practical path. The differences in road, maritime and air transport and packaging requirements have been identified by different background colors and highlighted step by step. A white background is used where the provisions are applicable to more than one transport mode. The orange background applies to road transportation, pink applies to maritime transportation and blue applies to air transportation. On the LEFT page, the Summary Sheet contains the following information: Where applicable, a) UN Number, b) Proper shipping Name, c) Class d) Packing Group e) Hazard label f) Prerequisite, conformity to the general requirements g) Specific requirements h) Exemption conditions i) Packing instructions j) Authorized packagings k) Quantity and weight limits l) Provisions applicable to road transportation (i.e. tunnel code, transport category, road transport exemptions) m) Marking and labelling on packages n) Overpack labels and markings o) Specific transport document required p) Instructions to personnel RIGHT page of Summary Sheet: On the opposite page (to the right), images show an example of how to practically prepare packaging for shipment: how to protect cells and batteries from short-circuit, verify, and use internal and external packaging, labelling and marking of packages. Copyright © www.batteriestransport.org 15
Step Actions and data Key words 1 New product (not waste) From the Product Data Sheet: Lithium Metal Ǧ Ǧ Ǧ 2 From the Product Data Sheet: Lithium metal content 6.5 g/cell Ǧ Ǥͷ Ȁ 3 Packed as batteries Ǧ 4 Go to § 2 “List of Summary Sheets” and follow the key words: New →Lithium metal →Cells →As Batteries Obtain → § 2.1.1 LITHIUM METAL CELLS Ǧ Ț ʹǤͳǤͳ 5 Go to § 2.1.1 and follow the flow chart for “road transportation” →according the lithium content 6.5 g/cell, your Summary Sheet is →2.1.1_IA Full Ǧ Ț ʹǤͳǤͳ̴ 6 →Now apply it following the provision for “Road” (the orange column) and the one in white background, which are common to other transport modes End of the search, Ǧ ʹǤͳ Ƭ ȋ Ȍ ʹǤͳǤͳ ȋ Ȍ ͵ͲͻͲ ǣ Ǥ ǡ ͳ͵Ǥͳͺͷȋ Ȍ Ǧ ͳͺͺ ͻͺǡ § ʹǤͳǤͳ̴ ȋȀ Ȍ ǡ ͳ͵ǤͳͺͷȋȌȋȌ Ǧ ͻͲ͵ Ǧ ͻͲ͵ ͻͺǡ § ʹǤͳǤͳ̴ ȋȀ Ȍ ͳδ ͷ ȋȀ Ȍ ε ͷ ǡ ͳ͵Ǥͳͺͷȋ Ȍ Ǧ ͻͲ͵ Ǧ ͻͲ͵ ͻͺǡ § ʹǤͳǤͳ̴ Ǧ ʹǤͳǤͳ ʹǤͳǤͳ̴ ̴ ͵ͲͻͲ ʹǤͳǤͳ̴ ̴ ʹǤͳǤͳ̴ ̴ ʹǤͳǤʹ ʹǤͳǤʹ̴ ̴ ͵Ͳͻͳ ʹǤͳǤʹ̴ ̴ ʹǤͳǤʹ̴ ̴ ʹǤͳǤ͵ ʹǤͳǤ͵̴ ̴ ͵Ͳͻͳ ʹǤͳǤ͵̴ ̴ ʹǤͳǤ͵̴ ̴ Including Lithium ʹǤͳǤͶ Metal ʹǤͳǤͶ̴ ̴ Alloy ͵ͲͻͲ ʹǤͳǤͶ̴ ̴ ʹǤͳǤͶ̴ ̴ ʹǤͳǤͷ ʹǤͳǤͷ̴ ̴ ͵Ͳͻͳ ʹǤͳǤͷ̴ ̴ ʹǤͳǤͷ̴ ̴ ʹǤͳǤ ʹǤͳǤ̴ ̴ ͵Ͳͻͳ ʹǤͳǤ̴ ̴ ʹǤͳǤ̴ ̴ ʹǤʹǤͳ ͵ͶͺͲ ʹǤʹǤͳ̴ ̴ ʹǤʹǤͳ̴ ̴ ʹǤʹǤͳ̴ ̴ ʹǤʹǤʹ ʹǤʹǤʹ̴ ̴ ͵Ͷͺͳ ʹǤʹǤʹ̴ ̴ ʹǤʹǤʹ̴ ̴ ʹǤʹǤ͵ ʹǤʹǤ͵̴ ̴ ͵Ͷͺͳ ʹǤʹǤ͵̴ ̴ ʹǤʹǤ͵̴ ̴ Including Lithium ʹǤʹǤͶ Ion ͵ͶͺͲ ʹǤʹǤͶ̴ ̴ polymer ʹǤʹǤͶ̴ ̴ ʹǤʹǤͶ̴ ̴ ʹǤʹǤͷ ʹǤʹǤͷ̴ ̴ ͵Ͷͺͳ ʹǤʹǤͷ̴ ̴ ʹǤʹǤͷ̴ ̴ ʹǤʹǤ ʹǤʹǤ̴ ̴ ͵Ͷͺͳ ʹǤʹǤ̴ ̴ ʹǤʹǤ̴ ̴ ʹǤ͵Ǥͳ ʹǤ͵Ǥͳ̴ ͵ͲͻͲ ʹǤ͵Ǥͳ̴ ʹǤ͵Ǥͳ̴ ʹǤ͵Ǥʹ ʹǤ͵Ǥʹ̴ ͵Ͳͻͳ ʹǤ͵Ǥʹ̴ ʹǤ͵Ǥʹ̴ ʹǤ͵Ǥ͵ ʹǤ͵Ǥ͵̴ ͵ͲͻͲ ʹǤ͵Ǥ͵̴ ʹǤ͵Ǥ͵̴ ʹǤ͵ǤͶ ʹǤ͵ǤͶ̴ ͵Ͳͻͳ ʹǤ͵ǤͶ̴ ʹǤ͵ǤͶ̴ ʹǤ͵Ǥͷ ͵ͶͺͲ ʹǤ͵Ǥͷ̴ ʹǤ͵Ǥͷ̴ ʹǤ͵Ǥͷ̴ ʹǤ͵Ǥ ʹǤ͵Ǥ̴ ͵Ͷͺͳ ʹǤ͵Ǥ̴ ʹǤ͵Ǥ̴ ʹǤ͵Ǥ ʹǤ͵Ǥ̴ ͵ͶͺͲ ʹǤ͵Ǥ̴ ʹǤ͵Ǥ̴ ʹǤ͵Ǥͺ ʹǤ͵Ǥͺ̴ ͵Ͷͺͳ ʹǤ͵Ǥͺ̴ ʹǤ͵Ǥͺ̴ Example of Six steps method: Lithium metal cell, with Li content 6.5 g/cell, packed as batteries, transported by road 16 Copyright © www.batteriestransport.org
