UN38.3 and ADR: Common Shipping Mistakes for Lithium Metal Battery Transportation

Lithium battery transportation for safety is a complex regulatory landscape where even a minor oversight in documentation or packaging can lead to costly terminal delays or severe safety hazards.

You face fines, returns, and delays when regulations are not followed. The cost of mistakes can shut down your supply chain. But these problems can be avoided with the right knowledge and preparation.

Lithium battery transportation requires strict compliance with UN38.3 testing and ADR regulations. Common mistakes include incomplete documentation, improper packaging, incorrect labels, and failure to meet transport-specific requirements.

These errors lead to shipment rejection, legal penalties, and safety risks during transit.

While the high energy density of lithium metal chemistries like Li-SOCl₂ and Li-MnO₂ makes them indispensable for industrial applications, it also classifies them as Class 9 Dangerous Goods, subject to stringent international mandates.

Understanding these regulations is not just about avoiding problems. It’s about protecting your business and ensuring safe delivery. Let’s explore what you need to know.

Table of Contents

• What Are UN38.3 and ADR Requirements for Lithium Battery Transportation?
• What Documentation Errors Happen Most Often?
• How Do Packaging Mistakes Lead to Shipment Rejection?
• Why Do Labeling Errors Cause Transportation Delays?
• What Classification Mistakes Should You Avoid?
• Bonus: Key Regulatory Requirement Lists for Lithium Metal Battery

What Are UN38.3 and ADR Requirements for Lithium Battery Transportation?

UN38.3 is a testing standard that verifies lithium batteries can safely withstand transport conditions. ADR governs road transport of dangerous goods in Europe. Both require specific testing, documentation, packaging, and labeling.

Compliance with these regulations ensures batteries can be legally shipped and prevents accidents during transit.

The relationship between UN38.3 and ADR creates a framework that protects everyone in the supply chain.

UN38.3 testing proves your batteries meet safety standards through eight rigorous tests.

These tests check altitude simulation, thermal conditions, vibration, shock, external short circuit, impact, overcharge, and forced discharge. Every battery must pass before shipping.

ADR takes this further by setting rules for how batteries move on roads.

The regulation covers packaging requirements, vehicle specifications, driver training, and emergency procedures.

When you ship lithium thionyl chloride batteries or other lithium metal batteries, both standards apply together.

Many manufacturers misunderstand the scope of these requirements.

UN38.3 is not just for manufacturers. Everyone in the supply chain must maintain proper documentation.

ADR compliance is not optional for European transport. The penalties for non-compliance include immediate shipment rejection and fines up to €50,000 per incident.

Key Regulatory Requirements Comparison

Different transport modes require different standards.

IMDG covers sea transport while IATA handles air transport. But UN38.3 applies to all modes.

This creates confusion for new shippers who think they only need one certificate. You need to understand which regulations apply to your specific shipping route and method.

At Long Sing Industrial, we see companies struggle with this complexity every day.

The good news is that proper preparation prevents most problems. The challenge is knowing exactly what to prepare and how to maintain compliance across multiple shipments and destinations.

What Documentation Errors Happen Most Often?

Missing or incomplete UN38.3 test summaries cause most documentation rejections. Shippers often provide expired certificates, incorrect battery specifications, or fail to include transport documents.

Each shipment needs a complete test summary, material safety data sheet (MSDS), dangerous goods declaration, and packing certificate to meet shipping lithium batteries requirements.

The UN38.3 test summary is your passport for transporting batteries. This document must include specific details about the battery model, test results, and test facility information.

Many companies make the mistake of using generic templates. Carriers reject these immediately because they lack required specifics like exact lithium content and watt-hour ratings.

Expired documentation creates another major problem.

UN38.3 certificates do not expire, but test procedures change. Batteries manufactured more than two years ago may need retesting under updated standards.

This catches many manufacturers by surprise when customs officials reject their shipments.

The dangerous goods declaration is where errors multiply. This form requires precise technical language and proper hazard class identification.

Common mistakes include wrong UN numbers, incorrect shipping names, and missing emergency contact information.

For lithium metal batteries, the UN number is UN3090 for batteries alone or UN3091 for batteries packed with equipment. Using the wrong number can reroute your entire shipment.

Required Documentation Checklist

Language barriers create additional documentation problems. Documents must be in the language of the origin country and the destination country.

