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Transportation Regulation FAQs for Lithium and Lithium Ion Cells and Batteries
This document is intended to provide some general guidance to questions we frequently receive related to
shipment of Lithium and Lithium Ion cel s and batteries, as wel as products being shipped with batteries and
cells, or containing batteries and cells. For more detailed information about your specific situation, please
contact us.

What are the regulations that govern the transport of Lithium and Lithium Ion cel s and batteries?
The governing organization for the transport of Lithium and Lithium Ion cells and batteries (cells and
batteries) varies based on the shipping method and region(s).
Air transport (domestic and international) – Shipments of cells and batteries by air are
governed by the International Civil Aviation Organization (ICAO) and the International Air Transport Association (IATA). ICAO has Technical Instruction for the shipment of Dangerous Goods, and IATA has a corresponding Dangerous Goods Regulations. • Sea transport – Shipments by sea are regulated by the International Maritime Dangerous
Goods (IMDG), which parallel the air transport regulations. • Transportation within the US (vehicle, air and vessel) – Shipments within the United States are
additional y regulated by the US Department of Transportation through the Code of Federal Regulations, CFR 49 (Sections 100-185), through the U.S. Hazardous Materials Regulations (HMR). • Transportation within other countries – Other countries, such as China, have specific
regulations for the shipment of Lithium and Lithium Ion cel s and batteries and should be investigated individually.
What are the current transportation regulations in the U.S.?

Transport of cel s and batteries within the U.S. is regulated through 49 CFR Sections 100-185 of the U.S.
Hazardous Materials Regulations (HMR). Specifically, Section 173.185 and the special provisions in
Section 172.102 apply to Lithium and Lithium Ion cel s and batteries. These sections include
information on packaging for shipping, package weight limits, required testing, and exceptions that
COPYRIGHT 2011 ENERGY ASSURANCE, L.L.C. ALL RIGHTS RESERVED may apply. The U.S. regulations are based on the mass of lithium in the anode of lithium cel and battery, and based on equivalent lithium content for Lithium Ion cells and batteries. The table below outlines the shipping regulations currently in effect for the U.S. 1 – Equivalent Lithium Content (ELC) = 0.3 x rated capacity (Ah) x # of cel s (for packs) 2 – The sizes noted here are based solely on U.S. DoT definitions in 49CFR. These are not the same as ICAO/IATA size definitions, or UN 3. – Packages containing more than 12 batteries or 24 cel s must meet certain packaging, marking and shipping paper requirements. 4 – Must be shipped as Class 9 hazardous materials unless transported by motor vehicle or rail. 5 – Requires Class 9 markings, label, specified packaging and appropriate shipping papers.
Al of these regulations apply not only to cel s and batteries alone, but to end product shipped with
these types of cells and batteries, as well as end products containing these types of cel s and batteries.
Another important note is that, with a very limited set of exceptions, no Lithium or Lithium Ion cells or
batteries may be introduced for transport in any mode without first completing testing in accordance
with the UN Manual of Test and Criteria. Exceptions to this include shipping of prototypes for testing
and waste batteries.
What are the current transport regulations international y?
ICAO Technical Instructions, IATA Dangerous Goods Regulations and the IMDG Code are the
regulations in place to cover international shipments of Lithium and Lithium Ion cells and batteries. All
of these codes require cells and batteries of these types to be tested to show compliance with the UN
Manual of Tests and Criteria. Additionally, as with the U.S. regulations, the rules apply to cells and
batteries shipped alone as wel as those shipped with equipment, or contained in equipment as noted
by the UN shipping numbers and names for the products as noted in the fol owing table.
COPYRIGHT 2011 ENERGY ASSURANCE, L.L.C. ALL RIGHTS RESERVED UN Shipping Name
Lithium ion batteries packed with equipment Lithium ion batteries contained in equipment Lithium metal batteries packed with equipment UN 3091 Lithium metal batteries contained in equipment UN 3091 These international regulations use only 2 size classifications which are based on lithium content for lithium batteries and Watt-hour rating for Lithium Ion batteries. The table below outlines the shipping regulations currently in effect based on these international regulations. 1 – Watt-hours = rated capacity (Ah) X nominal operating voltage (V).
What is meant by “Excepted” in the tables on current U.S. and international regulations?
In both of the above cases, the term “excepted” means that batteries and cel s meeting these criteria
AND which have passed testing in accordance with the UN Manual of Tests and Criteria, may be
shipped without the Class 9 classification. There are still marking, labeling and shipping document
requirements that must be met in order to comply with the exceptions.
COPYRIGHT 2011 ENERGY ASSURANCE, L.L.C. ALL RIGHTS RESERVED Can Lithium (metal) primary cells and batteries be shipped as cargo on passenger aircraft?
No, the US DoT prohibits the offering for transportation and transportation of primary lithium (metal)
cells and batteries as cargo aboard passenger aircraft, into, out of, and within the United States. The
exception to this rule is for primary lithium cells with no more than 1g of lithium content and batteries
with no more than 2g of lithium content when they are packed with or instal ed in equipment only.
Even in these cases, the net weight of the cel s and batteries in each package cannot exceed 5kg, and
the package cannot contain more than the number of cel s or batteries necessary to power the piece of
equipment.