1.2 Definitions “Approved packagings” means packagings manufactured under a quality assurance programme, which satisfies the competent authority, conform to the prototype which has passed specific tests. “Automotive battery” means any battery used for automotive starter, lighting, or ignition power; “Industrial battery” means any battery designed for industrial or professional uses or used in any type of electric vehicle “Battery” means two or more cells which are electrically connected together and fitted with devices necessary for use, for example, case, terminals, marking and protective devices. A single cell lithium battery is considered a "cell”. "Battery pack" means any set of primary or rechargeable cells or batteries that are connected together and/or encapsulated within an outer casing so as to form a complete unit that the end-user is not intended to split up or open. Note: “battery packs”, “modules” or “battery assemblies” having the primary function of providing a source of power to another piece of equipment, for the purposes of this manual are treated as batteries. "Button cell" means any small round portable battery or accumulator whose diameter is greater than its height. “Cell” means a single encased electrochemical unit (one positive and one negative electrode) which exhibits a voltage differential across its two terminals. Note: Under the International Dangerous Goods Regulations and the UN Manual of Tests and Criteria, to the extent the encased electrochemical unit meets the definition of “cell”, it is a “cell”, not a “battery”, regardless of whether the unit is termed a “battery” or a “single cell battery” outside of regulations and the UN Manual of Tests and Criteria . "Consignee" means any person, organization or government which is entitled to take delivery of a consignment "Consignor" means any person, organization or government which prepares a consignment for transport; “Hazardous Materials Regulations” means the regulations promulgated by the US DOT’s Pipeline and Hazardous Materials Safety Administration and are found in 49 CFR Parts 100 – 180. “IATA DGR” means the International Air Transport Association - Dangerous Goods Regulation "IMDG Code" means the International Maritime Dangerous Goods Code, “Large packaging” means a packaging consisting of an outer packaging which contains articles or inner packaging and which a) is designed for mechanical handling b) exceeds 400 kg net mass or 450 litres capacity but has a volume of not more than 3 m3 “Lithium metal batteries” have lithium metal or lithium compounds as an anode. The most common type of lithium cell used in consumer applications are primary cells using metallic lithium as anode and manganese dioxide as cathode, with a salt of lithium dissolved in an organic solvent. “Lithium-ion batteries” (sometimes abbreviated Li-ion batteries) are a type of secondary (rechargeable) battery commonly used in consumer electronics. Also included within lithium-ion batteries are lithium polymer batteries. “Lithium battery”: in this manual the term "lithium battery" covers all cells and batteries containing lithium in any form. "Manual of Tests and Criteria" mean the Recommendations on the Transport of Dangerous Goods, Manual of Tests and Criteria, published by the United Nations. "Overpack" means an enclosure used to contain one or more packages, consolidated into a single unit easier to handle and stow during carriage; "Package" means the complete product of the packing operation, consisting of the packaging and its contents prepared for dispatch. Copyright © www.batteriestransport.org 17
