In this whitepaper, we address the Lithium ion battery safety guidelines for US imports, which affect many manufacturers who are producing their goods in China and Asia and seeking to ship them to the USA for sale.
- 1. Background
- 2. Recalls
- 3. Product safety
E) SAE Intl.
- 4. Transport safety
- 5. Packing Restrictions & Safety Tips
- 6. Compliance recommendations from US CPSC
- 7. Lithium battery safety in practice
- 8. Source documents
The use of batteries in consumer products continues to grow exponentially. As such, lithium ion battery safety has become an important topic for US importers to understand.
With this proliferation of batteries and the miniaturization of portable products, manufacturers have sought to increase battery operating times while reducing the size and weight of the battery and the battery-powered product.
This has led to battery chemistries that pack higher energy in smaller packages. High-energy chemistry batteries include lithium ion, lithium ion polymer, and lithium metal batteries that are thinner, smaller, and lighter weight and contain more energy than traditional rechargeable and non-rechargeable batteries.
Although conventional battery chemistries, such as lead acid, pose fire and explosion hazards, the combination of high-energy volatile chemistry packed into a small volume requires special safeguards to minimize potential hazards.
High-energy density batteries need enhanced safety systems and additional care when using and handling, both in or when removed from the product; and batteries must be properly tested with the product, in its intended use and with the charger as a system.
When considering the shipping of ‘Lithium batteries’ into or within the USA, the types in question are, in summary:
- Lithium metal batteries. Are generally primary (non-rechargeable) batteries that have lithium metal or lithium compounds as an anode. Also included within lithium metal are lithium alloy batteries. Lithium metal batteries are generally used to power devices such as watches, calculators, cameras, temperature data loggers, car key fobs and defibrillators.
- Lithium-ion batteries (sometimes abbreviated Li-ion batteries) are a secondary (rechargeable) battery where the lithium is only present in an ionic form in the electrolyte. Also included within the category of lithium-ion batteries are lithium polymer batteries. Lithium-ion batteries are generally used to power devices such as mobile telephones, laptop computers, tablets, power tools and ebikes.
- Power banks. These are portable devices designed to be able to charge consumer devices such as mobile phones and tablets. For the purposes of this guidance document and the IATA Dangerous Goods Regulations, power banks are to be classified as batteries and must be assigned to UN 3480, lithium ion batteries, or UN 3090, lithium metal batteries, as applicable. For carriage by passengers, power banks are considered spare batteries and must be individually protected from short-circuit and carried in carry-on baggage only.
Related 👉 Learn more about the different types of batteries, in particular Li-ion batteries, in this guide: Different Types Of Batteries For Electronic Products (Importer’s Guide)
CPSC Reports indicate incidents have occurred while the product is in use, in storage incl. transport, and during battery charging.
There have been a number of recalls involving lithium-ion batteries / battery packs / battery chargers used in cellular telephones, portable computing products, personal electronic products, and electric scooters (hoverboards).
There have also been a number of recalls involving other types of batteries used in products such as battery-powered ride-on toys and portable battery-powered tools.
Potential hazards include overheating, fire, electrical shock from battery chargers, thermal burns, exposure to alkaline battery electrolytes, and high-velocity ejected internal components of batteries.
3. Product safety
Other than the near universal standard industry practice and market-based demands for listing and recognition of cells and batteries as components and end-products, there are no mandatory requirements for lithium battery safety testing. This applies to UL, IEC, IEEC and the like.
Regardless, because product safety is important (brand image, liability, etc.) and because passing safety certifications are one means of assuring products are safe, the practice of testing to UL, IEC, IEEC etc. is both routine and assumed by most consumers.
International Organizations and their Battery Safety Standards
- Underwriters Laboratories (UL)
UL is an independent product safety certification organization which, in conjunction with other organizations and industry experts, publishes consensus-based safety standards. For lithium batteries, key standards are:
- UL 1642 (Lithium Batteries) – This standard is used for testing lithium cells. Battery level tests are covered by UL 2054.
- UL 2054 (Household and Commercial Batteries) – For lithium batteries, UL 2054 defers all component cell level testing to UL 1642.
