Comprehensive Guide to Lithium Battery (and Battery Assembly) Export

To regulate the export management of lithium batteries (cells and batteries) and ensure transportation safety, customs authorities strictly supervise lithium battery exports in accordance with relevant international regulations and domestic laws.

1.Classification of Lithium Batteries (Cells and Batteries) for Export

According to the United Nations Recommendations on the Transport of Dangerous Goods – Model Regulations(TDG), lithium batteries (cells and batteries) are primarily classified into the following three categories based on their hazard characteristics and transport conditions, each corresponding to a specific UN number:

Lithium batteries (cells and batteries) transported separately:​

Lithium metal batteries (cells and batteries): UN 3090

Lithium-ion batteries (cells and batteries): UN 3480

Lithium batteries (cells and batteries) transported with equipment:​

Lithium metal batteries (cells and batteries): UN 3091

Lithium-ion batteries (cells and batteries): UN 3481 (Note: UN 3091 and UN 3481 cover both "batteries installed in equipment" and "batteries packed with equipment.")

Vehicles or self-propelled equipment powered by lithium batteries (cells and batteries):​

UN 3171, e.g., electric bicycles, cars, and self-balancing scooters powered by lithium batteries.

Special Note: According to the Amendment 42-24 of the International Maritime Dangerous Goods Code(IMDG Code), new UN numbers (UN 3556, UN 3557, and UN 3558) have been introduced for new energy vehicles. The new regulations took effect in 2025 and will be enforced starting in 2026.

2.Key Regulatory Basis for Customs Supervision

Customs supervision of lithium battery exports is primarily based on the following international regulations and domestic laws:

International Regulations:​

Recommendations on the Transport of Dangerous Goods – Model Regulations(TDG)

International Maritime Dangerous Goods Code(IMDG Code)

Technical Instructions for the Safe Transport of Dangerous Goods by Air(ICAO-TI)

Regulations Concerning the International Carriage of Dangerous Goods by Rail(RID)

European Agreement Concerning the International Carriage of Dangerous Goods by Road(ADR)

Domestic Laws and Regulations:​

Law of the People's Republic of China on Import and Export Commodity Inspection

Inspection Regulations for Packaging of Export Dangerous Goods(SN/T 0370 Series)

3.Detailed Explanation of Key Customs Supervision Requirements

Article 17 of the Law of the People's Republic of China on Import and Export Commodity Inspectionstipulates that the packaging of exported dangerous goods (including lithium batteries) must undergo statutory inspection.

Packaging Performance Inspection:​

Applicant:​ Manufacturers of packaging containers.

Management Requirements:​ Customs implements a code management system for enterprises producing packaging for exported dangerous goods. Enterprises must apply for and obtain a manufacturer code from the local customs authority before applying for performance inspection of their packaging containers.

Inspection Results:​ After passing the inspection, Customs issues the Inspection Certificate for Packaging Performance of Import and Export Goods.

Validity Period:​ The validity period depends on the packaging material and quality. For lithium battery packaging, the certificate is generally valid for no more than 12 months from the production date.

Packaging Usage Appraisal:​

Applicant:​ Manufacturers or exporters of lithium batteries (cells and batteries).

Prerequisites:​ Before application, the enterprise must ensure that the lithium batteries (cells and batteries) have passed UN 38.3 testing and that the packaging containers used have passed performance inspection.

Inspection Content:​ Customs conducts on-site verification of the actual packaging of lithium batteries (cells and batteries) to ensure compliance with international and domestic standards.

Inspection Results:​ After verification, Customs issues the Appraisal Certificate for Packaging Usage of Export Dangerous Goods.

Validity Period:​ Generally 12 months from the date of filling. Special Note: For air exports, the validity period is shortened to 3 months. Additionally, the validity period of the appraisal certificate cannot exceed that of the corresponding performance inspection certificate.

4.Key Considerations

UN 38.3 Testing:​ All lithium batteries (cells and batteries) intended for transport (UN 3480, UN 3481, UN 3090, UN 3091) must pass the tests specified in Section 38.3 of the United Nations Manual of Tests and Criteriabefore shipment, and a test report must be issued by a professional institution.

Dangerous Goods Packaging Requirements:​ Commonly used box-type packaging must comply with TDG Packing Instruction P903:

Batteries (cells and batteries) inside the packaging must be protected to prevent damage caused by movement or changes in position. The packaging must meet Performance Level II.

For batteries (cells and batteries) with a total mass ≥ 12 kg and a sturdy outer casing, robust outer packaging, protective covers (e.g., wooden crates), or pallets must be used.

Batteries (cells and batteries) must be securely fixed to prevent accidental movement, and electrodes must not bear weight.

Exemption Clauses:​ Small or limited quantities of lithium batteries (cells and batteries) meeting the requirements of TDG Special Provision 188 may be exempted from certain dangerous goods packaging requirements. However, the specified "rectangle mark" must be displayed on the packaging.

Labels/Markings:​ The packaging must clearly and durably display the following information:

Corresponding UN number (e.g., UN 3480).

UN marking.

Class 9 dangerous goods label (or marking).

Lithium-ion batteries (cells and batteries) must indicate the watt-hour (Wh) rating.

All markings must be durable, visible, and able to withstand exposure to outdoor conditions.

5.Summary

Enterprises exporting lithium batteries (cells and batteries) must strictly comply with the aforementioned international and domestic regulations. They should complete UN 38.3 testing in advance, select qualified packaging, and complete customs inspection and appraisal procedures to ensure compliant and safe exports. Given that regulations may be updated, enterprises are advised to stay informed about the latest official releases.

 

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