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Lithium battery shipping: IATA DGR, IMDG, ADR, DOT

Guide, lithium battery shipping

Shipping lithium-ion and lithium-metal batteries crosses two distinct regulatory layers. The UN Recommendations on the Transport of Dangerous Goods (UN Model Regulations, 23rd revised edition, 2023) set the harmonised classification, packing and documentation framework. The modal regulations, IATA DGR for air, IMDG Code for sea, ADR for European road, RID for European rail, ADN for inland waterways, and 49 CFR Part 173 for the United States, transpose and operationalise these recommendations with mode-specific packing instructions, labels, segregation and reporting. The transport qualification baseline is UN 38.3, defined in the UN Manual of Tests and Criteria, 8th revised edition (2023), Section 38.3. This guide maps the architecture: UN numbers and packing instructions, watt-hour thresholds, packaging codes, labels and marks, state-of-charge limits, special provisions for damaged or recycling-destined batteries, and the recurring pitfalls flagged by carriers and customs.

Lithium battery shipping is governed by a layered set of texts. The base layer is the UN Model Regulations, published by the UN Economic Commission for Europe (UNECE), which set the international harmonised classification and packing framework. The modal regulations transpose these recommendations into binding text for each mode of transport.

LayerTextScope
Base, classificationUN Model Regulations, 23rd revised edition (2023)Classification, UN numbers, packing groups, base packing rules
Base, transport testingUN Manual of Tests and Criteria, 8th revised edition (2023), Section 38.3Eight transport tests T.1 to T.8 for lithium cells and batteries
AirIATA DGR (Dangerous Goods Regulations) and ICAO Technical InstructionsAir-specific packing instructions PI 965 to PI 970, labels, CAO restrictions
SeaIMDG Code (International Maritime Dangerous Goods), IMOSea-specific provisions, segregation, stowage, SP 188 for small cells
Road, EUADR 2025Road-specific provisions in Europe, SP 188, SP 230, SP 310, SP 636, SP 666, SP 670
Rail, EURID 2025Rail-specific provisions, broadly aligned with ADR
Road, US49 CFR Part 173, Subpart E, Section 173.185US-specific lithium cell and battery rules, exception 173.185(c) for small shipments

The UN Model Regulations are revised on a biennial cycle. The 23rd revised edition entered force as the baseline for modal updates published from 2024 onward. The IATA DGR is reissued annually (the 66th edition applies for 2025). The IMDG Code is reissued biennially (Amendment 42-24 in force from 2024). Verify the current edition before any shipment campaign.

Section 38.3 of the UN Manual of Tests and Criteria defines the eight transport tests applicable to every lithium cell and battery design type before first shipment.

TestSubjectApplies to
T.1 Altitude simulationLow pressure equivalent to 11 600 m altitude, 6 hoursCells and batteries
T.2 Thermal testThermal cycling between hot and cold extremesCells and batteries
T.3 VibrationVibration profile representative of transportCells and batteries
T.4 ShockMechanical shock half-sine pulsesCells and batteries
T.5 External short circuitShort circuit at controlled temperatureCells and batteries
T.6 Impact or crushMechanical impact (small cells) or crush (large cells)Cells
T.7 OverchargeCharge at twice maximum charge current and voltageRechargeable batteries
T.8 Forced dischargeForced discharge through primary cellPrimary cells

The Test Summary defined in sub-section 38.3.5 has been mandatory at handover since 1 January 2020. For the test programme itself, the IEC 62133 product safety standard, and the relationship between the two, see IEC 62133 and UN 38.3.

The UN Model Regulations assign four primary UN numbers to lithium batteries, plus one for battery-powered vehicles, and since the 23rd edition (2023) three new numbers for sodium-ion.

UN numberDesignationClass
UN 3480Lithium-ion batteries (shipped alone)9
UN 3481Lithium-ion batteries packed with equipment or contained in equipment9
UN 3090Lithium-metal batteries (shipped alone)9
UN 3091Lithium-metal batteries packed with or contained in equipment9
UN 3171Battery-powered vehicle (with lithium battery)9
UN 3556Lithium-ion sodium-ion battery (new 2023)9
UN 3557Sodium-ion battery (packed with equipment)9
UN 3558Sodium-ion battery (contained in equipment)9

Lithium-ion (Li-ion) refers to rechargeable secondary cells with intercalation chemistry (LFP, NMC, NCA, LCO, and so on). Lithium-metal refers to primary (non-rechargeable) cells with metallic lithium anode (Li-MnO2, Li-SOCl2 thionyl chloride, and so on). The two families have distinct thresholds: lithium-ion is measured by watt-hour (Wh), lithium-metal by metallic lithium content in grams (g).

