Shipping lithium batteries: Are you up to date on the requirements?

By Elizabeth M Dickinson, JD, Legal Editor

Confused? It’s not surprising considering that the U.S. Department of Transportation (DOT) has revised its hazardous material regulations (HMRs) for shipping lithium cells and batteries several times over the past 2 years. The DOT has added Proper Shipping Names and Identification Numbers to the Hazardous Materials Table (HMT) and revised packaging, including labeling, requirements for lithium cells and batteries.

The idea behind these revisions is to harmonize the HMRs with recent changes to international standards for transporting hazardous materials. So are you up to date on changes to the lithium battery shipping standards? A review of the following will help give you a better handle on how to ship lithium batteries in compliance with the changes that are now all in effect.

Revised requirements for shipping

As you know, the lithium battery requirements apply to both lithium metal and lithium-ion cells or batteries that are either packed with the equipment powered by the batteries or are actually contained within the battery-powered device. It’s common to find lithium batteries in cell phones, laptops, watches, cameras, and toys, as well as in power tools and electric vehicles.
Shipping descriptions. To understand what HMRs apply to your shipment of lithium batteries, you must first identify what kind of lithium battery it is and then find the best shipping description for it on the HMT which would be the Proper Shipping Name and Identification Number. The DOT incorporated these 6 Proper Shipping Names and 4 Identification Numbers into the HMT:

• Lithium-ion batteries, including lithium-ion polymer batteries (UN3480)
• Lithium-ion batteries contained in equipment, including lithium-ion polymer batteries (UN3481)
• Lithium-ion batteries packed with equipment, including lithium-ion polymer batteries (UN3481)
• Lithium metal batteries, including lithium alloy batteries (UN3090)
• Lithium metal batteries contained in equipment, including lithium alloy batteries (UN3091)
• Lithium metal batteries packed with equipment, including lithium alloy batteries (UN3091)

Packaging requirements. Column 8(A) of the HMT indicates that the packaging requirements that apply to all of these lithium battery shipping descriptions are found at 49 CFR 173.185, which was revised by the DOT to require that:

• All outer packagings for transportation of lithium batteries be marked according to new hazard communication standards, with the only exception being a package containing button cell batteries installed in equipment (including circuit boards), or no more than 4 lithium cells or 2 lithium batteries installed in the equipment;
• One set of hazard communication markings applies to shipments by highway, rail, and vessel, with a second set of markings applying to air shipments; and
• A new prescribed “large packaging” be used for a single large lithium battery or a battery contained in equipment (except for air transport).

Easily overlooked in the flurry of HMR revisions is the requirement that hazmat shippers no longer include a packing group assignment for lithium batteries on shipping papers or other communications.

Air shipments

The most recent change is the prohibition of transporting lithium-ion batteries (UN3480) as cargo on passenger aircraft when they are not contained in or packed with equipment. In addition to other applicable requirements from the DOT, the International Civil Aviation Organization (ICAO), and the International Air Transport Association (IATA), the UN3480 packaging must display the “Cargo Aircraft Only” label. When shipped on cargo aircraft, these UN3480 batteries must be shipped at a state of charge (SoC) not exceeding 30 percent of their rated design capacity. A similar passenger aircraft prohibition has been in effect for lithium metal batteries, including lithium alloy batteries (UN3090) for over a year.
Shipments of lithium-ion batteries packed in battery-powered equipment or with associated battery-powered equipment (UN3481) are not affected by the passenger aircraft prohibition.