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All you need to know if specifying or transporting Rechargeable Lithium ion Batteries

The Transportation of Lithium ion Batteries

This webpage has been written to help customers understand the regulations surrounding the transportation of Lithium ion batteries. It is also available as a pdf download.

What is important to know?

These are top five things you need to know and which are covered in detail by this Accutronics webpage:

1. The transport of Lithium ion batteries is subject to international regulation which can differ if the batteries are transported by air, sea or road. There are a range of fines for companies (including OEMs) who do not comply with these regulations.

2. All Lithium ion batteries must undergo mechanical and electrical tests which simulate the effects of transportation.

3. Lithium ion batteries which have been transportation tested but have a possible stored energy of >100Wh must be transported as class 9 dangerous goods which impose strict packaging, labelling and documentation requirements on those shipping the product. Special training and certification is required for those wishing to ship class 9 dangerous goods.

4. Lithium ion batteries which have been transportation tested and have a possible stored energy of <100Wh are excepted from dangerous goods regulations but still have special packaging, labelling and document requirements.

5. There are restrictions on the number and size of Lithium ion batteries which can be taken on board aircraft (as carry on or checked in luggage).

Accutronics recommend that where possible, OEMs specify Lithium Ion batteries at <100Wh so shipping to end customers is simplified and less costly. For those applications which require a Lithium ion battery>100Wh then we advise that customers read the sections of this document which deal with the shipping of Lithium ion batteries as Dangerous Goods so the implications are fully understood. Alternatively discuss with Accutronics the option of using multiple <100Wh in a modular system.

Scope – IMPORTANT, PLEASE READ CAREFULLY

As a developer and manufacturer of Lithium ion rechargeable batteries, this document has been written without reference to Lithium Ion (rechargeable) cells or lithium (primary) cells or batteries. This has been done for the purposes of clarity.

This document has been written based on our understanding of the latest regulations. It should be noted that regulations are subject to constant review in the light of new technical developments and changing requirements of industry and transportation. States and operators may impose further restrictions to the regulations at any time.

International Regulations

Q: What international transportation regulations are currently in effect for rechargeable Lithium ion batteries?
International transportation regulations require battery manufacturers or companies that ship equipment packed with or containing these batteries to meet UN testing, marking, packaging, labelling and shipping paper specifications.
The transport of dangerous goods is regulated in order to prevent, as far as possible, accidents involving people or property, damage to the environment, to the means of transport employed or to other goods being transported. Each mode of transport, air, sea and road has its own regulations:

• Safe transport of dangerous goods by air (ICAO/IATA)
• Dangerous goods by sea (IMDG)
• Dangerous goods by road within Europe (ADR)

Although separate, they are now largely harmonized with the Model Regulations, published by United Nations Economic and Social Council's Committee of Experts on the Transport of Dangerous Goods.
Battery manufacturers have a duty of care to make their OEM customers aware of the shipping regulations and OEM customers have a duty of care on their end customers.
Dangerous goods in transport are identified both by a proper shipping name and a UN number. The Technical Instructions and the Dangerous Goods Regulations contain the same list of dangerous goods; this shows all the proper shipping names with their UN numbers. See table below:

Proper Shipping Name	UN Number
Lithium ion batteries	UN3480
Lithium ion batteries contained in equipment	UN3481
Lithium ion batteries packed with equipment

Based on Watt-hour rating (for Lithium ion batteries), the following international shipping regulations apply: 

Lithium ion & Polymer Battery Max Watt-hours	Shipping Classification / Testing	Special Packaging / Markings
100Wh Maximum(1)	Excepted / T1-T8(1)	Yes(1)
>100Wh(2)	Class 9 / T1-T8(2)	Yes(2)

(1) Batteries must pass UN38.3 T1-T8 tests. Batteries that are <100Wh and pass UN tests are excepted from regulation. Correct packaging, labelling and paperwork requirements apply. Read the section of this document entitled “Shipping of Excepted Lithium ion batteries”

(2) Batteries must pass UN38.3 T1-T8 Tests and be shipped as Class 9 Dangerous Goods. Requires Class 9 markings, label, special packaging and shipping papers. Read the section of this document entitled “Shipping of Lithium ion Batteries as Class 9 Dangerous Goods”

 

Q: How are Watt-hours (Wh) calculated for Lithium ion batteries?