- UL 2580 (Batteries for use in Electric Vehicles)
- The International Electrotechnical Commission (IEC)
IEC is a non-profit standards organization that writes International Standards for all electrical, electronic and related technologies. IEC standards address general, safety, and transportation specifications. For lithium batteries, key standards are:
- IEC 62133 (Secondary Cells and Batteries containing Alkaline or other Non-Acid Electrolytes – Safety Requirements for Portable Sealed Secondary Cells, and for Batteries made from them, for use in Portable Applications)
- IEC 60086-4 (Primary Batteries – Safety of Lithium Batteries)
- IEC 61960 (Secondary Cells and Batteries containing Alkaline or other Non-Acid Electrolytes – Secondary Lithium Cells and Batteries for Portable Applications)
- IEC 62281 (Safety of primary and secondary lithium cells and batteries during transport) This standard is similar to UN/DOT 38.3.
- The Institute of Electrical and Electronics Engineers (IEEE)
IEEE is an international non-profit organization covering technologies related to electricity and develops safety standards for the industry, including batteries. For lithium batteries, key standards are IEEE 1725 and IEEE 1625 both of which are design guidelines, not pass/fail safety standards:
- IEEE 1725 (Rechargeable Batteries for Cellular Telephones)
- IEEE 1625 (Rechargeable Batteries for Multi-Cell Mobile Computing Devices)
The Cellular Telephone Industries Association (CTIA), also known as the Wireless Association, is an international trade group that certifies compliance with IEEE 1725 and IEEE 1625 standards.
CTIA has taken IEEE 1625 and 1725 standards and generated pass/fail criteria in order to convert IEEE’s safety guidelines into something quantifiable and certifiable. In addition, CTIA is currently developing an industry standard method for measuring battery life in smartphones.
Through their CATLs, the CTIA also manages a program to permit operators and their suppliers to validate Li-ion battery compliance with the IEEE Standards 1725 and 1625.
- SAE International
SAE International (Society of Automotive & Aerospace Engineers) is a professional organization for the aerospace, automotive, and commercial vehicle industries. SAE develops standards for engineering professionals. With hybrid and fully electric vehicles now entering the marketplace in large numbers, the need for battery standards is getting greater attention.
Key SAE standards for lithium batteries include:
- SAE J 2929 (Electric and Hybrid Vehicle Propulsion Battery System Safety Standard – Lithium -Based Rechargeable Cells)
- SAE J 2464 (Electric and Hybrid Electric Vehicle Rechargeable Energy Storage System (RESS) Safety and Abuse Testing)
4. Transport safety
The UN (United Nations) issues recommendations for the transport of dangerous goods worldwide, and the U.S. DOT (United States Department of Transportation) defines shipping regulations for the U.S. under 49 CFR, Sections 100 – 185. Section 173.185 specifically addresses specifications and exceptions and packaging for lithium ion batteries; section 172.101 covers shipping.
Together, the UN and DOT guidelines define test requirements for the safe packaging and shipment of lithium metal and lithium ion batteries. Safety test criteria are defined in the “Recommendations on the Transport of Dangerous Goods, Manual of Tests and Criteria, Part III, Section 38.3.”
- UN/DOT 38.3 (also known as the T1-T8 Tests and UN ST/SG/AC.10/11/Rev. 5). Covers transportation safety testing for all lithium metal and lithium ion cells and batteries. The test criteria span 8 different tests (T1 – T8) that are all focused on hazards associated with transportation.
- UN/DOT 38.3 is a self-certify standard. Independent third party test lab certification is not required. However, because of potential liability issues, most companies choose to use third-party test labs.
Classifying Li-ion Batteries
This flowchart helps classify Lithium metal batteries which have passed UN/DOT 38.3 and will help you to understand how they may be transported, which labelling should be used, and which regulations they are bound by:
Classifying Lithium Metal Batteries
This flowchart helps classify Lithium metal batteries which have passed UN/DOT 38.3 and will help you to understand how they may be transported, which labelling should be used, and which regulations they are bound by:
Battery Hazard Classes
You can see the different hazard classifications (defined by UPS in this chart) for battery types being shipped here:
Note how Li-ion batteries, which are extremely popular for use in most of today’s electronic devices, are hazard class 9.