The watt-hour rating of a lithium-ion battery determines its packing instruction section. The conversion is mechanical but a frequent source of error.

Wh = V_nominal (V) * C (Ah)
= V_nominal (V) * C (mAh) / 1000

For a battery with 3.6 V nominal voltage and 2 600 mAh capacity:

Wh = 3.6 * 2.600 = 9.36 Wh

Some manufacturer datasheets state only mAh and nominal voltage. The Wh value must be calculated and printed on the battery marking. For a lithium-metal cell, the metallic lithium content in grams is declared by the cell manufacturer, typically computed from anode mass.

The lithium-ion packing instructions (PI 965 and PI 966 and PI 967) divide shipments into three sections (II, IB, IA) based on watt-hour and net quantity per package. The lithium-metal packing instructions (PI 968, PI 969, PI 970) use an equivalent partition based on lithium content in grams.

SectionUN 3480 (Li-ion alone, PI 965)UN 3090 (Li-metal alone, PI 968)Regime
Section IIBattery <= 100 Wh, cell <= 20 Wh, limited net quantity per packageCell <= 1 g Li metal, battery <= 2 g Li metal, limited net quantityReduced documentation, lithium battery mark, handling rules, CAO restriction since 2016 for UN 3480 alone
Section IBBattery > 100 Wh or net quantity above Section II, up to a defined capAbove Section II up to defined capFull Class 9 label, CAO label, UN-spec packaging, DGD
Section IAAbove Section IBAbove Section IBFull Class 9, UN-spec packaging, DGD, fully regulated

The exact net-quantity caps depend on PI and section; consult the current IATA DGR. The principle: smaller shipments and lower watt-hours benefit from a lighter regime, but the lighter regime does not mean no regulation. Even Section II requires marking, packaging integrity, handling notice and Test Summary on demand.

Air transport, IATA DGR packing instructions

Section titled “Air transport, IATA DGR packing instructions”

The IATA Dangerous Goods Regulations are the operational reference for air shipment of dangerous goods. They are derived from the ICAO Technical Instructions but add carrier-side requirements and present the material in working format. Lithium batteries are covered by PI 965 to PI 970.

Packing InstructionUN numberDescriptionAircraft type
PI 965UN 3480Lithium-ion batteries shipped aloneCargo Aircraft Only (CAO) since 2016
PI 966UN 3481Lithium-ion batteries packed with equipmentPassenger or cargo, per section
PI 967UN 3481Lithium-ion batteries contained in equipmentPassenger or cargo, per section
PI 968UN 3090Lithium-metal batteries shipped aloneCargo Aircraft Only (CAO)
PI 969UN 3091Lithium-metal batteries packed with equipmentPassenger or cargo, per section
PI 970UN 3091Lithium-metal batteries contained in equipmentPassenger or cargo, per section

Since 1 April 2016, ICAO and IATA prohibit the carriage of lithium-ion batteries shipped alone (UN 3480) on passenger aircraft. PI 965 shipments must travel CAO, with the CAO label affixed. In parallel, since the same date, the state of charge (SoC) of lithium-ion batteries shipped under UN 3480 must not exceed 30 percent of rated capacity, except under specific State of Origin and State of the Operator approval. The 30 percent SoC cap reduces available energy in the event of thermal runaway in transit. UN 3481 (packed with or contained in equipment) is not subject to the 30 percent SoC cap.

Annex 2.8 of IATA DGR collects State variations applied by national civil aviation authorities (USDOT, EASA, UK CAA, JCAB, CASA, and so on). These variations can be more restrictive than the base text (additional segregation, lower thresholds for certain configurations, declaration formats). The State of Origin (departure), State of the Operator (carrier), States of transit and State of destination variations must all be checked before booking.

The International Maritime Dangerous Goods Code is published by the International Maritime Organization (IMO). Amendment 42-24 entered force from 1 January 2024 (mandatory from 2026 after a transitional period). It uses the same UN numbers as the UN Model Regulations and the air regulations.

