What is the purpose difference between IEC 62133-2 and UN 38.3?

Both texts address lithium-ion batteries but with distinct objectives. IEC 62133-2 is a product safety standard covering the placement on the market of secondary cells and batteries for portable, IT and light industrial applications. UN 38.3 is a transport qualification, derived from the UN Manual of Tests and Criteria, required before any air, sea, road or rail shipment of a lithium cell or battery. A cell compliant with IEC 62133-2 is not necessarily qualified to UN 38.3, and vice versa. The two test files are independent even when run by the same laboratory for cost and lead-time reasons.

What is the current edition of IEC 62133-2?

IEC 62133-2 is part 2 of the IEC 62133 standard, dedicated to secondary lithium cells and batteries. Edition 1.0 was published in 2017, supplemented by Amendment 1 published in 2021. The combined Ed 1.0:2017 + AMD1:2021 forms the current technical baseline in the IEC catalogue. Part 1, IEC 62133-1, covers nickel chemistries (Ni-Cd, Ni-MH) and remains published separately. Editions and amendments must be checked directly on the IEC webstore, since the content may evolve between revisions.

What is the current revision of the UN Manual, Section 38.3?

Section 38.3 appears in the UN Manual of Tests and Criteria, the technical companion publication to the UN Model Regulations on the Transport of Dangerous Goods. Revision 7 was published in 2019 and Revision 8 in 2023 (available on the UNECE website). Each revision may adjust certain test parameters and the contents of the Test Summary. Amendments must be read directly in the latest edition published by UNECE before launching a test campaign.

Which transport modes does UN 38.3 apply to?

UN 38.3 is incorporated by reference in the main multimodal dangerous-goods instruments. For air transport, the IATA DGR (Dangerous Goods Regulations) and the ICAO Technical Instructions both incorporate it. For sea transport, the IMDG Code from IMO refers to it. For road transport in Europe, the ADR agreement incorporates it, with RID covering rail and ADN covering inland waterways. In the United States, 49 CFR (Hazardous Materials Regulations under DOT) embeds the requirement in subpart 173.185. UN 38.3 compliance is therefore a prerequisite for any shipment of lithium cells or batteries, regardless of the routing.

What are the eight T.1 to T.8 tests in Section 38.3?

The programme consists of eight sequential tests. T.1 altitude simulation (low pressure). T.2 thermal test (temperature cycling). T.3 vibration. T.4 mechanical shock. T.5 external short circuit. T.6 impact or crush (cell). T.7 overcharge (battery). T.8 forced discharge (cell). Tests T.1 to T.5 and T.8 apply to cells and batteries as applicable. T.6 applies to cylindrical and prismatic cells. T.7 applies to rechargeable batteries. The exact parameters (pressure, temperature range, vibration profile, test current and voltage) are defined in Section 38.3 and must be read directly in the Manual.

What is the UN 38.3 Test Summary and when did it become mandatory?

The UN 38.3 Test Summary is a standardised document summarising the results of the eight tests, the characteristics of the cell or battery, the identity of the manufacturer, the reference of the full test report and the contact details of the laboratory. Since 1 January 2020, the summary must be made available by the manufacturer or distributor of the cell or battery and accessible to any party in the transport chain. The requirement appears in sub-section 38.3.5 of the Manual. Absence of the summary blocks the shipment.

How do IEC 62133-2, IEC 62619 and IEC 63056 relate to each other?

The three texts cover lithium battery safety for different scopes. IEC 62133-2 (Ed 1.0:2017 + AMD1:2021) targets portable, IT and light industrial applications (small power tools, measurement equipment). IEC 62619 targets industrial applications, including traction batteries, forklift trucks and non-residential stationary batteries. IEC 63056 targets stationary electrical energy storage batteries, complementing IEC 62619 on the electrochemical perimeter. An e-bike or electric-vehicle battery falls under IEC 62619 or specific UN ECE standards (for example UN ECE R100), not IEC 62133-2.

Does UN 38.3 need to be redone after a cell or pack modification?

Sub-section 38.3.3 of the Manual defines the requalification criteria. A change affecting electrolyte chemistry, mass, electrode materials, mechanical design, nominal voltage, capacity or manufacturing method in principle requires a new qualification. A change of cell supplier without specification alignment is also treated as a new reference, with a dedicated UN 38.3 file. The precise thresholds must be verified in the text of the sub-section.

What are the most frequent pitfalls in practice?

