Lithium Ion Battery Labeling: How to Ship Lithium Ion Batteries Without Getting Into Trouble With The IATA, 2019 Version
Provisions for the transport of lithium ion batteries updated, as per the IATA, on January 1st, 2019. The following is based on the regulations set forth by the Technical Instruction for the Safe Transport of Dangerous Goods by Air (Technical Instructions) and the 60th Edition of the IATA Dangerous Goods Regulations (DGR).
Note: This article is not intended to be legal advice and may not contain comprehensive or up to date requirements for lithium ion battery transport regulations. Do not take this article as legal advice. It is meant only as a starting point to understand the higher level requirements of transporting lithium ion batteries. Please refer to the IATA DGR 60th Edition for the latest official regulations.
Definitions For Lithium Battery Transport Regulations:
Lithium Battery: this is an umbrella term for several kinds of batteries with their own disparate chemical make-ups. Some in this group contain cathodes and electrolytes. They are as follows:
Lithium Metal Batteries: These batteries either possess an anode made of lithium metal or one made of a lithium compound. They’re typically used to give power to items like “watches, calculators, cameras, temperature data loggers, car key fobs and defibrillators” (pg. 2). They are usually non-rechargeable.
These batteries, when not housed in their packaging or inside of an electronic item, are prohibited from being moved as cargo on a passenger airplane. Unless you have been granted explicit approval by the State of Origin, and State of Operator, and their quantity is in keeping with the limits set by that authority. When it comes to other lithium metal cells and batteries.
Lithium-ion Batteries: Often referred to as Li-Ion Batteries. They possess but a scarce amount of lithium. This lithium is in its ionic state in the electrolyte. These batteries have the capacity to charge cell phones, laptops, power tools, tablets and e-bikes. Another battery type that is often considered a derivative form of lithium-ion is lithium polymer.
Again, there are rules for the transport of these items by aircraft. More specifically, for when they are being transported outside of their designated packaging or an electronic device.These batteries cannot be shipped if they possess a charge greater than 30% of their rated capacity.
Aggregate lithium content: Refers to the total amount of lithium in grams housed in the cells of a battery.
Battery: A battery is the product of two or more cells, or batteries, that are connected and feature certain apparatus that allow them to transfer electrical charges. These apparatus include terminals, cases, markings and protective devices. They are designed to be housed in and a provide an electrical charge to an item.
Button cell: small cylindrical cell or battery that has a height that is less than its diameter.
Cell: Electrochemical unit housed in a single cell. There should be a “voltage differential” across its two terminals. According to the “UN Manual of Tests and Criteria and this guidance, to the extent the encased electrochemical unit meets the definition of “cell” herein, it is a “cell”, not a “battery”, regardless of whether the unit is termed a “battery” or a “single cell battery” outside of the UN Model Regulations, the UN Manual of Tests and Criteria and this guidance” (pg. 3).
Consignment: Those dangerous goods, allotted to one or more packages, that sent from a shipper and received by an airline operator at a designated location. A receipt is, then, granted for these packages, and they are given over to a consignee.
Total weight/volume of dangerous goods in a package, not including the weight/volume of the packaging material itself.
The weight of the unpackaged dangerous goods.
Dangerous goods refers to any item, or items, described as such in Table 4.2 below. It should also be noted that the net quantity of an article, such as the lithium ion batteries contained is the same as the net weight of those lithium ion batteries in a package.
Overpack: Several dangerous goods in a singular package. Must be properly labeled, marked, and cannot be damaged.
Power Bank: Portable electrochemical battery. Device for charging cell phones and tablets. If a spare battery pack is to be brought on to an airplane as a carry-on, it must wrapped, and protected from items in the carry-on bag.
State of Origin: Country where the consignment is delivered from.
State of Operator: Country where operator’s main place of business is.
Lithium Battery Transport & Packaging Regulations:
To safely pack up lithium batteries, you must wrap in their own packaging material. This prevents any damage to the terminals. To protect the lithium batteries from short circuiting, wrap them in strong packaging that will keep them from touching metal or a conductive materials.
