Shipping Lithium Batteries by Air

Robert Smith | March 16, 2014 | Dangerous Goods/Hazmat, Export Compliance
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Shipping Lithium Batteries by Air | Shipping SolutionsAccording to current estimates, global manufacturers produce more than four billion lithium batteries every year. We use them extensively in all facets of our lives, and I personally can't imagine living without some of the gadgets they power.

As demand for lithium batteries has grown, so has concern about their safety. Regulators are closely examining all procedures for shipping these batteries. Why? Some battery consignments have overheated and caught fire. Once ignited, they can cause other nearby batteries to overheat and catch fire as well. These fires are very difficult to put out and produce toxic and irritating fumes.

When shipping lithium batteries, it is not always clear which mode of transport will be used. Your shipment may end up on an aircraft, and some aircraft fire suppression systems may be unable to extinguish all types of lithium battery fires. Evidence of this came with catastrophic and tragic results when both crew members of a UPS flight were killed when their 747-44AF crashed on September 3, 2010, near Dubai. Accident investigators traced the cause to a fire involving a variety of lithium batteries being carried as cargo. Correctly shipping these pervasive energy sources, especially by air, is becoming more complicated and often overlooked by shippers.

Counterfeit and no-brand lithium batteries are also of concern, because they may not have been safety tested. These lithium batteries may be poorly designed, have little protection, or contain manufacturing flaws. It is mandatory that all cells and batteries, and each subsequent re-configuration, be tested and pass the UN Manual of Tests and Criteria Part III Subsection 38.3 before they can be shipped. The regulations also forbid transport of batteries that have been identified by the manufacturer as being defective, damaged, or have the potential of producing a dangerous evolution of heat, fire or short circuit (e.g. those being returned to the manufacturer for safety reasons).

The name, lithium battery, is actually a general term and, depending on their chemistry, come in two distinct formats. Without getting too technical, they can come as either singular cells or as a combination of cells, which are considered batteries. While there are distinct differences between the two, let's just call them both batteries for the purposes of this article.

Lithium primary batteries are non-rechargeable and have lithium metal or lithium compounds as the anode. Due to their fully charged nature, shipping these batteries is very restrictive and the U.S. Federal Aviation Administration (FAA) forbids them as cargo on passenger aircraft to, from or through the U.S. The International Civil Aviation Organization's Dangerous Goods Panel is currently reviewing this restriction and is considering implementing it worldwide.

The other more popular form is lithium-ion (or Li-ion) batteries where a lithium gel or polymer is the key energy source. Because of this chemistry, they can be recharged.

Regardless of their format, with a few exceptions, all lithium cells and batteries are regulated for transport as Class 9, Miscellaneous Dangerous Goods. Each consignment containing lithium batteries must be accompanied with a document that indicates that the package contains lithium cells or batteries (primary or rechargeable) and must be handled with care. It also must indicate that a flammability hazard exists if the package is damaged; special procedures including inspection and repacking must be followed in the event the package is damaged; and a telephone number for additional information.

Complicating things further is the particular form in which the batteries are shipped. Both formats can be shipped alone, packed with equipment, contained in equipment, or possibly a mixed combination of these different forms. So we actually have six basic proper shipping names

  • UN3090, Lithium metal batteries
  • UN3480, Lithium ion batteries
  • UN3091, Lithium metal batteries contained in equipment
  • UN3481, Lithium ion batteries contained in equipment
  • UN3091, Lithium metal batteries packed with equipment
  • UN3481, Lithium batteries packed with equipment

Fully regulated lithium batteries contain more than two grams of lithium, and fully regulated lithium-ion batteries have a watt-hour rating higher than 100 watt-hours.

In order to ship these correctly by air, the batteries must have been tested and pass the UN Manual of Test and Criteria. A shipper must have received dangerous goods training to ensure that they know the proper classification and limits on the net quantity of lithium batteries per package. These details are indicated in the International Air Transport Association’s (IATA) Dangerous Goods Regulations (DGR) Part 4.2 as well as the applicable packing instructions. Appropriate UN tested specification packaging must be used, and the package must be marked and labeled according to the applicable specific requirements. A safety document must accompany the consignment, and a Shipper's Declaration for Dangerous Goods must accompany the air waybill.

All of these requirements also apply to fully regulated batteries packed with equipment. When fully regulated batteries are shipped contained in equipment, the UN performance testing for the package is not required, but the equipment must be packed in strong outer packagings made of suitable material of adequate strength and design in relation to the packaging's capacity and its intended use unless the battery is afforded equivalent protection by the equipment in which it is contained. At this point U.S. shippers of primary lithium metals batteries must be very careful to adhere to the more stringent Department of Transportation (DOT) restrictions for passenger carrying aircraft.

There are some exceptions, but unless a shipment is labeled for cargo aircraft only, every shipment must have "LITHIUM METAL BATTERIES—FORBIDDEN FOR TRANSPORT ABOARD PASSENGER AIRCRAFT" clearly marked on the outside of every package regardless of the shipping mode.

Depending on the amount of lithium or the strength of the cell or battery, there are exceptions for small lithium batteries. Primary metal batteries that include two grams or less of lithium or lithium-ion with a rating less than 100 watt-hours have less stringent requirements. The typical laptop battery, for example, has a rating around 60 watt-hours and qualifies for applying the exception for lithium-ion battery contained in equipment. These include a maximum limit of two batteries per non-specification packaging; no hazard label, only a lithium-ion battery handling label; and no dangerous goods declaration. There is also no maximum quantity per package when cells have a rating of 2.7 watt-hours or less and the total weight of the package does not exceed 2.5 kilograms.

Along with all the exceptions that can be applied, there are numerous special provisions that may apply to a shipment such as the limitations on shipping untested prototypes or the detailed requirements for large batteries that weigh greater than the 35-kilogram cargo aircraft limit. A very important one is Special Provision A164, which specifies packing requirements designed to prevent accidental activation and short circuiting.

This article is by no means an all-inclusive summary of all the details required to ship lithium batteries. Suffice it to say, shipping these types of cells and batteries is not something that anyone can take lightly. They are regulated for obvious reasons, and I strongly recommend shippers review their shipping department's awareness of this. Far too often during one of my training sessions I have discovered that a client occasionally ships a laptop or piece of equipment containing a lithium battery completely unaware it is regulated. They are regulated, and due diligence and training are essential.