I make medium cel s and/or batteries (according to the US DOT definition) and I need to ship only in
the U.S., what are my options?

As we mentioned in the table above for U.S. transport regulations, medium batteries must ship as Class
9 Hazardous Materials. There is a special provision (Special Provision 189) within the U.S. HMR that
allows for shipments of “medium size” cells and batteries by motor vehicle or rail car without being
classified as Class 9. This provision applies if the following items are met:
1. The cells or batteries are medium based on the U.S. HMR criteria. 2. The cel s and batteries have been tested in accordance with the UN Manual of Tests and 3. Cells and batteries are prevented from short circuits and are packed in a strong outer packaging 4. The outside of the package is marked “LITHIUM BATTERIES – FORBIDDEN FOR TRANSPORT ABOARD ARICRAFT AND VESSEL” on a background of contrasting color, in specific size lettering based on the weight of the package. 5. Each package with more than 12 medium batteries, or 24 medium cells, except when contained
in equipment, must comply with appropriate marking, packaging, and documentation requirements.
What does Class 9 mean?

COPYRIGHT 2011 ENERGY ASSURANCE, L.L.C. ALL RIGHTS RESERVED Class 9 is one of nine hazardous material or dangerous goods classes defined by the domestic and
international regulations. The class designations define the packaging, marking, labeling, and shipping
documentation requirements for items that fal within each class. Class 9 goods are considered
miscellaneous hazardous materials. Additional information can be found on the fol owing websites:

What regulations apply to Lithium and Lithium Ion cel s and batteries that area packed with or
contained in equipment?

If a cell or battery must be shipped as a Class 9 Hazardous material, then the same rules apply when
they are shipped with or contained in equipment for shipment. The markings, weight limits and
documentation requirements change.

Do batteries have to be tested, if they use cells that have already been tested?
Yes. Anyone offering a Lithium or Lithium Ion battery for shipment (alone, installed in or packaged
with equipment), is responsible for ensuring that the battery itself meets al the appropriate
requirements of the appropriate shipping regulations. This includes testing, marking, labeling,
packaging and documentation requirements. In the packaging instructions of the IATA regulations, it
states that batteries shal be tested regardless of whether the cel s have been tested. For changes to
previously tested cel s or batteries, the UN Manual of Tests offers some guidance stating that products
must be retested if there is a change of more than 0.1g or 20% by mass to the cathode, anode or
electrolyte used (20% increase in capacity), or any changes to the construction that could materially
affect the outcome of the tests.

Can smal consumer primary lithium cel s and batteries be shipped by United States Postal Service
(USPS)?
Small consumer primary lithium cells and batteries like those used in cameras and flashlights are
mailable as long as the following requirements are met:
1. The cells and batteries meet the requirements of small according to the U.S. HMR. COPYRIGHT 2011 ENERGY ASSURANCE, L.L.C. ALL RIGHTS RESERVED 2. Each cell or battery has been tested in accordance with the UN Manual of Tests and Criteria. 3. Packaging must be firmly sealed and provide separation and cushioning to prevent short circuiting, movement or damage during transport. 4. Except for batteries instal ed in equipment, they must be in a strong outer package. Al outer packages must have a complete delivery and return address. Even with these requirements met, the shipments of Lithium cel s and batteries which are not packaged with or installed in equipment are still restricted as follows: 1. Shipment by surface transportation only is al owed when the cel s or batteries are in the originally sealed packaging and the package must not exceed 5 pounds. 2. They are also forbidden aboard passenger aircraft. The outside of the package must be marked on the address side “Surface Mail Only, Primary Lithium Batteries – Forbidden for Transportation Aboard Passenger Aircraft.” If the small primary Lithium cells or batteries are contained in or shipped with equipment, the following restrictions still apply: 1. Shipment by surface or air is allowed when packed with or installed in the equipment they are intended for use with and the mail piece has no more than the number of batteries required to operate the item. 2. When installed, the cells or batteries should be prevented from short circuiting or being 3. The device must be provided with an effective means to prevent accidental activation of the 4. The package must be marked on the address side “Package Contains Primary Lithium 5. The mail piece must not exceed 11 pounds. Can smal consumer Lithium Ion cel s and batteries be shipped by United States Postal Service
(USPS)?

