Lithium Battery Export Customs Compliance Guide
2025-06-20
Customs Supervision Briefing on Lithium Battery Exports
Lithium batteries, pivotal for electric vehicles, consumer electronics, and wearables, are classified as Class 9 dangerous goods (UN 3480) due to chemical risks. This briefing outlines customs compliance requirements for exports, emphasizing safety protocols and regulatory adherence.
PART 01 Lithium Battery Classification
The UN Recommendations on the Transport of Dangerous Goods - Model Regulations assign distinct UN numbers to dangerous goods based on their hazardous properties and regulatory requirements. Lithium batteries are categorized into three main groups under five UN numbers depending on their configuration:
1. Lithium batteries shipped alone: Classified as either lithium metal batteries (UN 3090) or lithium-ion batteries (UN 3480).
2. Lithium batteries contained in equipment: Similarly differentiated into lithium metal batteries (UN 3091) and lithium-ion batteries (UN 3481).
3. Vehicles or self-propelled devices powered by lithium batteries: Such as electric vehicles, e-bikes, hoverboards, and electric wheelchairs, classified under UN 3171.
Lithium batteries classified under specific UN numbers are subject to tailored regulatory requirements for dangerous goods transport. The aforementioned Group 1 and Group 2 lithium batteries (i.e., those assigned UN 3480, UN 3481, UN 3090, or UN 3091) must pass the test series outlined in Section 38.3 of Part III of the UN Manual of Tests and Criteria prior to transport. These tests include altitude simulation, thermal cycling, vibration testing, shock testing, external short circuit at 55°C, crush/impact testing, overcharge testing, forced discharge testing, etc., to ensure compliance with lithium battery transport safety standards.
Lithium battery family
PART 02 Export Regulatory Requirements for Lithium Batteries
1. International Regulatory Standards
Lithium batteries fall under Class 9 dangerous goods per international transport regulations, including the UN Recommendations on the Transport of Dangerous Goods - Model Regulations (TDG), International Maritime Dangerous Goods Code (IMDG Code), and Technical Instructions for the Safe Transport of Dangerous Goods by Air (ICAO-TI). Unless exempted from dangerous goods packaging requirements, lithium batteries must be packaged in compliance with these international standards during transport.
2. PRC Legal Requirements
Under China’s Law on the Inspection of Import and Export Commodities:
Lithium battery packaging manufacturers must undergo dangerous goods packaging performance inspections by local customs authorities and obtain the Inspection Certificate for Export Dangerous Goods Packaging Performance. Exporters must then procure certified packaging from these manufacturers. After packaging, a final customs inspection is required to obtain the Inspection Certificate for Export Dangerous Goods Packaging Usage (“Dangerous Goods Package Certificate”), ensuring compliance with regulatory standards.
Legal reference:
Article 17 of the Law of the People's Republic of China on the Inspection of Import and Export Commodities: Enterprises manufacturing packaging for export dangerous goods must apply to commodity inspection authorities for performance evaluation of such packaging. Enterprises producing export dangerous goods must apply for usage inspection of the packaging. Dangerous goods utilizing uninspected or non-compliant packaging are prohibited from export.
PART 03 Common Export Non-Compliance Issues for Lithium Batteries
1. Customs Inspection Focus
At export ports, customs officials verify the Dangerous Goods Package Certificate issued by local customs authorities, cross-checking packaging details (type, UN marking, lithium battery markings) and quantities against physical shipments to ensure compliance.
2. Common Non-Compliance Issues
Key violations include failure to obtain the required Dangerous Goods Package Certificate when exemption criteria are unmet, resulting in missing documentation during port inspections. Additionally, instances of obscured or improperly marked lithium battery labels on packaging have been observed.
PART 04 Are All Lithium Batteries Required to Obtain a "Dangerous Goods Package Certificate"?
Under international regulations, certain exported lithium batteries may be exempt from the Dangerous Goods Package Certificate requirement, primarily falling into two categories:
1. UN3171 Lithium Batteries
Lithium batteries installed in vehicles (e.g., electric vehicles, electric bicycles) are exempt from dangerous goods packaging requirements.
2. Lithium Batteries Below Specified Thresholds
Specifically, lithium metal/alloy batteries with ≤1g lithium content per battery (or ≤2g per battery pack), and lithium-ion batteries with ≤20Wh per battery (or ≤100Wh per battery pack) may be exempt from dangerous goods packaging requirements when complying with IMDG Code Special Provision 188.
Important: This exemption applies solely to the Dangerous Goods Package Certificate. The outer packaging must still display the Watt-hour rating and appropriate lithium battery markings.
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