Important announcement to Lithium battery customersUPDATES TO REGULATIONS AS OF JANUARY 1, 2015
All lithium batteries are considered as Class 9 "Hazardous Materials" or "Dangerous Goods" for shipping either domestically or internationally. Lithium batteries are either classified as "Lithium Metal" (primary/non-rechargeable) or "Lithium Ion" (includes lithium polymer; these are secondary/rechargeable). There are two regulating authorities: U.S. Hazardous Materials Regulations (HMR) and its associated Code of Federal Regulations (CFR), and International Air Transport Association (IATA) along with International Civil Aviation Organization (ICAO). There are exceptions to the HMR & IATA regulations for "small" lithium/li-ion batteries based on amount of lithium in these batteries. The amount of lithium in li-ion batteries is determined by either Watt Hour rating.
Please note that special packaging and marking requirements as well as special shipping and handling may be required for shipping lithium batteries. Depending on how the batteries are shipped (via ground or via air) will determine the requirements for marking and shipping.
For batteries less than 100 Watt-hour (Wh), no more than 2 batteries can be transported in a package to qualify for the Section II exceptions. Shipment of more than 2 batteries per box or 8 cells per box will require Class 9 labeling and Dangerous Goods training for the shippers.
Note that current packaging solutions can still be used; however new direction specifically states that for solutions that do not meet the requirements, shipments will need to be regulated as Class 9 dangerous goods. If you, the customer, intend to reship/repackage these packs, meeting the new packaging requirements will be required or a trained dangerous goods shipper will need to manage the reshipment.
In addition, there are changes to UN 38.3 Testing requirements. The new Revision 5, Amendment 1 requires that single cell packs that contain an overcharge circuit must now be UN Tested (T7 only), even if the cell used in the 1-cell pack has already been UN Transport tested.
Summary of changes for 2015
* The ban on international shipments of lithium metal batteries has been extended to include lithium ion batteries.
- 12/24 Exception Eliminated: Old provisions stated that if a package contained no more than 12 lithium batteries or 24 lithium cells, no hazard mark or documentation was required. The new regulations do not include this 12 battery/24 cell relief, which means many of shipments will now be regulated as Dangerous Goods. In addition, the new provision distinguishes between modes of transport with regard to the size of the package and type of mark required.
- New, Simplified Proper Shipping Names and UN Numbers: To align with international standards, PHMSA has adopted alternative proper shipping names for lithium ion and lithium metal batteries and new UN numbers.
- Low Production Runs and Prototypes: The new regulations make it easier to ship prototypes. Special provisions for low production lithium cells and batteries and prototype lithium batteries by air were deleted and replaced by a new provision that’s more aligned with international standards. This change will alleviate the need to secure approvals from PHMSA for ground and rail shipments of prototype and low production cells and batteries, but manufacturers still need approval for shipments by air.
- Cells and Batteries Packed With/In Equipment: When packed with equipment, a lithium battery may be placed in inner packaging that meets the Packaging Group II performance requirements. For lithium batteries contained in equipment, the packaging is no longer required to be waterproof.
- Shipping Lithium Cells or Batteries for Disposal/Recycling: The final rule provides relief for cells and batteries that are transported by motor vehicle. In addition, small or medium batteries that would have been classified as fully regulated are now exempt when transported by motor carrier.
- New Paperwork Retention for Manufacturers: Lithium cell and battery manufacturers must create a record of satisfactory completion of the UN testing prior to offering the cell or battery for transport.
Package "Mark" Every lithium metal/lithium ion package will require a "Mark" in accordance with 49 CFR 173.185(c). Currently, under Special Provision 188, any package moving by ground that contains less than 12 batteries or 24 cells does not require any marking or labeling requirements. These current 12 batteries or 24 cell exemptions will end.
Effective February 6, 2015, any amount of lithium metal/lithium ion cells or batteries will have to be marked with:
- An indication that the package contains "lithium metal" or "lithium ion" cells or batteries, as appropriate
- An indication that the package is to be handled with care and that a flammable hazard exists if the package is damaged
- An indication that special procedures must be followed in the event the package is damaged, to include inspection and repacking if necessary
- A telephone number for additional information
All shipments must be accompanied by the proper shipping documentation. In the past the documentation was only required for shipment of packages that contained more than 12 batteries or 24 cells. The ICAO/IATA Lithium Handling Label (LHL) is not required for shipments by ground or ocean, but this label does meet the "Marking" requirements of 49 CFR 173.185 (c).
Quick Reference Guide for shipping Rechargeable Lithium Ion Batteries(Based on IATA DGR 55)
Quick Reference Guide for shipping Non-Rechargeable Lithium Metal Batteries(Based on IATA DGR 55)
Please note: This information is not intended to take the place of regulations or encompass all of the changes to the ICAO/IATA Technical Instructions. This information should not be interpreted as a complete summary of the regulations or used in place of regulations. Also: it is the responsibility of the person offering a package of Lithium cells or batteries for transportation, including those packed with or contained in equipment, to be in compliance with all local, state, and country regulations for the mode of transport being used. All shippers of lithium metal and Lithium cells and batteries are affected by the changes to the 2014 ICAO and IATA Technical Instructions.
Please contact Rose Electronics (firstname.lastname@example.org) for further information.
Click here for the IATA 2015 Guidance Document for Lithium Batteries; refer to PI 965-970 for Packaging
Click here for the IATA 2014 Packing Instructions for Lithium Batteries
Click here for PRBA Document: Packaging and Shipping Batteries Safely
Click here for Department of Transportation 49 CFR Section 173.185 "Lithium Cells and Batteries"
Click here for copy of the UN Transportation Test Requirements: "UN Manual of Tests and Criteria, Revision 5, Amendment 1"
Click here for a copy of US Dept of Transportation's "Shipping Batteries Safely by Air"
Click here for 2013-2014 Quick Reference Guide to shipping Lithium Batteries by Air
Click here for example of Shippers Declaration Form – Section II
Click here for example of Shippers Declaration Form – Section 1B
Click here for UPS Guidelines 2013