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Policy & Compliance
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Understanding the complexities of lithium A thorough understanding of lithium batteries is a prudent step for everyone involved in their transport. As well as the safety aspect, ill-informed enquiries and additional documentary demands for such shipments can cause delays and frustration
Lithium as a substance – and indeed lithium batteries – was until around the mid-1980s classified for dangerous goods regulations under Class 4.3 (Substances which, in contact with water, emit flammable gases). Experts and regulators were persuaded that smaller batteries present reduced hazards compared
articles) on the basis that lithium batteries do not constitute a ‘substance’, rather they are ‘articles’. In normal use, of course, one would not encounter the lithium contained within a battery.
Special Provision 188 (SP188) While recognising that there are
various special provisions applicable to lithium batteries, the focus here is on one alone. On the basis that smaller lithium batteries present a reduced hazard, within the UN regulations SP188 exists to enable transport under specific conditions. Where lithium batteries or cells meet these requirements, when offered for transport they are not subject to other provisions of the ADR/IMDG code. Notwithstanding qualification for transport under SP188, however, these batteries continue to be dangerous goods, presenting the same risks, rather on a smaller scale. The qualifying criteria under SP188 starts by considering weight and energy content, specifying maximum weights and energy content for both lithium metal and lithium ion cells and batteries. The requirements proceed to focus on protection of the cell or battery, specifying the required packaging and considering protection from the risks of short circuit, particularly where cells or batteries are contained within equipment. Each package containing qualifying lithium batteries must, with certain exceptions, be marked with the appropriate lithium battery mark. An important point to raise here is that because those lithium batteries qualifying under SP188 are not subject to other provisions of ADR/IMDG, beyond the marking of the packages (externally invisible once packed in a freight container), there is no requirement to notify the carrier specifically of the contents. Cells and batteries that are not satisfying the requirements set out under SP188 are fully
with their larger counterparts through the supply chain. Therefore, the criteria for classification was redesigned around the weight and power outage of the cell or battery. Consequently, lithium ion batteries are classified by the equivalent energy content in watt-hours (Wh), while lithium metal/alloy batteries are classified by the weight of lithium content in grams. There are four different UN numbers for the classification of lithium cells or batteries based on defined thresholds, being: • Cells – for lithium metal/alloy cells, the lithium content is not more than 1 gram, and for a lithium ion cell, the watt-hour rating is not more than 20 Wh; • Batteries – for a lithium metal or lithium alloy battery, the aggregate lithium content is not more than 2 g, and for a lithium ion battery, the Watt-hour rating is not more than 100 Wh. The UN numbers are: • 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.
regulated for transport. Accordingly, such shipments must be declared and shipped as dangerous goods under the applicable UN number. Where there is absent inspection or incident, bad actors will recognise that the likelihood of being caught mis-declaring is remote. Supply chain relationships are often complex, but actors need to be aware where liability may rest and undertake effective due diligence on counterparties and the presented cargo. Requesting a copy of the actual shipper’s Statement of Compliance could provide a useful check point in this process. Importance of advances Technological advances should logically result in a review of classification. Lithium batteries have continued to decrease in size and weight, while being able to deliver increasing energy output through more efficient use of the active content. Advances in technology mean that lesser performing batteries could still qualify for
These are included within Class 9 (Miscellaneous dangerous substances and
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April 2022
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