A shipment from China to Germany needs documentation in both Chinese and German. Many shippers only provide English versions, which slows customs clearance.

Digital versus paper documentation is another area of confusion.

Some countries accept electronic documents while others require original signatures on paper.

The transportation of lithium batteries across borders means you must know each country’s specific requirements. This is where a specialized freight forwarder becomes valuable.

We work with clients who have faced returned shipments due to documentation errors.

The pattern is always the same. They rushed the paperwork, used old templates, or assumed one document covered all requirements.

Taking time to verify every document before shipping saves weeks of delays and thousands in return shipping costs.

How Do Packaging Mistakes Lead to Shipment Rejection?

Improper packaging fails to protect lithium batteries from damage and fire risks during transport.

Common errors include using non-approved containers, insufficient cushioning, exceeding quantity limits per package, and improper terminal protection.

Correct packaging must meet ADR Section II requirements and prevent short circuits through proper insulation and separation.

Packaging is your first line of defense when transporting lithium batteries.

The outer packaging must be rigid and strong enough to withstand normal transport conditions. Cardboard boxes alone rarely meet ADR standards for lithium battery transportation.

You need UN-certified packaging with proper markings and ratings.

Inner packaging creates the most problems.

Each battery or battery pack needs individual protection. Terminals must be protected against short circuits through caps, tape, or individual plastic bags.

We see companies pack batteries loosely in boxes with just bubble wrap. This does not meet regulations and creates serious safety risks.

Quantity limits per package surprise many shippers. ADR sets strict limits on how much lithium content can go in one package.

For lithium metal batteries under Section II, each cell can contain up to 1g of lithium and each battery up to 2g. Exceeding these limits moves you into a different classification with much stricter requirements.

Many lithium manganese dioxide batteries fall into this category.

The 12-inch drop test is mandatory for all packages. Your packaging must survive a drop from this height without battery damage or exposure.

Most standard retail packaging fails this test. You need cushioning that absorbs impact while keeping batteries secure.

Packaging Requirement Levels

Temperature control matters more than most people realize. Batteries must be protected from extreme heat and cold during transport.

This means using temperature-stable packaging materials and considering seasonal shipping routes. Summer shipments through hot climates need extra protection.

Separation requirements prevent different types of dangerous goods from mixing.

You cannot pack lithium batteries with flammable liquids or corrosive materials. Each dangerous good needs its own compartment or package.

This rule catches shippers who try to consolidate multiple products into single containers.

State of charge adds another layer of complexity.

Most regulations require batteries to ship at 30% charge or less. Higher charge levels increase fire risk and may require special approvals.

Many manufacturers ship batteries fully charged without realizing this violates transport regulations.

This applies to both hybrid pulse capacitors and traditional lithium cells.

Why Do Labeling Errors Cause Transportation Delays?

Incorrect or missing labels prevent transport workers from identifying hazards and handling packages properly.

Labels must show the lithium battery mark, UN number, proper shipping name, hazard class 9, and handling instructions. Each transport mode has specific label requirements under IATA, IMDG, and ADR regulations that must be followed exactly.

The lithium battery handling label is mandatory for all shipments. This label shows the distinctive battery symbol with the torn battery mark.

The label must be at least 120mm x 110mm in size with clear black markings on white background. Smaller labels or printed versions that do not meet size requirements will be rejected.

Placement of labels determines whether carriers accept your shipment. Labels must be visible on the outside of packages and oriented correctly.

They cannot be covered by other labels, tape, or shipping information. Corner placement often gets covered during handling, so center placement on the largest face works best.

UN numbers must appear in the correct format.

For lithium metal batteries, UN3090 or UN3091 must be clearly visible. The numbers need to be in letters at least 12mm high. Many shippers print these too small or use fonts that are hard to read.

Carriers will not load packages with unclear or incorrect UN numbers.

Required Label Elements

The Class 9 hazard label shows that batteries are miscellaneous dangerous goods. This diamond-shaped label with black stripes must appear on packages when required.

Section II shipments have different label requirements than Section I shipments.

Many shippers apply all labels to every package, which confuses handlers and can cause problems.

Multiple transport modes require different labels. A shipment that goes by truck then by air needs both ADR and IATA labels.

The challenge is knowing which labels apply at each stage. Remove labels from previous shipments before applying new ones. Old labels from past shipments create confusion and violations.

