Lithium-Ion Battery Shipping Regulations and Carrier Policy Compliance

Lithium-Ion Battery Shipping Regulations and Carrier Policy Compliance

Shipping lithium-ion batteries requires strict adherence to international and domestic rules. These batteries can catch fire if damaged, packed incorrectly, or mislabeled, which is why transport authorities apply close scrutiny.

The International Air Transport Association (IATA) and the U.S. Department of Transportation (DOT) regulate how lithium batteries move by air and ground. Carriers like FedEx and UPS often add their own restrictions. Labeling errors remain one of the top reasons shipments are delayed, rejected, or flagged. Incorrect marks, missing UN numbers, and improper label placement are all common triggers for compliance failures.

Clear knowledge of the regulations, label requirements, and carrier policies helps prevent avoidable risk in the shipping process.

IATA DGR and U.S. DOT for Shipping Lithium Ion Batteries

Two primary regulatory frameworks apply when shipping lithium-ion batteries: the International Air Transport Association’s Dangerous Goods Regulations (IATA DGR) and the U.S. Department of Transportation’s Title 49 of the Code of Federal Regulations (49 CFR). Each sets specific packaging, marking, labeling, and documentation requirements depending on battery type, size, and shipping method.

IATA DGR governs air transport and is updated annually based on safety data and incidents. For companies shipping lithium-ion batteries by air, IATA compliance is non-negotiable, even for small cells or equipment containing them.

49 CFR governs transport within the United States, covering all ground shipments and harmonizing many rules with international standards. While there are overlaps between IATA and DOT rules, certain packaging instructions and exceptions vary, especially for low-volume or Section II shipments.

Both sets of regulations require careful attention to classification, documentation, and labeling. Misalignment between package content and declared classification is a frequent reason for shipment rejection or audit.

IATA DGR: Air Cargo Rules for Lithium Batteries

The IATA Dangerous Goods Regulations (DGR) classify lithium-ion batteries under UN3480 (batteries only) and UN3481 (batteries packed with or in equipment). These designations determine packaging, labeling, and documentation requirements.

Batteries shipped by air must be charged to no more than 30% and pass UN 38.3 testing. Packaging must meet performance standards, and most shipments require the lithium battery mark. Some also need the Class 9 hazard label, depending on quantity and configuration.

Airlines are increasingly limiting or rejecting Section II shipments, even if technically allowed under IATA rules. Many require full documentation and pre-approval, especially for bulk battery shipments.

Most issues arise from labeling errors or missing paperwork. Incorrect use of marks or failure to include a Shipper’s Declaration can delay or ground a shipment.

U.S. DOT 49 CFR: Domestic Ground Shipping Regulations

The U.S. Department of Transportation regulates lithium-ion battery shipments under Title 49 of the Code of Federal Regulations (49 CFR). These rules apply to all ground transport within the United States, including highway and rail.

Like IATA, DOT uses UN3480 and UN3481 to classify lithium-ion batteries. The regulations outline requirements for packaging, hazard communication, shipping papers, and training. For ground shipments, exceptions are available for smaller batteries in limited quantities, but these still require proper markings.

Section 173.185 of 49 CFR is the key reference for lithium battery requirements. It covers testing, packaging specifications, overpack conditions, and marking rules. Ground shipments may not require a Class 9 label, but the lithium battery mark is often still required.

Labeling mistakes under DOT regulations can trigger shipment holds or penalties, especially for repeat violations. Packaging must match the declared battery configuration and include the correct UN number and marks to move through carrier networks without delays.

Classifying Your Battery: Li-Ion vs. Li-Metal Batteries

Before shipping, it's important to classify batteries correctly. Lithium-ion and lithium metal batteries fall under different UN numbers and follow different packaging and labeling rules.

Lithium-ion batteries (UN3480 or UN3481) are rechargeable and commonly found in devices like laptops, power tools, and medical equipment. Lithium metal batteries (UN3090 or UN3091) are non-rechargeable and used in devices like watches, implantable medical devices, and memory backup systems.

The key differences that affect shipping:

  • Lithium-ion: measured in watt-hours (Wh)
  • Lithium metal: measured in lithium content (grams)
  • Each follows different packaging, documentation, and exception rules

Misclassifying a battery is a common cause of regulatory violations. The correct classification drives all other decisions: what mark to apply, which label is required, and how much documentation is needed.

Required Marking and Labeling for Compliant Shipping

Lithium battery shipments must display the correct mark or label based on type, quantity, and transport mode. This includes the lithium battery mark, UN number, and sometimes a Class 9 label.

Air shipments often require more visible hazard communication. Small errors like missing UN numbers or incorrect label size are common reasons for shipment delays or holds.

Applying the Right Lithium Battery Mark and UN Number

Most lithium-ion and lithium metal battery shipments require the lithium battery mark unless fully exempt. It must include the correct UN number—either UN3480, UN3481, UN3090, or UN3091—depending on battery type and configuration.

Marking must follow specific size, color, and durability standards. The symbol (battery with flame), UN number, and telephone number for additional information must be legible and placed on one side of the outer package.

For shipments that meet fully regulated criteria, the lithium battery mark alone is not enough. These also require the Class 9 hazard label, and in some cases, the Cargo Aircraft Only (CAO) label.

When to Use the Class 9 Hazard Label and CAO

The Class 9 hazard label is required for fully regulated lithium battery shipments. This includes standalone lithium-ion batteries over certain weight or watt-hour thresholds, or when batteries exceed the limits for Section II.

The Cargo Aircraft Only (CAO) label is required when the package cannot be shipped on a passenger aircraft under IATA regulations. This typically applies to larger battery shipments or those that exceed the limits for standard air cargo.

Both labels must meet size and durability standards and be placed on the same side of the package as the lithium battery mark when possible.

Carrier Policy Variations: FedEx, UPS, and DHL

Major carriers follow IATA and DOT regulations but apply their own policies to lithium battery shipments. FedEx, UPS, and DHL often require stricter packaging and pre-approval for Section II.

What’s accepted under regulation may still be refused by the carrier. Understanding each carrier’s specific rules helps avoid rejected shipments or unexpected delays.

Stricter Carrier Rules on Section II Shipments

Section II allows limited quantities of lithium batteries to ship with fewer requirements, but most major carriers apply stricter controls.

FedEx and UPS require pre-approval for Section II shipments. DHL has stopped accepting Section II for standalone lithium-ion batteries in many areas. Some services and destinations block them entirely.

Even when allowed, these shipments must follow each carrier’s specific packaging and marking rules. Relying on IATA alone can lead to refused pickups or returns.

Required Documentation: The Shipper’s Declaration

Fully regulated lithium battery shipments must include a Shipper’s Declaration for Dangerous Goods. This document provides key details such as the UN number, proper shipping name, hazard class, packing group, and quantity.

It must be completed accurately and signed by a trained individual. Errors in the declaration, including wrong classification, missing data, or outdated forms, can result in shipment holds or fines.

Section II shipments typically don’t require a declaration, but many carriers still request supporting paperwork for tracking.

GMP Labeling Solutions: The Compliance Partner You Need

GMP Labeling supplies compliant lithium battery marks, Class 9 hazard labels, and CAO labels, built for air and ground shipping. All labels meet regulatory size, durability, and design requirements and are manufactured to perform under demanding transport conditions.

We support QC teams and logistics professionals who need accuracy, fast turnaround, and dependable service, including access to thermal transfer printers for on-site label production. Our products help prevent delays, avoid mislabeling, and maintain compliance across global and domestic shipping networks.

Reach out to a specialist to learn more today.