Simply multiply the rated capacity (in Ah) by the nominal voltage (in V) to give a Wh rating. Note that all batteries must have the Wh rating clearly shown on the battery.

 

Transportation Testing

Q: What are the UN "T" tests required by the UN regulator scheme?

The UN Manual of Tests and Criteria, Fifth Revised Edition (ST/SG/AC.10/11/Rev.5 section 38.3 entitled “Lithium Metal and Lithium ion Batteries”), contain the UN T1-T8 Tests that are paraphrased below. Refer to the complete UN document for a full description of the tests and the purpose, procedure and requirement of each test. These tests must be conducted for each battery of a given design and must be completed prior to shipment. Lithium ion batteries which differ from a tested type by a change that would materially affect the test results shall be considered a new type and must be retested.

Test T1: Altitude Simulation. Simulates air transport under low pressure conditions. Store at 11.6kPa or less for 6 hours at +20°C.

Test T2: Thermal Test. Assesses cell and battery seal integrity and internal electrical connections using thermal cycling to simulate rapid and extreme temperature changes. Perform 10 cycles between +75°C and -40°C, 6 hours per cycle with no more than 30 minutes between cycles of the battery.

Test T3: Vibration. Simulates vibration during transport. Sinusoidal waveform with a logarithmic sweep between 7Hz and 200Hz and back to 7Hz in 15 minutes. This cycle must be repeated 12 times for a total of 3 hours for each of three mutually perpendicular mounting positions of the battery.

Test T4: Shock. Simulates possible impacts during transport. Half-sine shock of peak acceleration of 150g and pulse duration of 6 milliseconds. Each battery shall be subjected to three shocks in the positive direction and 3 shocks in the negative direction of three mutually perpendicular mounting positions for a total of 18 shocks. The test differs for large cells or batteries, refer to the Manual of Tests and Criteria.

Test T5: External Short Circuit. Simulates an external short circuit. After stabilising at +55°C, apply an external resistance of less than 0.1 Ohm for 1 hour and then observe for 6 hours.

Test 6: Impact. Not applicable for batteries (only for cells).

Test 7: Overcharge. Evaluates the ability of a rechargeable battery to withstand overcharge, Charge at twice the manufacturer's recommended maximum continuous charge current for 25 hours, and then observe for 7 days.

Test 8: Forced Discharge. Not applicable for batteries (only for cells)

 

Q: How many rechargeable batteries are required for testing and which tests are performed for each?

Sixteen batteries are required. Eight are used for T1 to T5 (four small batteries at first cycle, in fully charged states plus four small batteries after 50 cycles ending in fully charged states) and eight are required for T7 (four small batteries at first cycle, in fully charged states plus four small batteries after 50 cycles ending in fully charged states). T6 and T8 are not conducted as they apply only to cells (not to batteries).

 

Q: Where can I obtain a copy of the complete UN testing requirements?

You can obtain a copy of the test requirements portion of the UN Recommendations on the Transport of Dangerous Goods, Manual of tests and Criteria (ISBN 978-92-1-139135-0) is available through the UN website.

 

Q: Do batteries that are manufactured by battery assembly companies have to be tested, even if they are assembled using cells that have already been tested by the cell manufacturer?

Yes, all OEM customers, distributors and battery assemblers are responsible for obtaining a test certificate for each battery type that they manufacture. The responsibility usually falls on the battery assembler who will test the battery (or have it tested by a third party test house) as part of the approval/certification process. It is important to remember that the battery must be retested if (i) There is a change in Watt-hours of more than 20% or an increase in voltage of more than 20% or (ii) There is a change which would materially affect the test results. Battery assemblers must undertake a due diligence process if they make a design change without repeating the UN T1-T8 tests.

 

Q: If my batteries must be tested prior to shipping, how am I supposed to ship these products to a testing facility without violating the hazardous materials regulations?