Several recurring traps are flagged by testing laboratories. First, shipping prototypes or cell samples without a UN 38.3 report (common in pre-production). Second, certifying the cell to UN 38.3 but not the assembled pack (each cell/battery/pack level needs its own file as applicable). Third, omitting IEC 62133-2 on a product destined for the European market under the LVD or North America under NRTL. Fourth, applying IEC 62133-2 to an e-bike or stationary battery when IEC 62619 or IEC 63056 is the applicable reference. Fifth, ignoring the qualification state of charge (typically 50 percent SOC for transport, see Section 38.3 for the exact values).

IEC 62133 and UN 38.3: Li-ion battery safety and transport

Author Hugues Orgitello Last updated 27 May 2026 ~14 min read

Guide - IEC 62133-2 and UN 38.3

Any product powered by a lithium-ion cell or battery faces two essential examinations before reaching the end user. The first is a product safety standard, IEC 62133-2, which qualifies the cell and the battery for placement on the market in portable, IT and light industrial applications. The second is a transport qualification, Section 38.3 of the UN Manual of Tests and Criteria, required by every multimodal dangerous-goods regime (IATA, IMDG, ADR, 49 CFR) before any shipment of a lithium cell or battery. The two texts coexist: a cell may comply with IEC 62133-2 without having passed UN 38.3, and vice versa. This guide sets out the scope of each text, the test list, the acceptance criteria, the articulation with industrial standards (IEC 62619, IEC 63056) and North American references (UL 1642, UL 2054, UL 62133-2), the UN classification of dangerous goods (UN 3480 through UN 3091), and the pitfalls most often observed in practice.

Why two distinct files

The apparent overlap between the two texts is a common source of confusion, especially during a design team's first battery project. The distinction rests on the regulatory purpose.

IEC 62133-2 is a product safety standard. It defines tests and criteria intended to prevent cell and battery failure under normal use and under single-fault conditions (external short circuit, abnormal charge, crush). Its adoption is voluntary at the IEC level but becomes mandatory by reference in national regimes: EN 62133-2 serves as a harmonised standard in certain scopes under the European Low Voltage Directive; UL 62133-2 is the US version recognised by NRTLs; in Japan, the PSE law refers to a local transposition.

UN 38.3 is a transport qualification for dangerous goods. It stems from the UN Model Regulations on the Transport of Dangerous Goods, with the Manual of Tests and Criteria as the technical companion document. Its purpose is to prevent incidents during transport (fire in an aircraft hold, overpressure in a sea container) by ensuring that the cell or battery withstands the thermal, mechanical and electrical stresses of a logistic route. Without UN 38.3 qualification, no lithium cell or battery can lawfully be loaded onto an aircraft, a vessel or a long-haul truck in international traffic.

The two files are independent, but their schedules typically run in parallel: the same accredited-laboratory campaign can cover both series of tests on a single set of samples, with a typical duration of six to twelve weeks depending on laboratory load and sample count.

IEC 62133-2: scope and structure

IEC 62133-2 is the second part of the IEC 62133 standard. Part 1 (IEC 62133-1) covers nickel chemistries (nickel-cadmium and nickel-metal hydride). Part 2 covers lithium-ion and lithium-polymer chemistries. Both parts share a common architecture: cell-level and battery-level tests, normal conditions and fault conditions, acceptance criteria based on the absence of fire, explosion and leakage.

Reference	Chemistry	Application
IEC 62133-1 Ed 1.0:2017	Ni-Cd, Ni-MH	Portable, IT, light industrial applications
IEC 62133-2 Ed 1.0:2017 + AMD1:2021	Li-ion, Li-polymer	Portable, IT, light industrial applications
IEC 62619	Li-ion	Industrial applications (forklift trucks, industrial traction, non-residential stationary)
IEC 63056	Li-ion	Stationary electrical energy storage (ESS), residential and commercial

The boundary between 62133-2 and 62619 is governed by intended use. A 1 kWh battery integrated in a hand-held power tool typically falls under 62133-2. The same battery inside a forklift truck or an industrial inverter shifts to 62619. For an e-bike battery, European practice generally refers to IEC 62133-2 or EN 50604-1 depending on the LMT class defined in the EU Battery Regulation, with national variations to verify.

The current edition in the IEC catalogue is Edition 1.0 published in 2017, supplemented by Amendment 1 published in 2021. The European transposition EN 62133-2 published by CENELEC takes the IEC content with any regional deviations documented in Annex ZA. For presumption of conformity under the Low Voltage Directive, the exact reference (year, amendment, cessation date) must be checked on the European Commission LVD page.

