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Lithium Batteries · International Shipping Compliance 2026

Published 2026-05-1810 min read
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Class 9 Dangerous Goods · 2026 Rules

Lithium Batteries · International Shipping Compliance 2026

Lithium cells are the freight industry's most-handled Class 9 dangerous good — and the cause of most of those port-yard fires you keep reading about. Under IATA DGR 67 (air) and IMDG 42-24 (sea) the 2026 rules tightened around state of charge (SOC ≤ 30%), packaging, and which UN number you declare. This is the working brief for what's exempt, what's not, and which docs you can't ship without.

4
UN numbers cover all lithium-cell shipments — 3480 / 3481 / 3090 / 3091
SP188
Sea-only exemption — small cells skip the full DG paperwork track
≤30%
2026 mandatory state-of-charge for air; recommended for sea
160Wh
Air shipment ceiling — above this, no air freight allowed

Four UN Numbers — Which One Is Yours

Per IATA DGR 67 (air) and IMDG 42-24 (sea). The split is by chemistry (Li-ion vs. Li-metal) and by whether the cell ships alone or inside a device.

UN3480
Li-ion · StandaloneMost-shipped — bare cells / packs
Rechargeable lithium-ion cells shipping without a device. Air: cargo-only aircraft.
UN3481
Li-ion · Packed-With or In-EquipmentCell inside the product
Lithium-ion cells installed in or packed with a device (phone, laptop, e-bike). Passenger aircraft allowed up to 100 Wh.
UN3090
Li-metal · StandaloneNon-rechargeable, primary cells
Primary (non-rechargeable) lithium-metal cells shipping alone. Air: cargo-only aircraft.
UN3091
Li-metal · With or In-EquipmentWatches, sensors, coin cells
Lithium-metal cells installed in or packed with a device. Mostly small button / coin cells.

SP188 — The Sea-Only Exemption (Air Has No Equivalent)

If your cells fit the SP188 envelope you skip the full DG paperwork track on sea. Still Class 9, but no DG declaration / DG slot / hazpac certificate. Damaged or scrap cells: zero exemption, always declared under SP376.

Energy Cap
Li-ion: ≤ 20 Wh per cell, ≤ 100 Wh per pack. Li-metal: ≤ 1 g per cell, ≤ 2 g per pack. Pack must show Wh on the label.
UN 38.3 Tested
Every cell / pack passes UN 38.3 testing, certificate valid (≤ 1 year). No test, no shipment — exemption or not.
Drop-Test Pack
Packaging survives a 1.2-meter drop test. Outer carton carries the lithium-battery warning mark (color or B/W both OK).
Weight Cap
Loose cells / packs: ≤ 30 kg gross per carton. Outside SP188: the full UN-packaging certificate kicks back in.

Air vs. Sea — Two Different Rule Books

Same cell, different limits. The biggest 2026 changes hit air freight; sea changed less but still moved on SOC.

Air · IATA DGR 67
By Air — Tighter, Always
Passenger Aircraft
UN3480 / UN3090 banned. Standalone bare cells go cargo-only.
≤ 100 Wh
In-device (UN3481) allowed on passenger aircraft.
100–160 Wh
Cargo-only, airline approval required.
> 160 Wh
Air freight not allowed.
SOC Rule
SOC ≤ 30% mandatory. Over 100 Wh — SOC declaration / log at booking.
Cargo-Aircraft Label
"Cargo Aircraft Only" mark on every package.
Sea · IMDG 42-24
By Sea — Slightly Looser
DG Slot
Outside SP188: must book a DG slot — anti-static, reinforced.
Segregation
Away from heat sources, flammables, direct sun.
Packaging
> 12 kg: rigid outer + palletized. High-energy packs: BMS protection cert required.
SOC Rule
No global mandate, but SOC ≤ 30% recommended. Some carriers ask for declaration anyway.
Common Mistake
Mixing damaged / scrap cells into a SP188 box — instant SP376 declaration trigger.
Labels (always)
Class 9 hazard label + lithium-battery warning mark, UN number on the outer.

Documents — Five You Can't Ship Without

Each line below is one document. SP188 exempts you from declaring DG, but you still need items 1-3.

1

UN 38.3 Test Report

The lithium-cell safety transport test. One year validity. Without it, no carrier will load you, exempt or not.

2

MSDS / SDS

Safety Data Sheet — current revision, ideally both EN and CN versions.

3

Transport Condition Identification Report

"货物运输条件鉴定报告". Two flavors — air version, sea version — you pick by mode.

4

Hazpac (Export DG Packaging) Certificate

危包证. Required when SP188 doesn't apply. Issued by exit-port customs.

5

DG Declaration + SOC Statement

Air: IATA DG declaration form, packaging-compliance statement, SOC ≤ 30% declaration if > 100 Wh. Sea: Multimodal DG declaration + carrier-specific SOC statement.

Where Most Shippers Get Caught

01 · DAMAGED CELLS

SP188 Doesn't Cover Damaged

Even one scrap / dented / leaking cell in the box kills the exemption. Re-routes to UN3480 + SP376 declaration with full DG paperwork.

02 · SOC OVER 30%

Air Carriers Are Now Checking

Random gauge tests on the ramp. Pack of laptops at 60% SOC = refused at airline counter, recharge / re-pack cost is yours.

03 · WH LABEL MISSING

No Wh, No Boarding

The outer carton MUST show energy in Wh. Forwarders see SP188 boxes refused for missing Wh markings every week.

04 · EXPIRED UN 38.3

One-Year Validity Bites

UN 38.3 report has a 1-year window. Re-shipping last year's stock = re-test if expired. Plan re-tests 30 days before expiry.

Where Cube-Age fits

Cube-Age sources lithium-powered SKUs (electric pallet jacks, label printers, e-bikes, power tools) and ships them under compliant DG flow — UN-tested cells, in-spec SOC, full document set. Pair with CPSC eFiling (atlas-c67) for certificate-side compliance and 5H / 9H clearance (atlas-c69) for the U.S. entry side.

Source: IATA Dangerous Goods Regulations 67th Edition (effective 2026); IMDG Code 42-24 amendment; UN Recommendations on the Transport of Dangerous Goods, Manual of Tests and Criteria (UN 38.3). Industry compendium via "林说物流" practitioner notes.