SP 188 of the IMDG Code (mirrored in ADR and 49 CFR) exempts small lithium cells and batteries from the bulk of Class 9 requirements when all of the following are met: each lithium-ion cell <= 20 Wh and each battery <= 100 Wh (or lithium-metal cell <= 1 g and battery <= 2 g); package marked with the lithium battery mark; package able to withstand a 1.2 m drop test; net quantity per package within defined limits; outer packaging integrity. SP 188 still requires the Test Summary on demand and the lithium battery mark.

Class 9 lithium batteries are subject to segregation and stowage rules in the IMDG Code. Stowage codes (SW1, SW2 and so on) specify deck position (under deck, on deck), distance from accommodation and from sources of ignition. Segregation tables define separation distances from other dangerous goods classes. Container ships with reefer connections require additional power monitoring where lithium batteries are stowed near temperature-controlled cargo.

ADR (Accord europeen relatif au transport international des marchandises Dangereuses par Route) is the European agreement on the international carriage of dangerous goods by road, applied across UNECE member states. ADR 2025 entered force on 1 January 2025, with a transitional period until 30 June 2025.

Special ProvisionSubject
SP 188Small lithium cells and batteries exemption (mirrors IMDG SP 188)
SP 230Lithium cells and batteries general classification rule
SP 310Lithium cell and battery prototypes, pre-production samples
SP 376Damaged or defective lithium cells and batteries
SP 377Lithium cells and batteries shipped for disposal or recycling
SP 636Used lithium cells and batteries collected from consumers
SP 666Battery-powered vehicles, equipment and machinery
SP 670Lithium cells and batteries installed in damaged vehicles

Documentation and operational requirements

Section titled “Documentation and operational requirements”

Above the SP 188 threshold, full ADR applies: transport document, written instructions (driver tremcards), orange plates on the vehicle, Class 9 placards on the unit load, ADR-certified driver, on-board safety equipment, mandatory safety adviser (DGSA, Dangerous Goods Safety Adviser) at consignor and carrier level. Packaging is UN specification, typically 4G or 4GV, Packing Group II performance.

In the United States, the Hazardous Materials Regulations are codified in 49 CFR (Code of Federal Regulations), administered by the Pipeline and Hazardous Materials Safety Administration (PHMSA), part of the Department of Transportation (DOT). Lithium cells and batteries are covered by Section 173.185.

  • Section 173.185(a): classification, requires UN 38.3 qualification.
  • Section 173.185(b): general packaging requirements, including UN specification packaging for shipments above the small battery exception.
  • Section 173.185(c): small battery exception, analogous to international SP 188, exempts small lithium cells and batteries from most requirements when packaged according to specified conditions.
  • Section 173.185(d): medium lithium batteries, between the small exception and the fully regulated regime.
  • Section 173.185(f): damaged, defective or recalled lithium cells and batteries, with specific packaging and hazcom requirements (analogous to international SP 376).

49 CFR aligns closely with the UN Model Regulations but retains specific US-only provisions (for example the use of the US DOT marking, training requirements under 49 CFR Part 172 Subpart H, and Hazmat Employer training records).

Packaging used for fully regulated lithium battery shipments must carry a UN specification marking demonstrating compliance with the performance tests of Part 6 of the UN Model Regulations.

CodeDescriptionTypical use
4GFibreboard boxMost common for lithium battery shipments
4GVVariation packaging, fibreboard box with non-standardised inner packagingWhere multiple inner packagings or non-standard inners are used
4DPlywood boxHeavier or larger battery shipments
4DVVariation packaging, plywood with non-standardised inner packagingSimilar to 4GV but in plywood
4H2Solid plastics boxSome specialised applications

A typical mark such as UN 4G/Y20/S/24/F/AB1234 decodes as follows:

  • UN UN symbol
  • 4G packaging code (fibreboard box)
  • Y packing group performance (Y for Packing Group II and III, X for I, Z for III only)
  • 20 maximum gross mass in kg or specific gravity for liquids
  • S indicates solids or inner packagings (alternative: marking with the test pressure for liquids)
  • 24 year of manufacture (2024)
  • F country of authorisation (France in this example, GB for United Kingdom, USA for United States and so on)
  • AB1234 manufacturer and approval authority identifier

The packaging certification (design type approval) is delivered by an accredited body and typically valid up to 5 years per design, subject to national rules. Re-use of UN-spec packaging is conditional on integrity verification and traceability.

Lithium battery shipments require specific marks and labels depending on the regime (Section II exempted, Section IB or IA fully regulated, SP 376 damaged or defective).

