On the road, lithium batteries are carried as ADR Class 9 dangerous goods. Depending on the battery type, UN 3480, 3481, 3090 or 3091 is selected; every battery type must have passed the UN 38.3 tests and packages must bear the 9A label. Small batteries are subject to simplified rules under special provision 188, while damaged batteries are subject to stricter packaging rules.
Which UN number is selected?
Two questions determine the choice: is the battery rechargeable lithium-ion or non-rechargeable lithium metal, and is it shipped on its own or contained in or packed with equipment?
| UN | Description | Example |
|---|---|---|
| 3480 | Lithium-ion batteries | Spare battery, carton of power banks |
| 3481 | Lithium-ion batteries contained in or packed with equipment | Laptop, cordless power tool |
| 3090 | Lithium metal batteries | Non-rechargeable primary cells |
| 3091 | Lithium metal batteries contained in or packed with equipment | Smart meter, medical device |
| 3536 | Lithium batteries installed in cargo transport unit | Containerised energy storage system |
| 3556 | Vehicle, lithium-ion battery powered | Electric car |
ADR 2025 added UN 3551 and 3552 for sodium-ion batteries, and UN 3557 and 3558 for vehicles powered by lithium metal and sodium-ion batteries. The general rules of Class 9 are explained in ADR Class 9.
What conditions must be met before carriage?
- Every cell and battery type must have passed the tests in sub-section 38.3 of Part III of the UN Manual of Tests and Criteria. A battery is tested separately even if its cells have been tested.
- The manufacturer and subsequent distributors must make the test summary in 38.3.5 available to the supply chain; button cells installed in equipment are exempt from this requirement.
- Batteries must be protected against external short circuits, and manufacturing must be carried out under a quality management programme.
- For consignments subject to full ADR, an ADR transport document is issued.
Packaging, labelling and vehicle rules
Lithium battery packages bear the 9A label, the battery-symbol variant of the striped Class 9 label. The packing instruction for UN 3480 is P903, and this number cannot be carried as a limited quantity (LQ). Because it is in transport category 2, the 1.1.3.6 quantity exemption can be applied up to 333 kg per vehicle; above this limit, orange plates, a driver with an SRC5 certificate, instructions in writing and full ADR equipment are required. The calculation method is in ADR transport category.
Small batteries: special provision 188
Batteries not exceeding 20 Wh per cell and 100 Wh per battery for lithium-ion, or 1 g per cell and 2 g per battery of lithium for lithium metal, are exempt from the other provisions of ADR under the following conditions: the Wh rating must be marked on the battery case, the batteries must be protected against short circuits by inner packaging, the package must withstand a 1.2-metre drop test and, for shipments without equipment, must not exceed 30 kg gross. The package bears the lithium battery mark with a red hatched border. Packages containing only button cells installed in equipment, and packages with equipment containing no more than four cells or two batteries where there are no more than two packages in the consignment, are exempt from this mark.
Calculation example: a cell rated 3.6 V and 3,000 mAh equals 3.6 × 3 = 10.8 Wh, which is below the 20 Wh limit.
Damaged, defective and waste batteries
- Special provision 376: Batteries that have leaked, vented, been mechanically damaged or cannot be diagnosed before carriage are packed under instruction P908 or LP904.
- Critically damaged batteries: Those liable to rapidly disassemble, produce a flame or dangerous heat under normal conditions of carriage are carried under P911 or LP906 and placed in transport category 0; no exemption applies.
- Special provision 377: Batteries collected for disposal or recycling may be shipped under P909, and the 38.3 test is not required. Packages are marked "LITHIUM BATTERIES FOR DISPOSAL" or "LITHIUM BATTERIES FOR RECYCLING".
Batteries installed in vehicles
When an electric car is carried as cargo on a truck, it falls under UN 3556. If the conditions in special provision 666 are met, it is exempt from the other provisions of ADR; if the vehicle is shipped in a crate, the marking and labelling of the crate is checked separately against the ADR text before loading. Special provision 667 applies to damaged vehicles: if the damage significantly affects the safety of the battery, the battery is removed and carried under special provision 376.
How does Voltim Global support this?
In dangerous goods (ADR) transport, Voltim Global first asks for the test summary and the Wh rating for battery shipments; the UN number, whether an exemption applies and the vehicle equipment are determined on the basis of these two pieces of information.