Planning to ship lithium batteries by air into the United States, the European Union, or other markets? In this article, we explain what importers and manufacturers should know about UN 38.3 and the International Air Transport Association’s (IATA) Dangerous Goods Regulations (DGR) requirements.
We explain the requirements regarding testing, the shipper’s declaration, and how to package lithium batteries and subsequently label these for air transport.
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What is UN 38.3?
UN 38.3 – Lithium metal and lithium-ion batteries is a subsection of the UN Manual of Tests and Criteria Part III that focuses on the requirements regarding lithium metal batteries and lithium-ion batteries.
It aims to provide parameters for how you should comply with relevant rules regarding the transportation of lithium batteries by air, including testing, documentation, and labeling.
The batteries are classified as follows:
- UN 3090: Lithium metal batteries
- UN 3480: Lithium-ion batteries
- UN 3091: Lithium metal batteries contained, or packed with equipment
- UN 3481: Lithium-ion batteries contained, or packed with equipment
According to the Lithium Battery Guidance Document published by the International Air Transport Association (IATA), compliance with the UN 38.3 requirements is necessary to transport lithium batteries by air.
In this section, we outline the requirements that you, as an importer or manufacturer, should be aware of when shipping lithium metal and lithium-ion batteries by air.
For example, you should ensure that your lithium batteries are safe by having these tested against the requirements in UN 38.3. After the batteries have been tested, you need to provide relevant test reports.
You should also provide a shipper’s declaration certifying that your lithium batteries comply with IATA’s DGR, as well as make sure that you abide by applicable packaging requirements.
Do note that compliance for the shipment of lithium batteries is necessary for locations such as the following:
UN 38.3 Testing Requirements
It is important to ensure that your lithium batteries are well-designed and of high quality to prevent these from catching fire unexpectedly during shipment.
As such, you may need to have your lithium batteries tested against UN 38.3 requirements using different kinds of test methods such as the following:
- Test T.1: Altitude Simulation
- Test T.2: Thermal Test
- Test T.3: Vibration
- Test T.4: Shock
- Test T.5: External Short Circuit
- Test T.6: Impact/Crush
- Test T.7: Overcharge
- Test T.8: Forced Discharge
These kinds of tests can help you ensure that your lithium batteries are reliable enough to withstand the stresses of being transported by plane, ship, or land vehicle.
UN 38.3 Test Summary
The Lithium Battery Guidance Document states that importers and manufacturers of lithium cells or batteries, including appliances that use these cells or batteries as a source of power, are required to provide a UN 38.3 test summary if they want to ship their products by air.
If you are an importer or a manufacturer of lithium cells or batteries, then you need to provide the following information in the test summary:
a. Your name
b. Your contact information (including address, phone number, email address, and website)
c. The test laboratory’s address, phone number, email address, and website
d. The test report identification number (it should be unique to the test report)
e. The date on which the test was conducted
f. A description of the cell or battery
g. A list of the conducted tests and their results (i.e., pass/fail)
h. References to requirements regarding the assembled battery testing, if applicable (i.e., 38.3.3 (f) and 38.3.3 (g))
i. Used references to the revised edition of the Manual of Tests and Criteria, and any amendments, if there are any
j. The signature with the name and title of the signatory (to indicate that the provided information is valid)
The description of the cell or battery, as mentioned in item i above, should include at minimum the following:
- Lithium-ion or lithium metal cell or battery
- Watt-hour rating, or lithium content
- Physical description of the cell/battery; and
- Model numbers
UN 38.3 Shipper’s Declaration
If you ship lithium-ion batteries you should include a Shipper’s Declaration that includes a certification statement that may read as follows:
“I declare that all of the applicable air transport requirements have been met.”
When you sign your Shipper’s Declaration, you legally state that your lithium-ion batteries comply with the DGR by having a state of charge (SoC) that does not exceed 30% of its rate capacity.
In addition to the statement, you are also required to provide the following details:
- Shipper’s name
- Transport details
- Shipment type
- Nature and quantity of dangerous goods
For a more detailed outline of the Shipper’s Declaration for Dangerous Goods, click here.
UN 38.3 Packaging Requirements
In this section, we explain how you should properly package lithium batteries for air transport, and how you should subsequently label those packages.
To prevent your lithium cells or batteries from short-circuiting, and the terminals from being damaged, you should pack each cell or battery in blister packaging and provide it with a cushioning sheet (such as bubble wrap), before separating it from other packaged cells or batteries in the box with a divider.
Here we list some of the UN 38.3 labeling requirements.
“Cargo Aircraft Only” label
You are required to provide a “Cargo Aircraft Only” label on the package of the lithium-ion batteries you are shipping.
Lithium battery mark label
You are required to place the lithium battery mark label on the packaging of your lithium batteries. The label’s minimum dimensions should be 100 mm x 100 mm, and it should include the following:
a. The color-contrasting symbol of a group of batteries, one of which is damaged and emitting a flame
b. Applicable UN number(s) for relevant lithium batteries or cells, i.e., UN 3090, UN 3091. These should be below the mark
Class 9 lithium battery hazard label
You should also place the Class 9 lithium battery hazard label on the shipment package. Although you do not have to place this label on the same face of the package as the other labels, you should do so if space allows for it.
You are also required to provide the following on your packaging:
- “UN” and the Proper Shipping Name
- The UN Number
- The shipper’s and consignee’s address
- Net mass
If you use an overpack to ease the handling or transport process, you should duplicate any labels on the package(s) and place these on the overpack.
In this section, we explain whether compliance with the requirements in UN 38.3 is necessary, in different markets.
Is UN 38.3 compliance required in the US?
If you ship lithium batteries in the US by air, or products that contain the batteries, then according to the Hazardous Material Regulations you are required to ensure that your batteries and the shipment of such comply with UN 38.3.
It is inherently dangerous to ship lithium batteries in bulk by air. The Federal Aviation Administration (FAA) has provided information about the possible risks when shipping lithium batteries:
- FAA Safety Alert (10017)
- FAA Safety Alert (16001)
Is UN 38.3 compliance required in the EU?
EU transport rules follow international regulations, as the European Aviation Safety Agency (EASA) cooperates with the IATA, which notes that you should ensure your lithium batteries comply with its requirements in UN 38.3 before you ship these by air in the EU.
You cannot ship counterfeit, non-compliant, or substandard lithium batteries by air because they are dangerous and can explode.
Is UN 38.3 compliance required in the UK?
According to the Civil Aviation Authority (CAA), which provides information from the International Civil Aviation Organization’s (ICAO) Technical Instructions for the Safe Transport of Dangerous Goods by Air, you are required to ensure that your lithium batteries comply with the requirements in UN 38.3 if you want to ship these by air.
Is UN 38.3 compliance required in Australia?
The Australian Dangerous Goods Code states that you can ship lithium cells or batteries by air (including those contained in equipment) only if they comply with the requirements in UN 38.3, and have been assigned UN Numbers 3090, 3091, 3480, or 3481.