- UN 3090, Lithium metal batteries (shipped by themselves)
- UN 3480, Lithium ion batteries (shipped by themselves)
- UN 3091, Lithium metal batteries contained in equipment or packed with equipment
- UN 3481, Lithium ion batteries contained in equipment or packed with equipment.
NOTE: unless a company intends to be extremely restricted in its options for transporting their lithium batteries (ground transport as Class 9 Hazardous Goods), they will need to certify that their batteries have passed UN/DOT 38.3.
Other organizations in the transportation industry’s Li-ion battery safety regulations
There are several other international organizations serving the transportation industry which have their own lithium ion battery safety regulations. Although these regulations are based on UN/DOT 38.3 and rely heavily on packaging/shipping guidelines provided in 49 CFR sections 173.185 and 172.101, some differences regarding shipping/transportation exemptions and inclusions exist.
Listed here for reference are the major international transportation organizations:
- PHMSA (Pipeline and Hazardous Materials Safety Administration, U.S. DOT) – PHMSA is the Pipeline and Hazardous Materials Safety Administration of the U.S. Department of Transportation, which develops regulations for transport of dangerous goods by all modes within the U.S.
In March 2019, the Pipeline and Hazardous Materials Safety Administration (PHMSA) adopted an Interim Final Rule (IFR) generally harmonizing the 49 CFR with the ICAO Technical Instructions, so the 2016 restrictions now apply to all air transport within the United States, as well.
- IATA (International Air Transport Association) – IATA is the International Air Transport Association. It is a global trade organization that develops commercial standards and publishes the Dangerous Goods Regulations, containing standards for the transport of dangerous goods by air. IATA’s Dangerous Goods Regulations are based on the International Civil Aviation Organization (ICAO) Technical Instructions for the Safe Transport of Dangerous Goods by Air. ICAO is the United Nations body with jurisdiction over international aviation issues.
IATA released IATA Lithium Battery Shipping Guidelines for their users with amendments and corrections to the 8th Edition, effective from 1 January 2021.
According to the IATA, Lithium ion batteries packed by themselves (Packing Instruction 965) (not contained in or packed with equipment):
(a) must be shipped at a state of charge (SoC) not exceeding 30% of their rated capacity. Cells and/or batteries at a SoC of greater than 30% may only be shipped with the approval of the State of Origin and the State of the Operator under the written conditions established by those authorities, see Special Provision A331; and
(b) may be shipped as cargo on a passenger aircraft under an approval issued by the authority of the State of Origin, State of Destination and State of the Operator where the lithium ion cells or batteries that meet the quantity limits, or in the case of urgent medical need, one consignment of lithium batteries may be transported as Class 9 (UN 3480) on passenger aircraft with the prior approval of the authority of the State of origin and with the approval of the operator, see Special Provision A201. All other lithium ion cells and batteries can only be shipped as cargo on a passenger aircraft under exemption issued by all States concerned.
- ICAO (International Civil Aviation Organization)
- IFALPA (International Federation of Air Line Pilots’ Associations)
- IMDG Code (International Maritime Dangerous Goods code)
Shipping standalone Li-ion & Lithium metal batteries by air
It is possible to ship standalone consignments of Li-ion batteries by air, as per PHMSA guidance:
- Lithium ion cells and batteries to be shipped at not more than a 30 percent state of charge aboard cargo-only aircraft when not packed with or contained in equipment.
- Not more than one package of standalone lithium-ion batteries prepared in accordance with Packing Instruction 965 or 968 Section II per consignment.
- Lithium ion or metal batteries packed with or contained in equipment that are prepared under Section II of IATA Packing Instructions 966, 967, 969, or 970 in individual packages that are in compliance with the regulations may be consolidated within an overpack.
- Must display a ‘cargo aircraft only’ label.
- Damaged, defective, or recalled lithium ion batteries must not be transported by air. They may be transported by ground instead.