Air: The International dangerous goods regulations contain provisions that authorise shipments by air of "prototype or low production" cells and batteries. These provisions are found in Special Provision A88 in the ICAO Technical Instructions and IATA Dangerous Goods Regulations. However, shippers that want to offer prototype batteries by air transport must first secure a "competent authority approval" from the appropriate transportation agency in the country of origin. 

Sea: Shippers of prototype batteries also have the option of shipping their products internationally by cargo vessel. No approval is required for such shipments but there are very stringent packaging requirements. The provision that applies to such shipments is Special Provision 310 in the IMDG Code. 

Road: The testing requirements in sub-section 38.3 of the Manual of Tests and Criteria do not apply to production runs consisting of not more than 100 cells and batteries, or to pre-production prototypes of cells and batteries when these prototypes are carried for testing. The provision that applies to such shipments is Special Provision 310 in the European Agreement ADR Volume II.

 

Shipping of Excepted Lithium Ion Batteries

Q: What are the marking, packaging, and shipping paper requirements for excepted batteries?

Lithium ion batteries may be offered for transport if they meet the following (i) For Lithium ion batteries, the Watt-hour rating is not more than 100Wh. (ii) The Watt hour rating is marked on the outside of the battery case (except for those batteries manufactured prior to January 2009, (iii) Each battery is of the type proven to meet the requirements of each test in the UN Manual of Tests and Criteria, Part III, section 38.3. (currently the 5th revised edition).

Batteries must be packed in strong outer packaging. The maximum gross weight of the packaged batteries is 10Kg (for Passenger or Cargo aircraft). Batteries must be packed in inner packagings that completely enclose the battery. Batteries must be protected as to prevent short circuits. This includes protection against contact with conductive materials within the same packaging that could lead to a short circuit. Each package must be capable of withstanding a 1.2m drop test in any orientation without (a) damage to batteries contained therein; (b) shifting of the contents so as to allow battery to battery contact or (c) release of contents.

Each consignment must be accompanied with a document such as an air waybill or packing slip with an indication that:(i) the package contains Lithium ion batteries (ii) the package must be handled with care and that a flammability hazard exists if the package is damaged (iii) special procedures should be followed in the event the package is damaged, to include inspection and repacking if necessary; and (iv) a telephone number for additional information. The words “Lithium ion batteries”, “not restricted” and “PI965” must be placed on the airway bill, when an airway bill is used.

Each package must be labelled with a Lithium Ion battery handling label (see example in figure 1). The minimum dimensions of this label for air shipments is 120mm x 110mm. Smaller labels can be used for shipments by motor vehicle, cargo vessel or rail. Colour required for international air shipments is black text/graphics on a white background and red hatching around perimeter. Black hatching can be used for shipments by motor vehicle, cargo vessel and rail.

 

Figure1

Any person preparing or offering batteries for transport must receive adequate instruction on these requirements commensurate with their responsibilities.

 

Shipping of Lithium Ion Batteries as Class 9 Dangerous Goods

What does Class 9 and Packing Group mean?

In order that the potential hazards in transport are identified, dangerous goods are divided into nine categories by classes. Class 9 is one of the nine classes of hazardous materials (dangerous goods) defined by the U.S. HMR and other transportation regulations. Class 9 defines the specification packaging, markings, labelling, and shipping paper requirements for “Miscellaneous" hazardous materials which include LITHIUM ION BATTERIES among other materials.

Which Lithium Ion Batteries have to be shipped as class 9 Dangerous Goods?

(i) Lithium ion batteries which have not been transportation tested.

(ii) Lithium ion batteries which have been transportation tested but are capable of storing >100Wh.

Q: What are the marking, packaging, labelling and shipping documents requirements for Lithium ion batteries shipped as Class 9 Dangerous Goods?

