Shipping Lithium Batteries From China: UN 38.3, Packaging & Labels

Suggestion: Watch the 10 minutes video tutorial before reading this article

Importing standalone lithium batteries, or Li-ion powered electronic devices, from China?

Then you might be aware of the strict and complicated safety regulations, covering labeling, export packaging and documentation.

However, you might still struggle to understand how you should go about to actually follow these regulations when importing li-ion batteries and electronics from China.

In this article, we cover the following:

• What types of lithium batteries and devices are regulated?
• UN 38.3 and other safety standards
• Export packaging requirements
• Documentation requirements
• Lab testing requirements
• Shipping lithium batteries by sea
• Shipping lithium batteries to Amazon

Notice that IATA and air couriers update these regulations on a yearly basis.

However, you can safely assume that it’s not going to get any easier to transport lithium batteries and devices in the future.

What types of lithium batteries and devices are regulated?

All lithium batteries are classified as hazardous materials (hazmat), which therefore require that all lithium batteries are packed and labelled in a certain way.

And, that the batteries are technically compliant with safety standards.

Before we move on, I want to clarify that regulations cover the following lithium battery types:

• Lithium Ion (Li-Ion) Batteries
• Lithium Polymer (Li-Po) Batteries
• Lithium Metal Batteries

In this article, we focus on Li-Ion and Li-Po batteries, as these are rechargeable and therefore used in many electronic devices.

Further, some electronic devices are also covered by the transportation regulations:

• Power banks
• MP3 and MP4 players
• Other lithium battery powered equipment

There are also UN codes that classify Li-Ion batteries as following:

• UN 3480, Lithium ion batteries
• UN 3481, Lithium ion batteries contained in equipment
• UN 3481, Lithium ion batteries packed with equipment

These codes are used for export packaging labeling, which I will get back to later in this article.

Are the regulations the same worldwide?

No. First of all, IATA comes out with yearly transportation safety requirements that apply to all international air transportation.

However, air couriers such as Fedex and UPS add their own, often stricter, requirements on top of those issued by IATA.

Keep in mind that this only applies to transportation regulations.

You must also ensure that the batteries comply with applicable safety standards in the target market.

Overview of Lithium Battery Regulations

a. UN/DOT 38.3

The purpose of UN 38.3 is to set an international standard that ensures safety when transporting lithium batteries, by air, sea or land.

IATA requires at all batteries must pass UN 38.3 testing, in order to be transported.

Technically, UN 38.3 outlines safety requirements that covers the following:

T1 – Altitude Simulation (Primary and Secondary Cells and Batteries)
T2 – Thermal Test (Primary and Secondary Cells and Batteries)
T3 – Vibration (Primary and Secondary Cells and Batteries)
T4 – Shock (Primary and Secondary Cells and Batteries)
T5 – External Short Circuit (Primary and Secondary Cells and Batteries)
T6 – Impact (Primary and Secondary Cells)
T7 – Overcharge (Secondary Batteries)
T8 – Forced Discharge (Primary and Secondary Cells)

A test report is the only way to prove that your batteries are UN 38.3 compliant.

In other words, if you don’t have a test report, valid for your batteries, you can’t get the lithium batteries and equipment shipped from China.

While IATA doesn’t require that you submit an MSDS or UN 38.3 test report, your freight forwarder or air courier (i.e., Fedex or DHL) will certainly do so.

b. Documentation Requirements

IATA requires that you and/or the shipper fills out a ‘Shipper declaration for dangerous goods’, which includes the following information:

• Shipper
• Consignee (Importer)
• Air Waybill Number
• Airport of destination
• Nature and quantity of dangerous goods

You can either visit this page, or request a template from your freight forwarder.

In addition, you will likely need the following documents to your freight forwarder:

• UN 38.3 test report
• Material safety data sheet (MSDS)

c. Export Packaging Requirements

The export cartons must have a permanent (printed) freight remark that includes the following information:

• Warning Labels
• Battery type name
• Name and address of supplier
• Name and address of the importer
• UN Label (i.e., UN 3480)
• Handling procedures (if damaged)
• Phone number

There are strict label size requirements.

Further, only use rigid cardboard boxes with at least 5 layers.