Lithium metal batteries are also restricted for air transport:
“Lithium metal batteries packed by themselves (not contained in or packed with equipment) (Packing Instruction 968) are forbidden for transport as cargo on passenger aircraft). In accordance with Special Provision A201, lithium metal cells or batteries that meet the quantity limits of Section II of PI 968 may be shipped on a passenger aircraft under an approval issued by the authority of the State of Origin, State of Destination and State of the Operator. Or in the case of urgent medical need, one consignment of lithium batteries may be transported as Class 9 (UN 3090) on passenger aircraft with the prior approval of the authority of the State of origin and with the approval of the operator, see
Special Provision A201. All other lithium metal cells and batteries can only be shipped on a passenger aircraft under exemption issued by all States concerned.“ (Source)
Labelling air shipments of Lithium-ion or metal batteries within equipment
UPS provides a useful labelling guide for the air shipments of devices containing Lithium-ion or Lithium metal batteries. A good point to note is that the labelling was updated for 2019:
For fully regulated shipments, the Class 9 Lithium Battery label is required. Note that the new label is mandatory from 01 January, 2019:
Shipping various lithium batteries by ground
Additional weight and labeling requirements apply to ground shipments of lithium batteries in the U.S. The requirements differ depending upon what type of lithium battery you are shipping (lithium ion or lithium metal) and whether you are shipping batteries packed without equipment, batteries packed with equipment, or batteries contained in equipment.
Packages must be marked with the following statements in letters at least 6 mm tall which denotes which type of Lithium battery is being shipped, or use the cargo aircraft only label:
- LITHIUM METAL BATTERIES – FORBIDDEN FOR TRANSPORT ABOARD PASSENGER AIRCRAFT
- PRIMARY LITHIUM BATTERIES – FORBIDDEN FOR TRANSPORT ABOARD PASSENGER AIRCRAFT
- LITHIUM ION BATTERIES – FORBIDDEN FOR TRANSPORT ABOARD PASSENGER AIRCRAFT
- OR, use this label:
When shipping almost any battery, you must protect all terminals against short circuits that can result in fires. Protect terminals by completely covering them with an insulating, non-conductive material (e.g., using electrical tape or enclosing each battery separately in a plastic bag), or packing each battery in fully enclosed inner packaging to ensure exposed terminals are protected.
- Package the batteries to keep them from being crushed or damaged, and to keep them from shifting during handling.
- Always keep metal objects or other materials that can short circuit battery terminals away from the batteries (e.g., using a separate inner box for the batteries).
5. Packing Restrictions & Safety Tips
Packing instruction 965 & 968 sections IA and IB state:
“UN 3090, lithium metal batteries prepared in accordance with Section IA or Section IB of PI 968 and UN 3480, lithium ion batteries prepared in accordance with Section IA or Section IB of PI 965 must not be packed in the same outer packaging with dangerous goods classified in Class 1 (explosives) other than Division 1.4S, Division 2.1 (flammable gases), Class 3 (flammable liquids), Division 4.1 (flammable solids) or Division 5.1 (oxidizers). Packages containing cells or batteries must not be placed in an overpack with packages containing dangerous goods classified in Class 1 other than Division 1.4S, Division 2.1, Class 3, Division 4.1 or Division 5.1.”
PI 965 & PI 968 Section II state:
“Cells and batteries must not be packed in the same outer packaging with other dangerous goods.
Shippers are restricted to offering one package per consignment. Packages and overpacks must be offered to the operator separately from other cargo and must not be loaded into a unit load device before being offered to the operator.”
How do I safely package lithium batteries for transport?
One of the major risks associated with the transport of batteries and battery-powered equipment is short-circuiting of the battery as a result of the battery terminals coming into contact with other batteries, metal objects, or conductive surfaces. Packaged batteries or cells must be separated in a way to prevent short circuits and damage to terminals. They must be packed in a strong rigid outer packaging unless when contained in equipment, the battery is afforded equivalent protection by the equipment in which it is contained. Sample packaging meeting these requirements is shown below:
How can batteries be effectively protected against short circuit?
Methods to protect against short circuit include, but are not limited to, the following methods: a. Packing each battery or each battery-powered device when practicable, in fully enclosed inner packagings made of non-conductive material (such as a plastic bag);
b. Separating or packing batteries in a manner to prevent contact with other batteries, devices or conductive materials (e.g. metal) in the packagings;
and c. Ensuring exposed terminals or connectors are protected with non-conductive caps, non-conductive tape, or by other appropriate means.
If not impact resistant, the outer packaging must not be used as the sole means of protecting the battery terminals from damage or short-circuiting. Batteries should be securely cushioned and packed to prevent shifting which could loosen terminal caps or reorient the terminals to produce short circuits.
