Editor's note: The following article is intended as general information only and is not legal advice. If you have questions concerning legal requirements for shipping lithium batteries or other matters, consult an attorney.
Wherever you look these days, there’s a device powered by a lithium battery. From cell phones and hearing aids to electric vehicles and laptops, lithium batteries are literally everywhere.
No surprise then that demand for shipping lithium batteries is huge. But there’s a catch—these batteries have the potential to be dangerous. If a battery short-circuits or otherwise malfunctions, it may overheat and cause damage. It may even risk a chain reaction, in which surrounding lithium batteries catch fire.
The concern is real. That’s why safety is always top priority when transporting lithium batteries.
Here are nine essential things to keep in mind when preparing to ship lithium batteries for the first time:
Incidents with lithium batteries happen more frequently than you may think, according to Antonio Gonzalez, UPS Manager, Regulated Goods.
In 2019, the Federal Aviation Administration reported 45 “events with smoke, fire, extreme heat or explosion, involving lithium batteries" and U.S. passenger or cargo flights.
And it’s not just larger batteries that are to blame. Incidents stem from a range of devices, from small lithium batteries in cell phones and laptops to bigger units and power tools.
Understandably, the authorities take these events seriously. In the United States, any lithium battery incident involving an evolution of heat must be reported. This triggers formal investigations by the relevant enforcement agencies within the Department of Transportation (DOT).
When shipping lithium batteries, the shipper is responsible for ensuring strict compliance with the regulations.
To be clear, the shipper is the entity responsible for packaging and sending the goods. It shouldn’t be confused with the carrier, such as UPS, which is responsible for transporting them.
“Lithium batteries are a regulated commodity that requires the shipper to comply with the framework of regulations governing that transportation,” explains Gonzalez.
In the interests of public safety, shippers must take these regulations seriously. Failure for the shipper to comply has consequences. Carriers like UPS routinely reject lithium battery shipments for failing to properly follow the rules.
According to Gonzalez, the shipper’s primary responsibilities fall into three areas:
Every configuration of lithium battery shipments—from the most complex to the most straightforward—requires the shipper (that is, the person preparing the package for transportation) to undergo training.
Dangerous goods training covers a range of areas, including, but not limited to:
*Carriers, such as UPS, cannot classify your dangerous goods. The shipper should work with the Safety Data Sheet and manufacturer of their commodity for proper classification.
There are two levels of training available to the lithium battery community:
Regarding the second category, Gonzalez sounds a note of caution. "Shippers should understand that ‘lightly regulated’ is not a formal term,” he says. “Every lithium battery is regulated. There's a big misconception you'll hear a lot in the industry that their batteries are not regulated as hazmat."
Fortunately, training options are numerous. Shippers may run in-house training if they have the internal expertise, or they can outsource it to a third-party provider.
UPS offers its own Dangerous Goods Seminar. "The benefit of training with your carrier of choice is that you also get training on that carrier's variations and other carrier-specific restrictions," Gonzalez says.
When shipping lithium batteries, safety is the name of the game—and that is particularly true of packaging. Lithium batteries must be packed and prepared in a way that mitigates the risk of short circuiting and other malfunctions.
There are at least 16 possible packaging configurations for lithium batteries, depending on the shipment, according to Gonzalez. Shippers must be trained on the configurations to understand what is correct.
"A shipper has to ask a bunch of questions about what kind of battery they’re shipping, how many batteries there are, the size of the battery, whether it’s shipped by itself, contained in equipment or packed alongside equipment, to determine which of these 16 configurations it will fall in," he says.
Among various stipulations, the packaging regulations outline requirements for:
While the regulations lay out minimum packaging requirements, dangerous goods training helps a shipper understand how to apply those requirements in practice.
Getting the communications correct on lithium battery shipments is critical.
Dangerous goods training covers the required communications for different shipment configurations, including requirements for ‘lightly regulated’ shipments.
These communications may range from “Class 9” labels and “Cargo Aircraft Only” markings to a specific United Nations reference number and proper shipping name.
Carriers are not legally permitted to transport packages that are inaccurately or incompletely marked and labeled. Failure to meet compliance in this area can trigger an enforcement agency investigation.
A carrier variation is the legal right of an entity to be more restrictive than the law.
In some instances, certain types of lithium battery shipments that are technically permitted under international regulations are not accepted by carriers. Get to know the variations for your carrier of choice.
In addition to carrier variations, dangerous goods shippers should be aware of any country-level variations (known as “state variations”) that may be in force. In the United States, domestic transportation of dangerous goods is governed by Title 49 CFR rules.
Failure to meet dangerous goods training requirements is the most cited violation in the United States of the rules governing the shipping of dangerous goods, Gonzalez says.
Other frequent mistakes include failure to provide a phone number on the packaging or incorrectly filling out the “Lithium Battery Marking.”
"Another common one is obstructing the label. That happens not only manually when another sticker or communication—typically the shipping label—partially obstructs the lithium battery mark, but it’s very common in automated systems,” explains Gonzalez.
The most serious error is an undeclared shipment, otherwise known as “Hidden Dangerous Goods.” This is where someone places lithium batteries into a package—knowingly or not—without declaring their presence.
When discovered, it is a reportable incident and triggers agency investigation, with the potential for heavy fines.
To start shipping lithium batteries, the shipper must first meet the relevant regulatory training requirements. In the United States, these are laid out in U.S. Title 49 Subpart H of the Code of Federal Regulations.
Completing the required training is the first step to the safe and compliant shipping of lithium batteries.
Once certified, the shipper can apply for a UPS Dangerous Goods Account. This requires having a UPS payment account in place and agreeing to the UPS Hazardous Materials Contract Service. (Work with your UPS sales representative to confirm that you require a UPS Dangerous Goods agreement before tendering lithium batteries.)
It remains the shipper’s responsibility to classify goods and compliantly prepare goods for shipping.
The development of lithium batteries is as dynamic as the community underpinning it.
Lithium battery design is constantly evolving to make batteries safer, more efficient, and less prone to thermal events.
In this fast-moving environment, the regulations governing lithium battery transportation remain under close review at any given time. As a shipper of lithium batteries, it’s important to pay attention to changes in the regulatory landscape and to stay as current as the batteries themselves.
Fortunately, there’s a wide range of resources at your disposal, from those offered by the Federal Aviation Administration and the International Air Transport Association (IATA) to carrier-specific resources on lithium battery shipping.
In addition, these industry groups may offer helpful information and support:
Understanding how to ship lithium batteries compliantly takes time and training. But with the right preparation and a strong commitment to safety, you will find your feet. To help you on this journey, partner with a trusted carrier like UPS for support with your lithium battery shipping needs.
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