When shipping internationally under ‘Safe Transport of Dangerous Goods by Air’ (ICAO/IATA), ‘Dangerous Goods by Sea’ (IMDG) or ‘Dangerous Goods by Road to Europe’ (ADR), the following apply:

Marking on Packages:

Packages are always marked to indicate what they contain: 

• Proper shipping name
• UN number
• Shippers name and address
• Consignee name and address
• UN packaging specification

Packaging:

Dangerous goods must be packed for transport according to a specific Packing Instruction. Packaging must be of good quality, be compatible with their contents and be able to withstand the normal conditions of transport. They must meet general packing requirements and, in addition, most of them are required to meet prescribed specifications and performance tests for the design type of the packaging. These types of packaging display a packaging specification marking.

Labelling:

Packages are labelled to indicate the hazard(s) the contents present in transport. In addition, other labels may specify handling conditions. Each package must be labelled with a Lithium ion battery handling label (see example in figure 1). The minimum dimension of this label for air shipments is 120mm x 110mm.

Shipping documents:

Dangerous goods must be accompanied by a Dangerous Goods Transport Document (Shipper’s Declaration for Dangerous Goods). The document is prepared by the shipper; it gives the operator details about the dangerous goods and declares they comply with all applicable requirements. The information on the Shipper’s Declaration includes: 

• Proper shipping name
• Class
• UN number
• Packing group
• Net quantity
• Type of packaging
• Number of packages
• Telephone number
• Signature of shipper

 Note if shipping by Air the following additional information is required: 

• Air waybill number
• Proper certification (I declare that all of the applicable air transport requirements have been met).
• Whether for passenger and cargo aircraft  or cargo aircraft only
• Airport of departure
• Airport of destination
• Shipment type: non-radioactive or radioactive
• Place, date of signing of shippers certification

Any person preparing or offering batteries for transport must receive adequate instruction on these requirements commensurate with their responsibilities.

 

Q: How do the regulations apply to class 9 Lithium ion batteries packed with or contained in equipment?

If batteries must be shipped as Class 9 hazardous materials, equipment that is packed with or containing these batteries must also be shipped as class 9 hazardous materials. UN number 3481 has exists for this purpose with the following correct shipping names: “Lithium ion batteries contained in equipment” or “Lithium ion batteries packed with equipment”.

 

Q: Are there any training requirements for employees of companies that ship Lithium ion batteries?

Yes, depending which mode of transport you use, the following certification is required, which are valid for two years.

Safe transport of dangerous goods by air (ICAO/IATA)

For over 20 years all personnel involved in the transport of dangerous goods by air have been required to undergo training. The regulations cover the training of airline staff, handling agents, shippers and packers. The Technical Instructions on the Safe Transport of Dangerous Goods by Air published by the International Civil Aviation Organisation (ICAO) form the basis of the rules. The Dangerous Goods Regulations of the International Air Transport Association (IATA) is the day-to-day operational document. Enforcement of the regulations is vigorous and there are a number of prosecutions each year because consignors of dangerous goods fail to comply with the rules. A recent 'failure to declare' cost the shipper £10,000. This course will teach you everything you need to know about all the regulations and how to comply. It includes an examination in accordance with CAA training guidelines and approval. Successful candidates will receive a certificate with their unique Dangerous Goods by Air registration number.

Dangerous goods by sea (IMDG)

The International Maritime Dangerous Goods (IMDG) Code states that shore based personnel engaged in the transport of dangerous goods by sea must receive training in the contents of the dangerous goods provisions. This course will provide you with practical guidance on how to fulfil the obligations imposed by the new transport regulations. Practical class exercises throughout the course and a final test on the whole Code are included to ensure you have a good grasp of the principles. Attending this course will ensure you understand the complexities of the Code and its relationship with UN recommendations and UK national regulations enabling you to implement the Code in your company.

Dangerous goods by road within Europe (ADR)

The course is essential for everyone involved in the packaging and transporting of dangerous goods by road. It will give you a thorough understanding of ADR. After three intensive days you will understand the variations between ADR, Sea IMDG for transport, and the ICAO technical instructions for air.

 

Q: Are there any fines if shipping regulations are violated?

Yes. Fines are additive and multiple fines may be imposed for a single shipment of batteries that may have a combination of testing, packaging, labelling and other violations. Some examples are shown below:

The Civil Aviation (Offences) Regulations 1997 provide for offences for instant fines and 29 offences for which summary conviction results in a fine. The infringement fees for these offences range from $250 to $2,000 for an individual and $1,500 to $12,000 for a body corporate. The maximum fines resulting from a summary conviction range from $650 to $5,000 for an individual and $3,750 to $30,000 for a body corporate.