"Shipper” has the same meaning of consignor. "Single cell battery" as defined in Part III, sub-section 38.3.2.3 of the UN Manual of Tests and Criteria is considered a “cell” and must be transported according to the requirements for “cells”. “UN Model Regulations" means the UN Recommendations on the Transport of Dangerous Goods Model Regulation published by the United Nations. "Wastes" means substances, solutions, mixtures or articles for which no direct use is envisaged but which are transported for reprocessing, dumping, elimination by incineration or other methods of disposal. Words “shall", "should" and "may": in the International Transport Regulations, the words "shall", "should" and "may" mean that the relevant provisions are "mandatory", "recommendatory" and "optional", respectively. 18 Copyright © www.batteriestransport.org
Copyright © www.batteriestransport.org 19 1.3 General requirements 1.3.1 Test requirements 1.3.1.1 Manual of test and Criteria Each cell or battery is of the type proved to meet the requirements of each test of the Manual of Tests and Criteria, Part III, sub-section 38.3. Batteries shall be of a type proved to meet the testing requirements of the Manual of Tests and Criteria, part III, sub-section 38.3, irrespective of whether the cells of which they are composed are of a tested type. Due to copyright restriction, this manual cannot contain the text of Manual of Tests and Criteria, however, as a user, you can consult it at the following website: https://unece.org/transport/documents/2023/11/standards/manual-tests-and-criteria-revision-8 1.3.1.2 Transitional measures Depending on the period of production, cells and batteries can be transported according the following time frames: 49 CFR 173.185(a) Lithium cells and batteries manufactured according to a type meeting the requirements of sub-section 38.3 of the Manual of Tests and Criteria, Revision 3, Amendment 1 or any subsequent revision and amendment applicable at the date of the type testing may continue to be carried, unless otherwise provided in ADR. Lithium cells and batteries manufactured before 1 July 2003 meeting the requirements of the Manual of Tests and Criteria, Revision 3, may continue to be carried if all other applicable requirements are fulfilled. IMDG 41-22 and 41-24 IATA 2025 Each cell or battery is of the type proved to meet the requirements of each test of the UN Manual of Tests and Criteria, Part III, subsection 38.3. Cells and batteries manufactured according to a type meeting the requirements of subsection 38.3 of the UN Manual of Tests and Criteria, Revision 3, Amendment 1 or any subsequent revision and amendment applicable at the date of the type testing may continue to be transported, unless otherwise provided in these Regulations. Cell and battery types only meeting the requirements of the UN Manual of Tests and Criteria, Revision 3, are no longer valid. However, cells and batteries manufactured in conformity with such types before 1 July 2003 may continue to be transported if all other applicable requirements are fulfilled.