Terminal protection methods include but are not limited to the following: a. Securely attaching covers of sufficient strength to protect the terminals; b. Packaging the battery in a rigid plastic packaging; and c. Constructing the battery with terminals that are recessed or otherwise protected so that the terminals will not be subjected to damage if the package is dropped.
6. Compliance recommendations from US CPSC
CPSC recommends that:
- Components and battery-powered products comply with applicable safety standards, be it voluntary or otherwise
- New components and products that are not yet subject to voluntary standards be designed considering the best practices from similar voluntary standards;
- Battery-powered products are designed with a system approach addressing thermal protection, charge and discharge protection, and use in the product, including:
- Cells suitable for intended loads and conditions and manufactured with good quality control
- Battery packs with proper Battery Management Systems, including charge control, short-circuit protection and cell balancing
- Chargers that comply with applicable voluntary standards and are suitable for product/fit for purpose
- End-product systems (including cells, batteries, chargers, and product) are tested together for safe function under all reasonably foreseeable use conditions
7. Lithium ion battery safety in practice following a 3-step decision-making process
Decision 1. – UN/DOT 38.3
Should you self-certify or use an independent third-party testing lab?
- Using a third-party lab helps to mitigate liability should an incident occur
- If using a third-party test lab, it is best if the lab is ISO/IEC 17025 accredited, and approved by OSHA as a Nationally Recognized Testing Laboratory (NRTL)
- Whichever option you choose, all levels must be tested – cells, modules, and packs
Decision 2. – Cell testing
Is cell testing necessary? If yes, which standard should you use?
NOTE: It is highly likely that cells are already tested to UL 1642 and certified/listed by a third-party laboratory. Typically, new cell designs are certified/listed by the cell manufacturer and battery certification is the responsibility of the end-user / application device manufacturer.
- Cell listing for U.S. markets typically use UL1642
- For Battery certification, UL 2054 applies
NOTE: For lithium batteries, UL 2054 Section 2.1 (Lithium Cells) internally references UL 1642 for the cell level test requirements.
- The European-based IEC 62133 is rapidly becoming a global standard
- IEC 62133 is required for battery certification through the CB Scheme
- Although ANSI C18 is U.S.-based, third-party certification/listing (i.e. ETL Certification) to UL standards is more universally applied for lithium battery safety.
Decision 3. – Battery certification
Depending on your market needs, consider one of the following:
- UL 2054 (for general battery safety certification; global recognition and acceptance)
- IEC 62133 (for Europe and CB Scheme certification)
- SAE J2464 / J2929 (for Electric and Hybrid Vehicles; other standards for Light Electric Vehicles)
NOTE: Consider using application specific standards where these exist i.e. for medical devices, power tools, etc.
8. Source documents
US CPSC brief on Batteries
United Nations recommendations on the transport of dangerous goods https://www.unece.org/fileadmin/DAM/trans/danger/ST_SG_AC.10_11_Rev6_E_WEB_-With_corrections_from_Corr.1.pdf
Title 49 of the Code of Federal Regulations – Wikipedia page https://en.wikipedia.org/wiki/Title_49_of_the_Code_of_Federal_Regulations
IATA 2018 Lithium Battery Guidance Document https://www.iata.org/whatwedo/cargo/dgr/Documents/lithium-battery-guidance-document-2017-en.pdf
FedEx guidelines on Lithium Ion batteries shipments https://www.fedex.com/content/dam/fedex/us-united-states/services/LithiumBattery_Overview_2018.pdf
Intertek brief “Navigating the regulatory maze of lithium battery safety” http://batterypoweronline.com/wp-content/uploads/2013/11/Intertek_Regulatory-Maze-WP.pdf
UPS shipping guide for batteries
IATA Transport of Lithium Metal and Lithium Ion Batteries Revised for the 2021 Regulations
INTERNATIONAL CIVIL AVIATION ORGANIZATION SUPPLEMENT TO THE TECHNICAL INSTRUCTIONS FOR THE SAFE TRANSPORT OF DANGEROUS GOODS BY AIR 2015-2016 EDITION
PHMSA Hazardous Materials: Enhanced Safety Provisions for Lithium BatteriesTransported by Aircraft (FAA Reauthorization Act of 2018)
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