Shipping Requirements for Lithium Batteries

Rechargeable lithium batteries -also called lithium ion (Li-ion), or secondary lithium batteries- and non-rechargeable lithium batteries -also called lithium metal, or primary lithium batteries- provide more energy and a longer operating life than other types of batteries. They have the potential to generate a significant amount of heat or catch fire if damaged or improperly handled.

Laptop computers, cell phones, cameras, personal digital assistants (PDA), or other battery-powered devices are not regulated as hazardous materials when carried by individuals in an automobile by highway or in carry-on baggage by air. Electronic devices containing lithium batteries are not allowed in checked luggage.

The regulations for shipping lithium batteries are based on the size of the battery or cell to be shipped (a battery is made up of one or more connected cells). These size categories depend on the lithium metal or alloy (Li) content of a non-rechargeable battery or cell, or the equivalent lithium content (ELC) for rechargeable lithium batteries or cells, as follows:

Small – up to 1.0 g Li per non-rechargeable cell or 1.5 g ELC per rechargeable cell; up to 2.0 g Li per non-rechargeable battery or 8 g ELC per rechargeable battery.
Medium – up to 5 g Li per non-rechargeable cell or 5 g ELC per rechargeable cell; up to 25 g Li per non-rechargeable battery or 25 g ELC per rechargeable battery.
Large – greater than 5 g Li per non-rechargeable cell or 5 g ELC per rechargeable cell; greater than 25 g Li per non-rechargeable battery or 25 g ELC per rechargeable battery.

Small lithium batteries and cells include cell phone batteries, camera batteries, and internal batteries for notebook computers. Medium lithium batteries and cells include some extended life batteries for notebook computers, and batteries for video and lighting equipment. Large lithium batteries and cells are primarily those used in industry. Large batteries may be found in some electric and hybrid vehicles, as well as some mobility devices and scooters.

A shipper is responsible for ensuring that the batteries and cells offered for transportation have passed the tests found in the UN Manual of Tests and Criteria. Check with the battery manufacturer or distributor to determine if a battery design has passed these tests. Packaged batteries or cells must be separated in a way to prevent short circuits and damage to terminals. They must be packed in a strong outer packaging or be contained in equipment.

Packaging requirements for “small” lithium cells and batteries are found in the HMR in § 172.102, Special Provision 188; the requirements for “medium” lithium cells and batteries are found in the HMR in § 172.102, Special Provision 189.

Primary (non-rechargeable) lithium batteries and cells are forbidden for transport aboard passenger carrying aircraft as cargo. Secondary (rechargeable) small lithium batteries and cells are authorized aboard passenger carrying aircraft when properly packaged and identified.

A package containing “small” lithium batteries or cells must be:

Marked to indicate that it contains lithium batteries and that special procedures should be followed in the event the package is damaged;
Accompanied by a document indicating that the package contains lithium batteries and special procedures should be followed in the event that the package is damaged;
Capable of withstanding a 1.2 meter drop test in any orientation without damage to cells or batteries contained in the package, without shifting of the contents that would allow short circuits and without release of package contents;
No more than 30 kg (66 pounds).
IATA PI 967 Section II requires the lithium battery handling label if more than 4 cells or 2 batteries are contained in the package.

“Medium” and “Large” lithium batteries and cells must:

Pass the design type tests in the UN Manual of Tests and Criteria.
Be packaged in UN Specification combination packagings.
Marked and labeled in accordance with the HMR as Class 9.
Accompanied by a hazardous materials shipping paper prepared in accordance with the HMR describing the batteries. When transported by aircraft: accompanied by a shipping paper, emergency response information, notification of pilot-in-command, and must meet general packaging requirements and the requirements in § 173.27.

As provided by § 173.185(a)(4), each lithium battery must be packed in an inner packaging in such a manner as to prevent short circuits, including movement which could lead to short circuits. The inner packaging must be packed within a suitable outer packaging, such as a UN 4G fiberboard box, that conforms to the requirements of the Packing Group II performance level.

The IATA Dangerous Goods Regulations require certain packages containing small lithium cells or batteries to bear a “lithium battery” handling label. Per § 172.102(c), Special Provision A100, the outside of each package containing primary (non-rechargeable) lithium batteries or cells must be marked “PRIMARY LITHIUM BATTERIES—FORBIDDEN FOR TRANSPORT ABOARD PASSENGER AIRCRAFT” or “LITHIUM METAL BATTERIES—FORBIDDEN FOR TRANSPORT ABOARD PASSENGER AIRCRAFT” in letters at least 12 mm high on packages with a gross mass greater than 30 kg; or at least 6 mm high on packages with a gross mass of 30 kg or less. This prohibition applies regardless of whether the battery is packaged in accordance with PI 968 Section I or Section II.

Changes being introduced in the 2013 IATA Dangerous Goods Regulations include the following:

New Section “IA” for lithium cells and batteries that exceed 20 Wh per cell or 100 Wh per battery (PI 965) and lithium metal cells and batteries that exceed 1 g per cell or 2 g per battery (PI 968) - requires a CLASS 9 hazard label and a UN specification package.
New Section “IB” for PI 965 and PI 968 for lithium cells and batteries below the Section IA limits but exceeding the Section II limits - requires a lithium battery handling label in addition to the Class 9 hazard label, but does not require a UN specification package.
A Section IB consignment does not require a Shipper’s Declaration provided there is alternative written documentation or electronic information describing the contents.
New Section II lithium battery quantity limits per package.
A dangerous goods acceptance check is required
A summary Notice to Officer in Command, similar to that permitted for Dry Ice
Alignment of the net quantity limits for lithium batteries packed with and contained in equipment.

Individuals carrying spare batteries, even though they are not regulated under the hazardous materials regulations, must carry them in carry-on baggage, not checked baggage. Loose batteries must be kept away from metal objects, such as coins, keys, or jewelry. Spare batteries should be stored in their original packaging, or tape should be placed across the battery's terminals, or each battery should be placed in its own protective case, plastic bag, or package. Crushing, puncturing, or putting a high degree of pressure on the battery should be prevented.

To learn more about the revised regulations on Lithium Batteries, as well as other regulations that have come into effect in the past few months, sign up for our 2-Day Multimodal Dangerous Goods Training Seminar. For more information, check our website or call 800-631-3098.

About Unz & Co.

Since 1879, Unz & Co. has been helping the international trade industry stay compliant. We supply the industry with compliance forms, software, and publications in addition to dangerous goods labels and placards. Over 50,000 professionals have been trained by Unz & Co. in Export, Import and Dangerous Goods compliance topics. We are the proud recipients of the prestigious E-Star Award from the U. S. Department of Commerce for our continuing contribution to exports. For more info, check our website, www.unzco.com.

Unz & Co. (Division of WTS Corp.) / 333 Cedar Ave., Building B, Suite 2 / Middlesex, NJ 08846