The Class 9 lithium battery hazard label, introduced in 2016 and mandatory since 1 January 2017, is a white square set on point with seven black vertical stripes in the upper half and a battery icon in the lower half, plus the figure 9 in the bottom corner. It replaces the former lithium battery handling label for fully regulated shipments. Minimum dimensions are 100 mm by 100 mm.

The lithium battery mark (handling label since 2019) is a rectangular mark with the lithium battery symbol, the UN number(s) covered and a contact telephone number. It applies to Section II shipments and certain SP 188 configurations. Minimum dimensions are 100 mm by 100 mm (reducible to 100 mm by 70 mm where the package is too small).

The Cargo Aircraft Only (CAO) label is a black-and-orange rectangular mark with a passenger aircraft symbol crossed out and the words Cargo Aircraft Only. It is required on UN 3480 alone (PI 965) and UN 3090 alone (PI 968) shipments, irrespective of section. Minimum dimensions are 110 mm by 120 mm.

InformationWhere
UN number (UN 3480, UN 3481, UN 3090, UN 3091)Adjacent to the proper shipping name
Proper shipping name (Lithium ion batteries, Lithium metal batteries, etc.)Adjacent to the UN number
Watt-hour rating (Li-ion) or lithium content in grams (Li-metal)On the battery and on the package marking
Class 9 hazard label or lithium battery markPer regime
Cargo Aircraft Only labelUN 3480 and UN 3090 air shipments
Sender and consignee detailsPer modal regulation
Net or gross quantityPer modal regulation

Damaged, defective and recycling-destined batteries

Section titled “Damaged, defective and recycling-destined batteries”

Lithium cells or batteries identified as damaged or defective and liable to react dangerously during transport (thermal runaway risk, swelling, electrolyte leakage, fire-damaged housing, voltage out of design range) cannot be shipped under ordinary packing instructions.

Special Provision SP 376 of the UN Model Regulations defines the transport conditions for damaged or defective lithium cells and batteries. It requires:

  • specific reinforced packaging, often inner cushioning and fire-retardant material,
  • individual cell isolation where applicable,
  • ground transport only in most cases (air carriage generally forbidden),
  • explicit marking Damaged or defective lithium-ion batteries or Damaged or defective lithium metal batteries,
  • specific entry in the transport document.

Severely damaged batteries (with thermal runaway in progress, fire-affected, smoking) cannot be shipped under SP 376 either, and require specialist intervention.

Special Provision SP 377 covers lithium cells and batteries shipped for disposal or recycling, in defined packaging. Used consumer batteries collected for recycling under EU producer responsibility schemes (for example through the WEEE / DEEE system in France) typically move under SP 377 with consolidated packaging, on dedicated routes.

The categorisation between SP 376 (damaged or defective, requires reinforced packaging) and SP 377 (recycling, normal end-of-life) is critical: shipping a damaged battery under SP 377 normal-recycling conditions, or under PI 967 or PI 970 ordinary packing, is illegal and creates significant liability in case of in-transit incident.

Lithium battery shipments require a layered set of documents, each independent of the others.

DocumentSourceModeMandatory since
UN 38.3 Test SummaryCell or battery manufacturerAll modes1 January 2020
Safety Data Sheet (SDS)Cell or battery manufacturer, GHS-compliantAll modesContinuous, per chemical regulation
Dangerous Goods Declaration (DGD)Shipper, signed by trained DG specialistAir (mandatory for fully regulated), sea (mandatory IMDG), road (mandatory ADR full)Per modal regulation
Air waybill (AWB)Carrier, with dangerous goods entriesAirContinuous
Bill of LadingCarrier, with dangerous goods entriesSeaContinuous
CMR transport documentConsignor and carrier, ADR-compliantRoad EUContinuous
Packing certificateShipper or packing serviceSea (mandatory IMDG), road (recommended)Continuous

The DG specialist (DGR-certified for air, IMDG-trained for sea, ADR-trained for road) is responsible for documentation accuracy. DGR certification for air is renewed every 24 months. IMDG and ADR training is renewed at intervals defined by the respective regulations.

Connection with the broader risk framework

Section titled “Connection with the broader risk framework”

Lithium battery shipping risk is part of the product risk file. The hazard, frequency and severity assessment, treatment and residual risk justification logic follow the risk management ISO 14971 and IEC 31010 framework. For products placed on the EU market, lithium battery design also intersects EU Battery Regulation 2023/1542 on the substantive side (carbon footprint, removable battery, due diligence), and conflict minerals reporting for cobalt and lithium supply traceability.