IATA also requires that the products are protected and separated inside the cartons:

• Layer 1: Lithium Battery with unit packaging
• Layer 2: Plastic wrap sheet
• Layer 3: Cardboard Divider

d. National / Harmonized Product Safety Standards

In addition to transportation regulations, there are also national safety standards that you should be aware.

There are, for example, regulations in the United States and the European Union that apply to lithium batteries and equipment, in addition to UN 38.3 and other standards mentioned in this article.

You can learn more in these articles:

• CE Marking When Importing From China
• Product Safety Standards & Labeling in Canada
• UL Certification When Importing from China
• Product Compliance Requirements on Amazon
• Electronics Regulations & Standards: Ensuring Compliance in China

e. Lab Testing Requirements

All Lithium batteries must be UN 38.3 compliant, and freight forwarders require that you present a test report before shipment.

There are two ways to obtain a test report:

1. Submit a test report provided by the supplier

This only works if your supplier already has a UN 38.3 test report. This should certainly not be taken for granted, as most Chinese manufacturers don’t have UN 38.3 test reports issued by accredited testing companies.

Requesting, and verifying, UN 38.3 test report should be part of your supplier vetting process, as you can save a hundreds of dollars in testing fees by using the suppliers test report.

That does, however, require that:

a. The test report is valid for the same type of product or lithium battery
b. The test report is held by the supplier (and not an unverified subcontractor)

In other words, using your suppliers UN 38.3 test report is not always that straightforward.

2. Order a UN 38.3 test from an accredited testing company

In the likely scenario that your supplier cannot provide a valid and verifiable UN 38.3 test report, your only option is to submit a battery sample to an accredited compliance testing company.

You will need to pay for lab testing, which normally costs around US$350 to US$500.

Some Chinese suppliers may offer to submit the battery to a local testing company. But there are a few problems with that:

a. The test report may be worthless if it’s not issued by an accredited testing company

b. The test report will be issued in the supplier’s name, enabling them to use it for other customers

The latter could be acceptable, if it was not for the fact that they will still require you to pay for testing.

In other words, contact a testing company by yourself so you know who is managing the testing process. And, you’ll receive a test report that is held in your company name.

Shipping lithium batteries and devices to Amazon

Amazon seller requirements for lithium batteries are in principle the same as the rules set by IATA and air couriers.

However, Amazon goes even further when it comes to ensuring the safety of lithium batteries and battery powered devices:

a. Amazon requires up to date material safety data sheet (MSDS) provided by the Importer

b. You must correctly classify (i.e., correct UN number) your product before adding them to your listing

c. You may need to submit compliance documents (i.e., test reports, DoC and technical file) to prove that the product is tested and compliant with national or harmonized safety standards (in addition to UN 38.3).

d. There are some cases when Amazon required sellers to comply with UL 1642, which is a legally speaking a voluntary standard. It’s ultimately up to Amazon to decide what standards they set, even if they are above the legal minimum.

Read more

• Requirements for lithium batteries and products that ship with lithium batteries
• Required information for products regulated as dangerous goods

Questions & Answers

How do we comply if we are shipping lithium batteries by sea?

Overall, the same safety, documentation, packaging and labeling requirements also apply when transporting lithium batteries by sea, road or railway.

There are, however, some differences,that are explained in this guide by Kuehne and Nagel.

How do I make sure my supplier complies with these requirements?

Most Chinese suppliers are not IATA or UN 38.3 compliance experts, so you should not even ask them for advice.

At best, they may have a UN 38.3 test report that you can use.

As an importer, you will ultimately pay the price if the shipment gets stuck in customs, so you have to provide your supplier with clear instructions – and verify that they actually follow them.

Checklist

• Instruct the supplier how to correctly pack the products
• Instruct the supplier how to label the export cartons (and provide label files)
• Instruct the supplier how to fill out the IATA shipper declaration

Can I rely on my freight forwarder to take care of this?

A reputable freight forwarder should understand the IATA labeling, packaging and documentation requirements.

However, the forwarder doesn’t get paid to help you book UN 38.3 lab testing, or instruct your supplier on how to correctly pack and label the products.

They should be able to provide templates and checklists, and inspect the labels before shipment, but don’t assume that they will handle the entire process for you.

That’s simply asking for too much.