Emergency response information must be readily available. A 24-hour emergency contact number must be on the dangerous goods declaration. This number needs to reach someone who understands your product and can provide guidance in an emergency.

Using your regular office number that only works during business hours does not meet requirements.

Language requirements for labels vary by region.

In Europe, labels need text in the local language. In North America, English and French may both be required.

We help our clients create multi-language label sets that meet requirements across different shipping destinations.

At Long Sing Industrial, we provide pre-approved label sets for our battery products. This removes the guesswork for customers who need to ship our lithium thionyl chloride batteries.

Proper labels prevent most transport delays and show carriers you understand the regulations.

What Classification Mistakes Should You Avoid?

Misclassifying lithium batteries leads to wrong packaging, incorrect documentation, and regulatory violations. The most common mistakes include confusing lithium metal with lithium-ion, using wrong Section classifications, incorrect state of charge declarations, and failing to account for battery configuration.

Proper classification determines all other shipping requirements.

Battery chemistry determines your base classification.

Lithium metal batteries and lithium-ion batteries have completely different UN numbers and requirements.

Lithium metal batteries use UN3090 or UN3091, while lithium-ion use UN3480 or UN3481. This difference affects every aspect of transporting batteries from packaging to labeling to documentation.

The contained-in versus packed-with distinction creates ongoing confusion. Batteries contained in equipment (installed and not removable) use different UN numbers than batteries packed with equipment (separate but shipped together).

UN3091 covers metal batteries packed with equipment while UN3091 also handles contained in equipment based on the specific packing instruction used. Getting this wrong changes your entire shipping procedure.

Section classification determines your operational requirements. Section IA has the strictest rules and highest costs. Section IB offers some relief while Section II provides the most flexibility.

Many shippers classify everything as Section II to save money, but this only works if batteries truly meet the lithium content limits.

Misclassifying to Section II when you should be Section I creates serious legal liability.

State of charge affects classification for some battery types. Batteries at higher charge levels may require special provisions or different classifications.

Some hybrid pulse capacitors fall into special categories based on their charge state and design. Declaring a fully charged battery as discharged creates a false declaration that can lead to penalties.

Classification Decision Tree

Prototype batteries require special attention. Batteries that have not completed full UN38.3 testing can still ship under special provisions, but they need different documentation and handling.

Many companies try to ship prototypes as regular batteries, which violates regulations. Prototype shipments have quantity limits and require special approval from carriers.

Damaged or defective batteries move into a completely different classification system. These require Special Provision 376 and much more restrictive packaging.

You cannot simply ship damaged batteries using your normal procedures. The classification changes, packaging requirements increase, and not all carriers will accept these shipments.

Mixed shipments create classification challenges. If you ship multiple battery types in one package, you must follow the most restrictive classification requirements.

A package containing both Section I and Section II batteries must meet Section I requirements throughout. This increases costs and complexity, so separating different classifications makes sense.

Temperature-sensitive batteries may need special provisions.

Batteries that require refrigeration or have narrow operating temperature ranges need additional classification considerations. Standard shipping lithium batteries procedures may not apply, and you may need special carrier approval before shipping.

Conclusion

Shipping lithium batteries successfully requires attention to detail across documentation, packaging, labeling, and classification. The common mistakes we have discussed lead to fines, returns, and delays that damage your business relationships and bottom line.

UN38.3 testing proves your batteries meet safety standards, while ADR, IMDG, and IATA provide the transport-specific rules you must follow.

Prevention is always easier than correction. Invest time in understanding requirements before your first shipment.

Work with experienced partners who know lithium battery transportation regulations. Verify every document, inspect every package, and check every label before handing shipments to carriers.

The complexity of transporting lithium batteries across borders and transport modes means expertise matters.

At Long Sing Industrial, we have dedicated global battery transportation agents who solve import and customs clearance challenges for our customers. Our team understands the regulations and helps clients navigate the complexities of shipping lithium batteries worldwide. We provide complete documentation support, approved packaging solutions, and guidance on proper classification for our entire product range.

Contact us to learn how our transportation support services can eliminate shipping mistakes and ensure your batteries arrive safely and on time.

Bonus: Key Regulatory Requirement Lists for Lithium Metal Battery

Lithium batteries are classified as dangerous goods due to fire and thermal runaway risks. Their transportation is therefore governed by international regulations,regional laws, and transport-mode-specific standards.