Shippers of lithium batteries prepared in accordance with Section II of the lithium battery packing instructions are not subject to the formal dangerous goods training requirements set out in DGR 1.5, however, persons preparing such shipments must be provided with sufficient instruction as described in DGR 1.6.
The following is offered as a beginning point for an employer on what could be considered as being sufficient instruction:
In order to ship a package in accordance with these IATA standards, an employer must clearly articulate the kinds of lithium batteries they have chosen to ship. They must write down the procedures and standards to be met for the shipment of the aforementioned lithium batteries.
Any and all pertinent information should be given to the employees responsible for handling the shipment of the items. Employees assigned to handle the shipment of these items need to walk through the procedure in the preparation process.
They must “demonstrate the correct application of documented procedures for the packing, labeling, marking and documentations requirements, as applicable to their job function.” There must correct documentation on employees involved, and the date that instruction was provided to said employees.
Employees are to be given periodic refreshers. The other option is to have them, on a periodic basis, demonstrate the proposed procedures. These are to be conducted every 2 weeks, or every time the regulations or procedures are changed.
Any companies made to deal with the “reverse logistics,” making preparations for the return of the lithium batteries packed with, or housed inside of, equipment must detail the return procedure for the customer.
The warning label must include any prohibitions in regard to the transport of lithium batteries. It must also include information on how to and in what way to, properly transport said batteries.
Lithium battery mark appearance and requirement information?
Lithium batteries, in order to be transported, require specific markings as detailed in Section II of packing instructions 965, 966, 967, 968, 969 and 970. Further details on said markings can be found in Section IB of packing instructions 965 and 968. In these sections, you can also find regulatory information about the Class 9 lithium battery hazard label and Cargo Aircraft Only label.
The border edge must be outfitted with red diagonal hatchings. These hatchings must possess a minimum width of 5 mm. It should include a symbol of batteries, one of which should appear damaged and spewing flame. They are to appear above the UN number (UN 3090, UN 3091, UN 3480 etc.) for lithium or lithium metal batteries, view our Lithium Battery Transport & Handling labels here.
The image must be black on white, unless on another background with a high level of contrast. The smallest dimensions allowed are 120 mm wide x 110 mm high. If the package is unusually small, then 105 mm wide x 74 mm high is also acceptable.
When am I allowed to forgo the lithium battery mark?
The lithium battery mark should not be affixed to packages arranged in accordance with Section IA of Packing Instructions 965 and 968 and Section I of Packing Instructions 966, 967, 969 and 970.
Am I allowed to ship recalled, damaged or non-conforming cells or batteries?
There are prohibitions on the aerial transport of any lithium batteries that are defective. This includes any lithium batteries that have been damaged in such a way that they are at-risk of combustion or short-circuit.
This rule applies to the lithium components in phones, laptops or tablets, and any other object with the very real potential of being recalled. Other batteries with defects like the lights indicative of charge not turning on, erroneous serialization, or batteries that cannot maintain charge, can still be shipped by air.
Also, laptops being returned may not have a defective battery, it may not meet the needs of the customer, may be defective itself (but not the battery), etc. In these situations air transport would be permitted. The battery or equipment manufacturer should be contacted to determine the appropriate shipping method (pg. 16).
Maximum weight of batteries per package for fully regulated lithium ion batteries housed in equipment?
The maximum weight is 5 kg of lithium batteries for each passenger aircraft is 5 kg, or 11 lbs. The weight per package for cargo aircraft is not to exceed 35 kg, or about 77 lbs.
What other marking requirements are there for a package prepared in accordance with Section IB of Packing Instruction 965 and 968?
Additional and necessary marking for the lithium battery warning label are as follows (pg. 17):
the UN Number preceded by “UN” and the Proper Shipping Name (DGR 184.108.40.206 (a));
• the shipper and consignee address (DGR 220.127.116.11 (b));
• in addition, the net weight as required by (DGR 18.104.22.168(c)) must be marked on the package; and
• the lithium battery mark (see item 2D) in addition to the Class 9 lithium battery hazard label and Cargo Aircraft Only label.
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