1.3.3 Protection from short circuit Cells and batteries must be protected so as to prevent short circuits. This includes protection against contact with conductive materials within the same packaging that could lead to a short circuit. 20 Copyright © www.batteriestransport.org 1.3.1.3 Exemptions from the testing requirements: Exemptions under the Road and Maritime Transport Modes (US Highway/Rail: 49 CFR 173.185(e): IMDG: special provision 310) The testing requirements in sub-section 38.3 of the Manual of Tests and Criteria do not apply to • Low production runs consisting of not more than 100 cells and batteries. • Pre-production prototypes of lithium cells and batteries when these prototypes are transported for testing. They have to be packed in accordance to Packing Instruction P910 (IMDG) or 173.185(e) for US highway/rail. Exemptions under the Air Transport Mode (special provision A88) Small but significant differences exist in air transport: • Low production runs consisting of not more than 100 cells and batteries per year. • Transport aboard Cargo aircraft must be approved by the appropriate authority of the State of origin, even if all requirements of Packing Instruction 910 are met. Due to copyright restriction, this manual cannot contain the text of the exemption from test requirements, however, as a user, you can consult SP 310 at the following website: SP 310 https://unece.org/adr-2025-files 1.3.2 Manufacturing Quality Control Program (49 CFR does not include this requirement, but international shippers must take note). Cells and batteries shall be manufactured under a quality management programme that includes: • description of the organizational structure; • responsibilities of personnel with regard to design and product quality; • inspection and test instruction; • quality control instruction; • quality assurance instruction, • process operation instructions; • process controls, including relevant activities to prevent and detect internal short circuit failure during manufacture of cells; • quality records, such as inspection reports, test data, calibration data and certificates; • test data shall be kept and made available to the competent authority upon request; • management reviews under quality management programme; • documents control and revision; • a means for control of cells or batteries that are not conforming to the type tested • training programmes and qualification procedures for relevant personnel; and • procedures to ensure that there is no damage to the final product. NOTE: In house quality management programmes may be accepted. Third party certification is not required, but the procedures listed above shall be properly recorded and traceable. A copy of the quality management programme shall be made available to the competent authority upon request. Due to copyright restriction, this manual cannot contain the text of the Manufacturing Quality Control Programme however, as a user, you can consult 2.2.9.1.7.1 (e) (i) to (ix) ADR at the following website: • https://unece.org/adr-2025-files
Examples of protection against short circuits include, but are not limited to: • individual protection of the battery terminals, • inner packaging to prevent contact between cells and batteries, • batteries with recessed terminals designed to protect against short circuits, or • the use of an electrically non-conductive and non-combustible cushioning material to fill empty space between the cells or batteries in the packaging. 1.3.4 Damaged and Defective Batteries Damaged lithium batteries mean in particular, but are not limited to: - Cells or batteries identified as being defective for safety reasons; - Cells or batteries that have leaked or vented; - Cells or batteries that cannot be diagnosed prior to carriage; or - Cells or batteries that have sustained physical or mechanical damage. In assessing a cell or battery as damaged or defective, an assessment or evaluation shall be performed based on safety criteria from the cell, battery or product manufacturer or by a technical expert with knowledge of the cell’s or battery’s safety features. An assessment or evaluation may include, but is not limited to, the following criteria: (a) Acute hazard, such as gas, fire, or electrolyte leaking; (b) The use or misuse of the cell or battery; (c) Signs of physical damage, such as deformation to cell or battery casing, or colours on the casing; (d) External and internal short circuit protection, such as voltage or isolation measures; (e) The condition of the cell