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New rules for the transport of lithium batteries

November 20, 2019

Mandatory test report as from January 1, 2020

New rules for the transportation of lithium batteries as of Jan 1, 2020

Demand for lithium batteries/cells continues to grow strongly. Transportation of said items is subject to Legislation on hazardous goods. As more and more lithium batteries/cells from unknown sources are in circulation, legislation on hazardous goods is imposing new demands in terms of documentation: The UN 38.3 report proves that the batteries are generally suitable for transport. If it is not furnished, the carrier may refuse transportation accordingly.

A new requirement according to sub-section 38.3.5 of the UN Manual of Tests and Criteria is that, as of January 1, 2020, passing of the UN Transportation Test must be documented in more detail, and said documentation must be furnished all along the supply chain when transporting lithium batteries. This stipulation refers to all batteries manufactured after June 30, 2003. These requirements apply to manufacturers and distributors of lithium batteries/cells, i.e. also distributors. Exemptions from the UN test only apply to so-called prototypes, or small-lot production runs of a maximum of 100 lithium batteries/cells, which may then be transported in accordance with Special Provision 310 of ADR/IMDG or based on A88 of the IATA regulations.

According to the FBDi, important criteria for trouble-free transportation are correct classification and appropriate preparations for shipping. The requirements to be met also depend on the nominal energy of a lithium-ion battery or the lithium content in the lithium-metal battery. Simplified shipping according to IATA-DGR and ADR is possible with regards to lithium-ion batteries with a rated power of less than 100 Wh, or 20 Wh per cell, and lithium-metal batteries with a lithium content of up to 2 g, or 1 g per cell. Special packing and shipping requirements must be met for damaged lithium batteries or cells: In addition to the required identification for regular shipping, marking of the package as 'damaged/defective lithium-ion batteries/lithium-metal batteries' is mandatory.

The FBDi points out the comprehensive data which the UN test report is required to contain. Detailed information regarding the individual transport modes are contained in the respective regulations: 

  • Road, rail and inland waterways: ADR / RID / ADN 2.2.9.1.7
  • Sea freight: IMDG Code 2.9.4 Lithium batteries
  • Air freight: IATA-DGR 3.9.2.6 Lithium batteries

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