Small consumer Lithium Ion cells and batteries like the ones used in cell phones and tablets, are mailable with the following restrictions: 1. The cells and batteries meet the limits of small as defined in the U.S. HMR. COPYRIGHT 2011 ENERGY ASSURANCE, L.L.C. ALL RIGHTS RESERVED 2. The cel s and batteries have been tested to verify compliance to the UN Manual of Tests and 3. Packaging must be firmly sealed and provide separation and cushioning to prevent short circuiting, movement or damage during transport. 4. Except for batteries instal ed in equipment, they must be in a strong outer package. Al outer packages must have a complete delivery and return address. If the small Lithium Ion cells or batteries are contained in or shipped with equipment, the following restrictions still apply: 1. Shipment by surface or air is allowed when packed with or installed in the equipment they are intended for use with and the mail piece has no more than 3 cells or batteries. 2. When instal ed, the cel s or batteries should be prevented from short circuiting or being 3. The device must be provided with an effective means to prevent accidental activation of the 4. The package must be marked on the address side “Package Contains Lithium Ion Batteries (no The following links will provide additional information about mailing of batteries.

What are the UN “T” tests and UN 38.3?

UN 38.3 refers to subsection 38.3 of the UN Manual of Tests and Criteria, Part II . This subsection
details the required testing for Lithium and Lithium Ion cells and batteries prior to offering them for
shipping. The UN “T” tests refers to the 8 individual tests within this subsection of the UN Manual.
The tests are as follows:
T1 – Altitude Simulation
T2 – Thermal Test (Temperature Cycling)
T3 – Vibration
T4 – Shock (Mechanical)
COPYRIGHT 2011 ENERGY ASSURANCE, L.L.C. ALL RIGHTS RESERVED T5 – External Short Circuit T6 – Impact (Cell only) T7 – Overcharge (Battery only) T8 – Forced Discharge (Cell only) Tests T1 through T5 are done on the same samples in sequence. Al other tests are done on separate cells and batteries. The table below details the required number samples for testing: Test (by T
Rechargeable
Batteries
Batteries
16 (small)/ 8 (large)
*Prismatic cells require 10 cells for T6
A copy of the UN Manual of Tests and Criteria can be obtained at the fol owing link:

How do I ship my cel s and batteries for testing if they must always be tested prior to shipping?
Al of the regulations discussed here have exceptions or special provisions for the shipment of cel s and
batteries for testing purposes. Under the U.S. HMR, 49 CFR 173.185(e) allows for the shipment of cel s
and batteries (not contained in equipment) for testing purposes only by highway and as Class 9
hazardous materials. Additionally, the U.S. HMR and the international Dangerous Goods regulations
contain provisions that allow for the shipment by air of prototype cel s and batteries. In the U.S. HMR,
it is covered under Special Provision A55. In the ICAO Technical Instructions and the IATA Dangerous
Goods Regulations, it is under Special Provision A88. However, in order to use these special provisions
for air shipments, the shipping party must first obtain an approval from a competent authority in the
country of origin. In the U.S. that approval would come from the U.S. Department of Transportation’s
Pipeline and Hazardous Materials Safety Administration (PHMSA). Shipments by cargo vessel of
COPYRIGHT 2011 ENERGY ASSURANCE, L.L.C. ALL RIGHTS RESERVED prototype cel s and batteries do not require any prior approvals, however, there are still stringent
packaging requirements that can be found in Special Provision 310 in the IMDG Code.
What are the rules for consumers traveling with devices powered by Lithium and Lithium Ion cel s
and batteries?
Provisions for consumer transport of batteries and battery powered devices are covered in the ICAO
Technical Instructions as well as the U.S. HMR. These rules can be found on the U.S. DoT website at

CONTACT ENERGY ASSURANCE or VIST OUR WEBSITE FOR ADDITIONAL INFORMATION
Energy Assurance LLC
5202 Bel e Wood Court
Buford, GA 30518
404-954-2054

The information contained in this summary/FAQ is intended to be general guidance and interpretations of the regulations as of the date completed. It does not constitute legal advice and cannot substitute for obtaining legal advice related to specifics of individual situations and products. While every effort has been taken to accurately represent the information within the various regulations contained herein, Energy Assurance does not guarantee its accuracy or completeness. Information may cont CO warranties as to the completeness, accuracy, or currency of the information provided in this FAQ.

Source: http://energy-assurance.com/PDFs/Transport_FAQ.pdf

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