or battery safety features; or (f) Damage to any internal safety components, such as the battery management system. Transport of damaged and defective batteries is regulated as follow: Cells and batteries “not critical” (not liable to dangerously react during transport): Permitted according Special Provision 376 and Packing Instructions P908 and LP904 Cells and batteries “critical” (liable to dangerously react during transport): Permitted according Special Provision 376 and Packing Instructions P911 and LP906 IATA 2023: Forbidden for air transport both “critical” and “not critical” cells and batteries. Damaged, Defective, or Recalled Cells and batteries The packing procedures require approved packagings of packing group I performance level. Packages shall be marked “DAMAGED/DEFECTIVE LITHIUM-ION BATTERIES” or “DAMAGED/DEFECTIVE LITHIUM METAL BATTERIES”, as applicable. Cells or batteries shall be protected against short circuit. Each damaged or defective cell or battery or equipment containing such cells or batteries shall be individually packed in inner packaging and placed individually inside an outer packaging. Each inner packaging shall be surrounded by sufficient non-combustible and electrically nonconductive thermal insulation material to protect against a dangerous evolution of heat. Appropriate measures shall be taken to minimize the effects of vibrations and shocks, prevent movement of the cell or battery within the package that may lead to further damage and a Copyright © www.batteriestransport.org 21 49 CFR 173.185(f) IMDG 41-22 and 42-24
dangerous condition during carriage. Cushioning material that is non-combustible and electrically non-conductive may also be used to meet this requirement. The inner packaging or outer packaging shall be leak-proof to prevent the potential release of electrolyte. A181 - Air transport regulation clarifies the requirements for this combination of lithium batteries packed with equipment and lithium batteries contained in equipment in the same package: - the package must be marked UN 3091 Lithium metal batteries packed with equipment, or UN 3481 Lithium ion batteries packed with equipment as appropriate. - all applicable parts of both packing instructions must be met. - button cell batteries installed in equipment (including circuit boards) need not be considered. - the total weight of lithium batteries contained in any package must not exceed the limits for passenger aircraft or cargo aircraft, as applicable; - the Shipper's Declaration must indicate UN 3091 Lithium metal batteries packed with equipment or UN 3481 Lithium ion batteries packed with equipment, as appropriate. - if a package contains both lithium ion batteries and lithium metal batteries packed with and contained in equipment, the package must be marked as required for both battery types and the dangerous goods transport document must indicate both UN 3091 Lithium metal batteries packed with equipment and UN 3481 Lithium ion batteries packed with equipment. 1.3.6 Lithium batteries containing both a combination of primary lithium metal cells and rechargeable lithium ion cells According SP 387 and SP 388 of 49 CFR 172.102, lithium batteries containing both primary lithium metal cells and rechargeable lithium ion cells shall be assigned to UN Nos. 3090 or 3091 as appropriate. When such batteries are carried in accordance with special provision 188, the total lithium content of all lithium metal cells contained in the battery shall not exceed 1.5 g and the total capacity of all lithium ion cells contained in the battery shall not exceed 10 Wh. 22 Copyright © www.batteriestransport.org 1.3.5 Packages containing a combination of lithium batteries "packed with" and "contained in" equipment IMDG 41-22 and 42-24, 49 CFR 172.102 SP390 - When a package contains a combination of lithium batteries contained in equipment and lithium batteries packed with equipment, the following requirements apply for the purposes of package marking and documentation: (a) the package shall be marked “UN 3091” or “UN 3481”, as appropriate. If a package contains both lithium ion batteries and lithium metal batteries packed with and contained in equipment, the package shall be marked as required for both battery types. However, button cell batteries installed in equipment (including circuit boards) need not be considered; (b) the transport document shall indicate “UN 3091 LITHIUM METAL BATTERIES PACKED WITH EQUIPMENT” or “UN 3481 LITHIUM ION BATTERIES PACKED WITH EQUIPMENT”, as appropriate. If a package contains both lithium metal batteries and lithium ion batteries packed with and contained in equipment, then the transport document shall indicate both “UN 3091 LITHIUM METAL BATTERIES PACKED WITH EQUIPMENT” and “UN 3481 LITHIUM ION BATTERIES PACKED WITH EQUIPMENT”. IATA 2025