The IEC 62133-2 tests

The standard distinguishes cell-level tests (clause 7) from battery- or pack-level tests (clause 8). The table below summarises the main tests. The precise numerical values (voltages, currents, durations) are defined in the normative text and must be read directly in the IEC publication.

Test	Level	Objective	Acceptance criterion
External short circuit	Cell + battery	Verify behaviour under a direct short across the terminals	No fire, no explosion
Abnormal charge	Cell	Charge beyond the specified limits	No fire, no explosion
Forced discharge	Cell	Reverse-series discharge (cell driven below zero)	No fire, no explosion
Vibration	Cell + battery	Simulation of handling and transport vibration	No leakage, no fire, mechanical integrity
Mechanical shock	Cell + battery	Calibrated dynamic shock referenced to mass	No leakage, no fire
Free fall (drop)	Battery	Repeated drop from a specified height	No fire, no explosion, post-test function
Thermal abuse	Cell	Sustained exposure to elevated temperature	No fire, no explosion
Crush	Cell	Controlled compression to deformation	No fire, no explosion
Low pressure (altitude)	Cell + battery	Atmospheric simulation at high altitude (decompressed air freight)	No leakage, no explosion

The general acceptance criterion is the triple absence: no fire, no explosion, no leakage (the three no's in laboratory shorthand). Depending on the test, additional criteria apply (residual voltage retention, enclosure integrity, post-test functionality). The test sequence and number of samples are defined by clause 4 of the standard and govern the statistical representativeness of the file.

Tests are carried out by an ISO/IEC 17025 accredited laboratory on the IEC 62133-2 scope. The test report can be issued in IECEE CB format to ease multinational recognition. For the US and Canadian markets, the recognised NRTL bodies additionally issue the commercial mark (UL Listed, ETL, CSA) on the basis of UL 62133-2 or UL 2054.

UN 38.3: structure of Section 38.3

The UN Manual of Tests and Criteria is a technical companion to the UN Model Regulations on the Transport of Dangerous Goods. Section 38.3 dedicates its content to the tests specific to lithium cells and batteries. Revision 7 was published in 2019 and Revision 8 in 2023.

The structure of Section 38.3 comprises several sub-sections:

38.3.1 Purpose,
38.3.2 Definitions and general conditions,
38.3.3 Requalification criteria after modification,
38.3.4 Test procedures (tests T.1 to T.8),
38.3.5 Test Summary - mandatory since 1 January 2020.

The scope covers lithium-metal cells (non-rechargeable) and lithium-ion cells and batteries (rechargeable), together with assemblies in which those cells are integrated, up to the finished-product level if the battery is non-removable.

The eight tests T.1 to T.8

The tests are ordered from least to most severe and run as a series on the same samples up to T.5 (so-called series sequence), then T.6 to T.8 on separate samples. The state of charge of the samples at the start of the sequence is specified by Section 38.3 (typically 50 percent SOC for transport, the exact value to be verified in the current text). The table below summarises the objectives and acceptance criteria.

Test	Designation	Level	Objective	Acceptance criterion
T.1	Altitude simulation	Cell + battery	Exposure to low pressure (simulation of decompressed air freight)	No leakage, no fire, no excessive voltage drop
T.2	Thermal test	Cell + battery	Cycling at high and low temperature	No leakage, no fire, stable mass
T.3	Vibration	Cell + battery	Calibrated vibration profile, frequency sweep	No leakage, no fire
T.4	Mechanical shock	Cell + battery	Calibrated dynamic shock	No leakage, no fire
T.5	External short circuit	Cell + battery	Direct short across the terminals at elevated temperature	No fire, no explosion
T.6	Impact / crush	Cell (cylindrical and prismatic)	Cylindrical bar impact or compression	No fire, no explosion
T.7	Overcharge	Rechargeable battery	Charge beyond the specified limits	No fire, no explosion
T.8	Forced discharge	Cell	Reverse-series discharge	No fire, no explosion

The exact numerical values (altitude pressure, temperature range, vibration profile, test current and voltage, impact height, overcharge current) are defined in Section 38.3 and must be read directly in the latest revision published by UNECE. Secondary doctrinal sources (industry forums, laboratory fact sheets) are useful for preparation but do not substitute for the source text.

