Transport of Lithium-Ion Batteries

The transport of lithium-ion batteries is subject to dangerous goods regulations. According to ADR, lithium-ion batteries are assigned to dangerous goods class 9 (classification code 9A). Depending on the mode of transport and the condition of the battery, binding regulations apply to testing, packaging, marking, and documentation.

Classification and UN Numbers

Lithium-ion batteries belong to dangerous goods class 9 (code 9A); label 9A applies.

Mode-Specific Regulations

• ADR – road transport (Europe).
• RID – rail transport.
• IMDG Code – maritime transport.
• IATA-DGR / ICAO-TI – air transport (particularly restrictive).
• GGVSEB – German national dangerous goods regulation for road/rail/inland waterway transport.

Note: These regulations are updated regularly (ADR on a 2-year cycle). The currently valid version is decisive.

Test Requirement UN 38.3

Before transport, lithium batteries must have passed the tests according to UN 38.3 (UN Manual of Tests and Criteria, Part III, subsection 38.3). This includes eight individual tests for mechanical (vibration, shock), thermal, and electrical (short circuit, overcharge) stability. Proof is provided by the UN 38.3 test summary. Without this proof, no simplified shipment is possible.

Exemption under Special Provision 188 (100 Wh Limit)

Special Provision 188 (SP 188) allows simplified shipment as an “excepted quantity” provided that the energy limits are observed and the UN 38.3 tests have been passed:

The 100 Wh limit is the central threshold in battery logistics. If a battery exceeds this (e.g. an e-bike battery with 500 Wh), SP 188 does not apply and the battery must be transported as regular class 9A dangerous goods.

Packing Instructions by Condition

The regulations depend on the physical and legal condition of the battery:

Marking

Packages bear the lithium battery mark (rectangular marking with hatched border, battery symbol with flame and UN number); batteries shipped regularly additionally bear the label 9A.

Removal of the emergency telephone number: With ADR 2023, the obligation to indicate an emergency telephone number on the lithium battery mark no longer applies. Transitional period for the use of old marks with telephone number: until 31/12/2026; after that, the reduced label becomes mandatory.

Transport of Damaged Batteries

Damaged or defective batteries (visible housing damage, deformations, melted areas, self-heating) are considered the highest risk level and are transported according to SP 376 / P908. Required are non-combustible, electrolyte-absorbing filling and cushioning materials as well as fire-resistant overpacks. In practice, certified transport boxes are used. The transport document must contain the note “Transport in accordance with Special Provision 376”.

Differentiation

Transport must be distinguished from storage: For transport, dangerous goods law applies (ADR, class 9/code 9A, UN 38.3), while for storage, primarily hazardous substances and fire protection law apply (TRGS 510, VdS 3103).

Frequently Asked Questions

Which dangerous goods class do lithium-ion batteries fall under?

Class 9 (code 9A). Shipped separately under UN 3480, in or with equipment under UN 3481.

What does the 100 Wh limit mean?

Up to 100 Wh (battery pack) or 20 Wh (single cell), simplified shipment according to SP 188 is possible. Above that, the full dangerous goods status of class 9A applies.

What does UN 38.3 mean?

A binding test requirement with eight tests (including vibration, shock, thermal testing, short circuit, overcharge) that batteries must pass before transport.

How are damaged batteries transported?

According to SP 376 / P908: in fire-resistant overpacks with non-combustible fillers (e.g. vermiculite, glass granulate), with the note “Transport in accordance with Special Provision 376”.

Does an emergency telephone number have to be on the label?

No longer since ADR 2023. Old marks with telephone number may still be used until 31/12/2026.

Last update of this page: 06/2026