1.4 Packaging Dangerous goods shall be packed in good quality packagings. Packagings shall be strong enough to withstand the shocks and loadings normally encountered during carriage, including trans-shipment between transport units and between transport units and warehouses. Packagings shall be constructed and closed so as to prevent any loss of contents when prepared for transport which might be caused under normal conditions of transport, by vibration, or by changes in temperature, humidity or pressure No dangerous residue shall adhere to the outside of packagings during carriage. "Overpack" means an enclosure used (by a single consignor in the case of Class 7) to contain one or more packages, consolidated into a single unit easier to handle and stow during carriage; Examples of Overpack: 1. A loading tray such as a pallet, on which several packages are placed or stacked and secured by a plastics strip, shrink or stretch wrapping or other appropriate means; or 2. An outer protective packaging such as a box or a crate; "Package" means the complete product of the packing operation, consisting of the packaging and its contents prepared for dispatch. Dangerous goods shall not be packed together in the same outer packaging or in large packagings, with dangerous or other goods if they react dangerously with each other and cause: (a) combustion or evolution of considerable heat; (b) evolution of flammable, asphyxiant, oxidizing or toxic gases; (c) the formation of corrosive substances; or (d) the formation of unstable substances. Before being filled and handed over for carriage, every packaging, including IBCs and large packagings, shall be checked to be free from corrosion, contamination or other defects Any packaging which shows signs of weakening, with reference to the approved prototype shall no longer be used or shall be refurbished so that it can pass the tests required for the prototype. Copyright © www.batteriestransport.org 23
Approved packagings: The packs can be used must have passed specific tests and testing conform to the prototype tested. Packagings shall be manufactured, reconditioned and tested under a quality assurance programme which satisfies the competent authority. Shall bear markings which are durable, legible and readily visible, constituted by a sequence of symbols, letters and numbers, i.e.: 1.4.1 Table with Packaging Codes Kind Material Category Code A. Steel removable head 1A2 B. Aluminium removable head 1B2 D. Plywood - 1D G. Fibre - 1G H. Plastics removable head 1H2 Drums N. Metal, other than steel or aluminium removable head 1N2 A. Steel removable head 3A2 B. Aluminium removable head 3B2 Jerricans H. Plastics removable head 3H2 A. Steel - 4A B. Aluminium - 4B ordinary 4C1 C. Natural wood with sift-proof walls 4C2 D. Plywood - 4D F. Reconstituted wood - 4F G. Fibreboard - 4G H. Plastics expanded 4H1 solid 4H2 Boxes N. Metal, other than steel or aluminium - 4N The United Nations packaging symbol Plastic Drum with removable head For packing groups: I, II, III Maximum Gross mass in kilograms Carriage of Solids The State authorizing the allocation of the mark Name of Manufacturer Year of Manufacturing (last two digit) 24 Copyright © www.batteriestransport.org
Packing groups letter: X for packing groups I, II and III Y for packing groups II and III Z for packing groups III only "Drum" means a flat-ended or convex-ended cylindrical packaging made out of metal, fibreboard, plastics, plywood or other suitable materials. This definition also includes packagings of other shapes, e.g. round, taper-necked packagings or pail-shaped packagings. Wooden barrels and jerricans are not covered by this definition. "Jerrican" means a metal or plastics packaging of rectangular or polygonal cross-section with one or more orifices. "Box" means a packaging with complete rectangular or polygonal faces, made of metal, wood, plywood, reconstituted wood, fibreboard, plastics or other suitable material. Small holes for purposes of ease of handling or opening or to meet classification requirements, are permitted as long as they do not compromise the integrity of the packaging during carriage. Copyright © www.batteriestransport.org 25
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