Lithium Batteries & Hazmat: UN38.3, SDS/MSDS, and Packaging Rules for Shipping from China

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Who Should Read This

  • Exporters of electronics, e‑bikes, power tools, medical or consumer devices containing lithium cells/batteries.
  • Importers and ops teams booking air/sea freight from China.

Know Your Battery Type and UN Number

Lithium‑ion (rechargeable)

  • UN3480 (batteries), UN3481 (contained in/packed with equipment).

Lithium‑metal (non‑rechargeable)

  • UN3090 (batteries), UN3091 (contained in/packed with equipment).
UN No.Typical ContentWith Equipment?ClassCommon Notes
UN3480Li‑ionNo9Air: cargo aircraft only, SoC limits apply
UN3481Li‑ionYes9Often fewer restrictions vs standalone
UN3090Li‑metalNo9Air: cargo aircraft only; strict quantity limits
UN3091Li‑metalYes9Check per‑package limits and docs

Compliance Baseline (Before You Book)

UN38.3 Test Summary

  • Manufacturer/supplier must provide a UN38.3 test summary for each cell/battery design; carriers or authorities may request it.

SDS/MSDS

  • Provide a current Safety Data Sheet (SDS, formerly MSDS) with classification, emergency info, and handling.

Correct Classification

  • Confirm Wh rating (Li‑ion) or lithium content (Li‑metal), packaging instruction, and whether cells/batteries are contained in or packed with equipment.

Air Transport (IATA DGR — Check Latest Edition)

Packaging Instructions (PI)

  • PI 965–970 apply to most lithium shipments (specific PI depends on type and configuration).

Key Constraints (High‑Level)

  • State of charge (SoC) limits for standalone Li‑ion by air (commonly ≤30%).
  • Quantity/net weight limits per package; some must go Cargo Aircraft Only (CAO).
  • Section II for UN3480 is no longer permitted; shipments must follow Section IA/IB as applicable.

Documentation & Labels

  • Shipper’s Declaration for Dangerous Goods (where required), AWB remarks, lithium battery mark, Class 9 label, CAO label if applicable.

Ocean Transport (IMDG Code — Check Latest Amendment)

Special Provisions

  • SP 188 and others may exempt certain small cells/batteries from some requirements if conditions are met.

Stowage & Segregation

  • Follow IMDG packing, marking, and stowage rules; damaged/defective batteries have additional restrictions.

Documentation

  • Dangerous goods declaration, stowage plan info, SDS, and correct UN numbers on shipping papers.

Packing, Marking, Labeling — Practical Tips

Packaging

  • Use robust inner packaging; prevent short circuits; strong outer packaging; consider UN performance‑tested boxes where required.

Marking & Labeling

  • Lithium battery mark with telephone number; Class 9 diamond label; CAO label as required; orientation arrows for liquids/equipment with liquids.

Overpacks & Mixed Contents

  • Ensure markings remain visible; if not, repeat on the overpack; do not mix incompatible DG.

Step‑by‑Step Workflow (China Origin)

  1. Collect UN38.3 test summary + SDS; confirm UN number/PI.
  2. Verify SoC and per‑package quantities.
  3. Prepare packing per IATA/IMDG; apply labels/marks.
  4. Book with a DG‑approved forwarder/airline/vessel; declare DG accurately.
  5. Provide all docs: SDS, test summary, shipper’s DG declaration (if required), invoice/packing list.
  6. Origin DG inspection/screening; resolve any holds before uplift.
  7. Track and prepare destination customs and any authority notifications.

Special Cases

E‑bikes, Scooters, E‑mopeds

  • Usually Li‑ion batteries of large Wh; many lanes require CAO or sea; check PI and carrier policy.

Power Banks and Spare Batteries

  • Often treated as batteries, not equipment; stricter limits than “contained in equipment”.

Damaged/Defective Batteries and Recalls

  • Typically forbidden by air; severe restrictions at sea; consult carrier and DG advisor.

Common Mistakes (Avoid These)

  • Shipping without UN38.3 test summary or outdated SDS.
  • Misdeclaring “with equipment” when batteries are actually shipped separately.
  • Overfilling per‑package limits or exceeding SoC requirements.
  • Using non‑DG forwarders for DG cargo.

FAQs

Do I need UN38.3 for every shipment?

You need a test summary per cell/battery design; keep it on file and share when requested.

Can I ship standalone Li‑ion by passenger aircraft?

Generally no; many must be cargo aircraft only with SoC ≤30% and strict quantity limits.

Is Section II still allowed?

Not for UN3480 (standalone Li‑ion). Other configurations may still have Section II options—check the latest IATA DGR.

What if my battery is over 100 Wh?

Usually stricter limits, more documentation, and CAO in many cases—confirm with current PI and carrier policy.

Sources & Guidance