The Maritime (Offences) Regulations 1998 provide for offences which on summary conviction carry a maximum fine of $3,000 to $5,000 for individuals and $20,000 to $30,000 for a body corporate. These provisions and penalties apply to ship owners and masters. They also apply to harbourmasters, ‘shippers’ of dangerous goods, manufacturers of packagings, consolidators and packers and port operators.

The Land Transport (Offences and Penalties) Regulations 1999 (as amended) provide for offences against the Land Transport Rule. These offences attract a wide range of instant fines up to $10,000 for a company and $2,000 for an individual. Fines for summary convictions include a maximum $50,000 for a company and $10,000 for an individual.

 

Lithium ion Batteries as ‘Carry-on’ or ‘Checked-in’ Luggage on Aircraft

Q: Are there any provisions in the regulations that enable passengers to carry electronics devices containing Lithium ion batteries or spare batteries onto airplanes in carry-on baggage?

Yes, portable electronic devices (watches, calculating machines, cameras, cellular phones, laptop computers, camcorders, etc.) containing Lithium ion batteries when carried by passengers or crew for personal use can be carried as carry-on baggage. Spare batteries must be individually protected so as to prevent short circuits (by placement in original retail packaging or by otherwise insulating terminals, e.g. by taping over exposed terminals or by placing each battery in a separate plastic bag or protective pouch) and carried in carry-on baggage only. In addition, each installed or spare Lithium ion battery bust not exceed a watt-hour rating of more than 100Wh.

With the approval of the operator, Lithium ion batteries exceeding a watt hour rating of 100Wh but not exceeding 160Wh may be carried as spare batteries in carry-on baggage or in equipment in either checked or carry-on baggage. No more than two individually protected spare batteries per person may be carried.

Q: Are there any provisions in the regulations that allow Lithium ion batteries in checked baggage?

Unless approved by the operator, spare Lithium ion batteries are not allowed in checked baggage.

 

Additional Questions

Q: I need 120x110mm Lithium ion Battery caution labels with the red hatching and with my company telephone number printed on them. Where can I obtain these?

Accutronics can provide these labels to existing Lithium ion battery customers if required. Labels are available to buy in rolls of 500pcs. Contact Accutronics customer services for more details.

 

Q: What if one of our customers or distributors wants to return some Lithium ion batteries to us. Do they need to adhere to all the same rules?

Yes, anyone offering Lithium ion batteries for transport must follow the regulations. Note that Lithium Ion batteries being shipped for recycling or disposal are prohibited from air transport unless approved by the appropriate national authority of the State of Origin and the State of the Operator.

 

Q: I or my customer wants to send batteries which are faulty, does that make any difference?

Yes, Lithium ion batteries, identified by the manufacturer as being defective for safety reasons, or that have been damaged, that have the potential of producing a dangerous evolution of heat, fire or short circuit are forbidden for transport.

 

Q: I have additional questions and need to speak to an expert. Who can I contact?

For specific questions please contact our Dangerous Goods Adviser, Mr David Flaherty:
Telephone +44 (0) 1782 566622 (ext 124) or email david.flaherty@accutronics.co.uk

 

Disclaimer

Important: This document contains information which only relates to secondary (rechargeable) Lithium ion batteries (including Lithium ion polymer). It does NOT cover primary (non rechargeable) Lithium cells or Lithium batteries. Information has been provided based on our understanding International regulations. Domestic regulations for individual counties or states can and does vary. While every attempt has been made to ensure the accuracy of the advice in this document, no claim or guarantee is made by Accutronics Ltd for accuracy, completeness, applicability or compliance to the regulations which are subject to change. Accutronics Ltd shall not be liable for any inclusions, omissions, errors or outdated information. This document does not constitute, and should not be considered legal advice. In all cases we recommend that you fully research the topic and seek appropriate advice from regulatory authorities to ensure your compliance with all applicable regulations.
 

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