I. Core International Regulations (Mandatory)

1. UN 38.3 (UN Manual of Tests and Criteria, Part III, Subsection 38.3)

A mandatory safety testing standard required before any lithium battery can be transported commercially. It mainly applies the following products as global baseline requirement:

• Lithium-ion batteries
• Lithium metal (primary) batteries
• Cells and battery packs

2. UN Model Regulations on the Transport of Dangerous Goods

The foundational framework defining classification, packaging, labeling, and documentation. It has the following Un Numbers that applies to All countries adopting UN-based transport rules:

• UN3480 / UN3481 – Lithium-ion
• UN3090 / UN3091 – Lithium metal

II. Transport Mode–Specific Regulations

3. IATA DGR (Dangerous Goods Regulations – Air Transport)

Rules governing lithium battery transport by air which applies to all international air shipments.

It required in all IATA member countries (EU, US, Asia, Middle East) under the following key requirements:

• State of Charge ≤30% (Li-ion, cargo aircraft)
• Strict packaging instructions (PI 965–970)
• Shipper’s Declaration for Dangerous Goods (when applicable)

4. ICAO TI (Technical Instructions)

International civil aviation authority rules; IATA DGR is based on this.

It Required in all ICAO contracting states including South Africa, China, India, Japan, Australia, Singapore, South Korea, Indonesia, Vietnam, all EU countries, UK, USA, Canada, Brazil, etc.

5. IMDG Code (International Maritime Dangerous Goods Code)

Regulates lithium battery transportation by sea. It required in International maritime shipping as global regulartion.

It contains the following key Points when required:

• Dangerous goods declaration
• Marine pollutant classification (if applicable)
• Packaging & segregation rules

6. ADR (European Road Transport)

European agreement governing road transport of dangerous goods. It required in regions like EU + ADR contracting countries (UK, Norway, Switzerland, etc.)

The products that mainly required ADR are special focus on:

• Lithium metal content limits
• Vehicle marking
• Driver training

7. RID (Rail Transport – Europe)

Rail transport equivalent of ADR. It required in EU rail shipments

III. Regional & National Regulations

8. DOT / 49 CFR (United States)

US Department of Transportation regulations for hazardous materials.It mainly required in United States (domestic & export)

9. TDG (Canada)

Transportation of Dangerous Goods Regulations. It mainly required in Canada.

10. GB / JT / Local DG Regulations

Country-specific implementations of UN Model Regulations, such as China(GB / JT standards), Japan(METI / MLIT rules), Korea(MOLIT regulations), etc.

IV. Safety, Certification & Compliance Standards (Non-Transport but Often Required)

11. IEC 62133

Safety standard for rechargeable lithium batteries. It mainly required in: EU, UK, many global markets (often for customs or clients)

12. IEC 60086 (Primary Batteries)

Safety and performance standard for lithium primary batteries.

13. CE Marking (EU Market Access)

Declaration that the product complies with EU safety and EMC directives. It mainly required in European Union.

14. UKCA

UK version of CE marking. It mailny required in United Kingdom.

15. MSDS / SDS (Safety Data Sheet)

Chemical safety document describing hazards, handling, and emergency actions. It mainly required in most countries, especially EU & US.

V. Packaging, Labeling & Documentation Requirements

16. Packaging Instructions

UN-approved packaging requirements depending on battery type and transport mode. It includes: inner packaging, cushioning, short-circuit protection, and UN-certified outer cartons.

17. Marking & Labeling

A visual communication system to identify the chemical hazards (Class 9) and handling requirements of the shipment. It includes:

• Lithium battery handling mark
• Class 9 dangerous goods label
• UN number marking
• Cargo aircraft only label (air)

18. Transport Documents

Transport documents may include:

• UN38.3 Test Summary
• Dangerous Goods Declaration
• Air Waybill / Bill of Lading
• Packing List & Commercial Invoice
• MSDS

VI. Special Conditions & Limitations

When transporting primary lithium batteries, several stringent conditions and limitations apply to mitigate the inherent risks of metallic lithium.

19. Lithium Metal Content Limits

Restrictions on grams of lithium per cell or battery. This is important for lithium primary batteries (Li-SOCl₂, Li-MnO₂) transportation.

20. State of Charge (SOC) Limits

It mainly applies to lithium-ion batteries shipped by air.

21. Prototype & Small Batch Shipments

Special approvals may be required for:

• R&D batteries
• Pre-UN38.3 samples
• Damaged or recalled batteries