Step-by-step shipping procedure for a lithium battery shipment

Section titled “Step-by-step shipping procedure for a lithium battery shipment”

The typical sequence for a manufacturer or logistics team preparing a first international shipment.

  1. Identify the UN number for the configuration (UN 3480 alone, UN 3481 packed with or contained in equipment, UN 3090 lithium-metal alone, UN 3091 lithium-metal packed with or contained in).
  2. Compute the watt-hour rating for each lithium-ion battery (Wh equals V nominal multiplied by Ah), or lithium content in grams for lithium-metal. Print on the battery marking.
  3. Determine the applicable section in the relevant packing instruction (Section II, IB or IA for IATA DGR; equivalent partitions for IMDG, ADR, 49 CFR).
  4. Verify UN 38.3 qualification for the cell, battery and assembled pack as applicable. Obtain the Test Summary from the manufacturer.
  5. Confirm state of charge for UN 3480 alone air shipments at 30 percent SoC or below, verified in QC.
  6. Select UN specification packaging of the appropriate code (typically 4G or 4GV), within design type validity period.
  7. Apply marks and labels as required by the regime: Class 9 hazard label, lithium battery mark, CAO label for air, UN number, proper shipping name, watt-hour rating.
  8. Prepare documentation: Dangerous Goods Declaration signed by trained DG specialist, transport document, Test Summary, SDS, packing certificate.
  9. Book with a carrier authorised for Class 9 dangerous goods for the chosen mode. Verify State of Origin, State of the Operator and State of Destination variations for air.
  10. Maintain a shipping log linking each consignment to the UN 38.3 dossier, the packaging certificate, the SDS revision, and the DG specialist signature. For damaged or returned batteries, switch to SP 376 packaging and documentation, never reuse the ordinary PI for forward shipment.

For cross-cutting orders of magnitude per phase, see certification timeline.

PitfallConsequence
UN 38.3 Test Summary missing at handoverShipment blocked by carrier or customs, regardless of mode
State of charge above 30 percent on UN 3480 air shipmentRefusal by air carrier, return shipment, potential investigation by State of Origin authority
CAO label missing on PI 965 air shipmentRefusal at acceptance, refile required
Treating Section II as no regulationLithium battery mark missing, Test Summary not provided, handling instructions not communicated, surveillance block
UN packaging certificate expired or out of design validityPackage non-compliant, shipment blocked or refused
DGR staff certification lapsed (air)DGD signed by uncertified personnel, shipment rejected by carrier
Watt-hour calculation error, mAh stated instead of WhWrong section assignment, wrong packing instruction, customs detention
SP 188 documentation missing for sea (IMDG) small Li-ionShipment refused at port, demurrage charges
Damaged or returned battery shipped under PI 967 or PI 970Illegal under SP 376, severe liability in case of in-transit thermal runaway, criminal exposure
Confusing lithium-ion (Wh threshold) and lithium-metal (gram threshold)Wrong UN number, wrong PI, customs and carrier escalation
Sodium-ion battery shipped as lithium under UN 3480Wrong UN number (UN 3556 / 3557 / 3558 since 2023), documentation chain invalid
Re-using UN packaging without integrity verificationDrop-test performance not validated, packaging classed as non-spec

Sources & references

  1. UN Recommendations on the Transport of Dangerous Goods, Model Regulations, 23rd revised edition (2023) , UNECE unece.org/transport/dangerous-goods/un-model-regulations-rev-23
  2. UN Manual of Tests and Criteria, 8th revised edition (2023), Section 38.3 , UNECE unece.org/transport/dangerous-goods/un-manual-tests-and-criteria-rev-8
  3. IATA Dangerous Goods Regulations (DGR) , IATA www.iata.org/en/publications/dgr/
  4. IATA Lithium Battery Shipping Regulations , IATA www.iata.org/en/programs/cargo/dgr/lithium-batteries/
  5. IMDG Code (International Maritime Dangerous Goods Code), IMO , IMO www.imo.org/en/OurWork/Safety/Pages/DangerousGoods-default.aspx
  6. ADR 2025, European Agreement concerning the International Carriage of Dangerous Goods by Road , UNECE unece.org/transport/dangerous-goods/adr-2025-files
  7. 49 CFR Part 173, Hazardous Materials Regulations, Subpart E, Section 173.185, Lithium cells and batteries , US DOT / PHMSA www.ecfr.gov/current/title-49/subtitle-B/chapter-I/subchapter-C/part-173/subpart-E/section-173.185