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Shipping Lithium Batteries in 2016: FAQ

Posted on 1/19/2016 by Roger Marks

The rules for shipping lithium-ion and lithium-metal batteries have changed so dramatically and so often in the past few years that US shippers may feel like they’re always one step behind the latest requirements. Every day, Lion Technology’s regulatory experts answer questions from current and former students about a wide range of hazmat, hazardous waste, work safety, and EHS issues. Of the more than 700 hazmat questions Lion’s Finder Service answered in 2015, about one in ten was a question about shipping lithium batteries.

shipping small lithium batteries


Deciding which of the many lithium battery packaging instructions to use for your shipment can be a challenge. Below we’ve posted answers to some of the most frequently asked lithium battery questions from US shippers.

Q: What are the new lithium battery shipping rules for 2016?

A: For a full rundown of the latest new rules for lithium battery shipments, mandatory as of August 7, 2015, click here.

Major changes include a steep reduction in the reliefs allowed for small or medium lithium batteries. In the past, under Special Provision 188.f, US DOT exempted shippers from marking packages that held up to 12 small lithium batteries or 24 small cells. In 2016, all packages of lithium batteries require markings (with one exception, described below).

Q: What are the latest rules for shipping lithium batteries by air?

On January 16, 2016, IATA issued the first Addendum to its 57th Edition Dangerous Goods Regualtions (DGR) for hazmat air shipments. The Addendum makes some significant changes to the 2016 lithium battery air shipping rules, including: 

Effective April 1, 2016, lithium ion cells and batteries must be offered for transport at a state-of-charge (SoC) not exceeding 30% of their rated design capacity.  IATA also added new requirements for Section II lithium batteries: No more than one Section II package may be placed in an overpack. Packages and overpacks of Section II lithium batteries must be offered separately from other cargo. 

In addition, shippers who offer Section II lithium batterires must now comply with IATA's requirements for "restictions on dangerous goods in consolidation" (1.3.3.2.3 and 1.3.3.2.6) and rules for "use of unit load devices" (5.0.1.3).  Section II lithium batteries were previously not subject to those parts of the IATA dangerous goods requirements. 

Q. Do any lithium battery shipments still get relief from marking requirements?

A. Yes. Most shipments of small batteries (less than 100 watt-hours) may be prepared according to less restrictive packing requirements and marked with alternate hazard communications.

To be shipped without hazard markings, a lithium battery shipment must meet all of the following criteria:
  • No more than 2 packages;
  • No more than 2 batteries (or 4 cells) per package;
  • Lithium-ion (rechargeable, or secondary) chemistry; and
  • Lithium batteries contained in equipment.
Q: Is a battery charger considered “equipment”?

The rules for shipping lithium batteries in equipment or with equipment vary from the regulations for lone batteries. Of course, a battery is only useful when charged up. So, does including a “charger” in a package constitute shipping the battery “with equipment”?

A: Typically, the answer is no. A charger is not considered equipment, unless the charger includes internal power retention.

Q: How do I choose the right lithium battery packing instruction?

A: The US DOT’s Hazmat Table at 49 CFR 172.101 now includes SIX Proper Shipping Names for lithium batteries and FOUR identification numbers. The specific requirements for your shipment depend on a number of factors. To select the proper packaging instruction to follow, ask yourself these questions when preparing to ship lithium batteries:
  • What kind of battery?
    • Lithium-metal (primary, non-rechargeable)?
    • Lithium-ion (secondary, rechargeable)?
  • How are the batteries arranged?
    • By themselves?
    • In equipment?
    • With equipment?
  • What mode of transportation will be used?
    • Ground?
    • Air?
    • Vessel?
  • Is the destination domestic or international?
  • How big is each battery?
    • Kilograms or grams of weight?
    • Watt-hours or lithium content of electric power?
  • How many batteries per package?
  • How many packages per shipment?

Once you answer these questions, you’re ready to: 

1. Choose the best shipping description for your lithium battery shipment.

  • UN3480 Lithium ion batteries
  • UN3481 Lithium ion batteries contained in equipment
  • UN3481 Lithium ion batteries packed with equipment
  • UN3090 Lithium metal batteries
  • UN3091 Lithium metal batteries contained in equipment
  • UN3091 Lithium metal batteries packed with equipment
2. Select the applicable code of hazmat regulations to follow

  • 49 CFR
  • IATA/ICAO
  • IMDG Code
3. Select the appropriate packing instructions from the regulations.

4. Comply with all applicable hazard communication requirements.

By understanding the latest rules for lithium battery shipments, you can make informed, on-the-fly decisions about keeping your packages in compliance. The requirements may change constantly, but by staying focused on the latest rules, taking your time, and following a step-by-step method, you can be confident you’re doing everything possible to keep your shipments safe and in compliance.

DOT, IATA, and IMO Lithium Battery Shipper Training

To help lithium battery shippers keep ground, air, and vessel shipments in compliance, the Shipping Lithium Batteries Online Course covers the 2016 DOT, IATA, and IMO regulations through interactive, engaging lessons and exercises. Get up to speed with the new rules and meet your two- or three-year hazmat certification requirement for shipping lithium batteries. Sign up now.

For a live, expert-led update on the latest rules for shipping lithium batteries, join a Lion instructor for the Shipping Lithium Batteries Webinar on February 11, from 1 to 3 p.m. ET.

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