T.6 distinguishes two modes (impact and crush) according to cell geometry. Cylindrical and prismatic cells are subjected to impact. Pouch cells are subjected to crush. The mode selection is governed by the application clause.

UN classification and UN codes

The Model Regulations on the Transport of Dangerous Goods classify lithium cells and batteries in class 9 (miscellaneous dangerous substances). Four UN numbers cover the entire perimeter according to chemistry and shipment mode.

UN number	Official designation	Chemistry	Shipment mode
UN 3480	Lithium ion batteries (including polymer)	Li-ion	Cell or battery shipped alone
UN 3481	Lithium ion batteries contained in equipment or packed with equipment	Li-ion	Battery integrated in a product or accompanying a product
UN 3090	Lithium metal batteries	Li-metal	Cell or battery shipped alone
UN 3091	Lithium metal batteries contained in equipment or packed with equipment	Li-metal	Battery integrated in a product or accompanying a product

The marking and labelling of the goods at dispatch carry the applicable UN number, the class 9 lithium-battery label (yellow-and-black diamond specific to lithium batteries) and the shipper contact details. The absence of any one of these elements blocks the load by the forwarder.

Several Special Provisions apply depending on the mode and state of charge. For air transport, the IATA DGR lists in particular SP A88 (new cells not yet qualified to UN 38.3, under derogation), A99 (limited-quantity transport), A123 (replacement cells), among others. The exhaustive list and associated conditions are published annually by IATA in the current Dangerous Goods Regulations edition.

The UN 38.3 Test Summary

Since 1 January 2020, sub-section 38.3.5 of the Manual requires the manufacturer or distributor to make available a Test Summary accessible to any party in the transport chain. The document is standardised and must include:

the identity of the cell and battery manufacturer,
the commercial name and model references,
the technical characteristics (rated capacity, voltage, mass, chemistry),
the list of tests T.1 to T.8 carried out,
the reference of the full test report and the identity of the laboratory,
the test date and the version of Section 38.3 used.

Absence of the Test Summary at the time of shipment is grounds for refusal by the forwarder, the handling agent or the control authority. The document must be available electronically at each step of the logistic route. Several jurisdictions require retention of the summary by both the shipper and the consignee for the commercial lifetime of the product. For the general regulatory context of batteries in Europe, see the EU Battery Regulation guide.

Transport matrix: air, sea, road

UN 38.3 requirements are echoed in the main multimodal instruments. The matrix below summarises the applicable references for each mode.

Mode	Instrument	Geographic scope	UN 38.3 reference
Air	IATA DGR + ICAO TI	Worldwide	Full incorporation + Special Provisions A88, A99, A123, etc.
Sea	IMDG Code (IMO)	Worldwide	Full incorporation in class 9 chapter
Road (Europe)	ADR	ADR contracting states	Incorporated via 2.2.9 and 3.3
Rail (Europe)	RID	COTIF contracting states	Aligned with ADR
Inland waterways (Europe)	ADN	ADN contracting states	Aligned with ADR
Road (United States)	49 CFR 173.185	United States	Explicit reference to UN 38.3
Road (Canada)	TDG Regulations	Canada	Explicit reference to UN 38.3
Road (China)	GB 30000 / GB 38031	China	UN 38.3 incorporation + national requirements

Air transport is the most demanding mode in practice. IATA publishes a new edition of the DGR each year, and airlines apply their own additional restrictions (cargo only, lithium-metal batteries forbidden on passenger flights, state of charge capped at 30 percent for certain configurations). Preparing an air shipment implies a case-by-case review at the start of each calendar year.

For sea transport, the IMDG Code aligns its provisions with the UN Manual on a biennial revision cycle. For road transport in Europe, ADR is revised every two years, with a one-year transitional period for coexistence of editions.

IEC 62133-2 articulation with UL in the United States

In the United States, the safety-certification route runs through NRTLs (Nationally Recognized Testing Laboratories) recognised by OSHA. Several standards coexist for lithium cells and batteries.

UL reference	Scope	IEC equivalence
UL 1642	Lithium cells (Li-ion and Li-metal)	Partial overlap with IEC 62133-2 on the cell side
UL 2054	Batteries (cell assemblies), household and commercial	Overlap with IEC 62133-2 on the battery side
UL 62133-2	Li-ion cells and batteries (harmonised IEC transposition)	Direct reference to IEC 62133-2 with US deviations
UL 9540 + UL 9540A	Stationary storage (ESS), safety and thermal-runaway propagation test	Overlap with IEC 63056 and IEC 62619

For a portable or IT product targeting Europe and the United States simultaneously, the pragmatic route combines IEC 62133-2 (Europe, IECEE CB) with UL 62133-2 (United States). UL 1642 remains required by certain operators on the upstream cells, alongside or instead of the others depending on the file architecture. UL 2054 historically covers assemblies and is partially absorbed by UL 62133-2 in new projects.

Certification comes with a manufacturing-site audit (Initial Production Inspection) and periodic follow-up (Follow-Up Service). For the general framework of electrical safety on audio video, IT and communications equipment, see the IEC 62368-1 guide and the general perspective in the CE marking page.

Qualification levels: cell, battery, product

A recurring difficulty in the files is distinguishing the qualification levels. The cell, the battery and the finished product are three potentially distinct objects under both texts.

Level	IEC 62133-2	UN 38.3
Cell	Clause 7 tests (short circuit, abnormal charge, forced discharge, crush, thermal abuse)	Tests T.1 to T.5, T.6, T.8 depending on geometry
Battery (pack)	Clause 8 tests (short circuit, vibration, shock, drop, low pressure)	Tests T.1 to T.5, T.7
Finished product with integrated battery	Reference to 62133-2 in the product file (62368-1, 60601-1, 61010-1, etc.)	UN 3481 or UN 3091 (integrated battery), Test Summary required

The cell can be qualified by the cell manufacturer (Panasonic, Samsung SDI, LG Energy Solution, CATL and others). The assembled battery is qualified by the integrator or the pack subcontractor. The finished product may rely on the two upstream qualifications, without a new UN 38.3 file, provided that the integrated battery has not undergone a specification change since the original qualification.

A prudent rule: contractually require delivery of the UN 38.3 Test Summary and the IEC 62133-2 certificate by the cell or battery supplier, before integration. The absence of these documents downstream blocks the commercialisation of the finished product.

Pitfalls observed in the field

Without claim to exhaustiveness, several recurring traps are flagged in feedback from certification bodies and laboratories.

Shipping prototypes or cell samples without a UN 38.3 report. This trap is particularly frequent during pre-production, when the first samples leave the cell supplier for the design office or the pack subcontractor. The A88 derogation (cells not yet qualified, but in preparation for qualification) allows transport under strict conditions, generally cargo only with a class 9 UN-spec package. The best practice is still to schedule the UN 38.3 qualification of the cell ahead of the sample phase.
Certifying the cell to UN 38.3 but not the assembled battery. A UN 38.3 cell file does not cover the assembled battery if the battery ships as a distinct object. Tests T.1 to T.5 and T.7 must be carried out at pack level when the pack is shipped separately from the finished product. The pack integrator carries the qualification responsibility.
Forgetting IEC 62133-2 on a European or North American product. A product certified to 62368-1 or 60601-1 must also demonstrate compliance with 62133-2 (or the applicable vertical standard) on the battery component. Several technical files omit this reference, leading at best to an improvement notice from the notified body, at worst to a refusal of CE marking.
Confusing cell and battery in the test report. The test report must unambiguously identify the cell reference (manufacturer, model, capacity, nominal voltage) and the battery reference (pack configuration, number of cells in series and parallel, associated BMS). A confusion leads to a non-receivable file for placement on the market.
Applying IEC 62133-2 to an e-bike or stationary battery. The scope of 62133-2 excludes heavy industrial applications. An e-bike battery typically falls under IEC 62619 or EN 50604-1 (for the LMT class in the EU Battery Regulation sense). A stationary storage battery falls under IEC 63056. For a road-homologated electric vehicle, the applicable references are the UN ECE standards (R100).
Ignoring the qualification state of charge (SOC). Section 38.3 specifies a state of charge to be observed for the test sequence (typically 50 percent SOC, exact value to be verified in the current text). A test run at 100 percent SOC or empty does not comply and the report is rejected at review.
Neglecting requalification after modification. A change in electrolyte chemistry, mass, mechanical design, capacity or nominal voltage in principle requires a new UN 38.3 qualification (sub-section 38.3.3). A change of cell supplier without specification alignment is also treated as a new reference.
Underestimating the campaign duration. A combined IEC 62133-2 + UN 38.3 campaign typically lasts six to twelve weeks in an accredited laboratory, with a significant budget (several tens of thousands of euros depending on the cell + battery + product perimeter). This duration must be factored in at the start of the project, failing which the placement-on-market schedule slips by the same amount.