Lithium Battery Shipping Compliance Guide (UN3480/3481/3090/3091)

Lithium batteries are the single most common reason a freight forwarder rejects a package. They are also the single most common cause of in-flight cargo fires. Every regulator on Earth — ICAO, IATA, IMO, the US PHMSA, the EU under ADR — has tightened the rules over the last decade, and the rules will continue to tighten. If you ship anything with a battery in it, you need to understand this material cold.

This guide covers the four UN entries you will actually encounter, the packing instructions that apply to each, the documents you need, and the mistakes that get five-figure fines.

Table of contents

1. The four UN numbers
2. Watt-hours, lithium content and why they matter
3. Packing instructions PI 965 – PI 970
4. Section IA, IB and II explained
5. The 30% state-of-charge limit
6. Marks, labels and the lithium battery mark
7. Documents you must include
8. By sea (IMDG) and by road (49 CFR / ADR)
9. The 10 mistakes that get shipments grounded
10. FAQ

1. The four UN numbers

Every lithium battery in commerce ships under one of four UN numbers. Pick the right one and the rest of the regulation almost reads itself; pick the wrong one and you have committed a misdeclaration before you even reached the packaging.

• UN3480 — Lithium-ion batteries (standalone). Includes lithium polymer. Class 9. Most aggressively regulated entry on the list because pure standalone cells and batteries have caused in-flight fires.
• UN3481 — Lithium-ion batteries contained in equipment OR packed with equipment. Class 9. Splits into two distinct configurations on the Shipper's Declaration.
• UN3090 — Lithium metal batteries (standalone). Class 9. Forbidden on passenger aircraft above the Section II thresholds.
• UN3091 — Lithium metal batteries contained in equipment or packed with equipment. Class 9.

Lithium-ion is rechargeable. Lithium metal (sometimes labelled "primary" lithium) is not. CR2032 coin cells, the long cylindrical cells in some smoke alarms, and most camera batteries with the chemistry "Li/MnO₂" are lithium metal. Get this wrong on the paperwork and you have a UN number misdeclaration.

2. Watt-hours, lithium content and why they matter

For lithium-ion you classify by Watt-hours per cell and per battery. Watt-hours = Volts × Amp-hours. A 3.7 V cell rated 2,500 mAh is 3.7 × 2.5 = 9.25 Wh. A typical laptop battery is 50–100 Wh. A 12 V starter battery for a small motorcycle might be 200 Wh.

For lithium metal you classify by lithium content in grams per cell or battery. A CR2032 coin cell typically contains around 0.1 g of lithium.

The thresholds you need to memorize:

• Lithium-ion cell: 20 Wh boundary. Standalone cells up to 20 Wh and batteries up to 100 Wh fall in the lower-burden Section II of PI 965 / PI 967 / PI 968 (subject to the standalone air ban).
• Lithium metal cell: 1 g lithium content boundary. Batteries up to 2 g lithium content can use Section II of PI 968 / PI 969 / PI 970.

Above those thresholds you are in Section IA (large cells/batteries) or Section IB (small cells in larger outer packages), which means full Class 9 dangerous goods: UN specification packagings, full Shipper's Declaration, hazard label, the works.

3. Packing instructions PI 965 – PI 970

IATA assigns a numbered Packing Instruction to each lithium battery configuration. Memorize this matrix:

• PI 965 — UN3480, lithium-ion standalone
• PI 966 — UN3481, lithium-ion packed with equipment
• PI 967 — UN3481, lithium-ion contained in equipment
• PI 968 — UN3090, lithium metal standalone
• PI 969 — UN3091, lithium metal packed with equipment
• PI 970 — UN3091, lithium metal contained in equipment

IMDG and 49 CFR use the same UN numbers but different packing instruction references — Special Provisions 188 and 230 in particular. The split between standalone, packed-with and contained-in is identical across modes, which is why getting the configuration right is the most important call you make.

4. Section IA, IB and II

Each PI has up to three sections. They run from most restrictive to least:

• Section IA: cells over 20 Wh (lithium-ion) or batteries over 100 Wh; lithium metal cells with more than 1 g of lithium. Fully regulated. UN spec packaging required.
• Section IB: small cells/batteries (≤ 20 Wh / ≤ 100 Wh) in quantities exceeding the Section II package limits. Still fully regulated, still requires the Shipper's Declaration.
• Section II: small cells/batteries within the package limits. Excepted from the full Class 9 paperwork in exchange for strict packaging, marking and quantity rules. Standalone lithium-ion (PI 965 Section II) is forbidden on passenger aircraft worldwide.

Section II is where most consumer-electronics shippers live. It is also where most operator variations bite — Cathay, Lufthansa, FedEx, UPS and many state authorities all impose stricter rules than the IATA baseline.

5. The 30% state-of-charge limit

Since 1 April 2016, standalone lithium-ion cells and batteries (UN3480, PI 965) shipped by air must be at a state of charge no greater than 30% of rated design capacity. The rule was added by ICAO after a series of cargo fires and an FAA test program that showed thermal runaway energy release drops sharply below 30% SoC.

The limit applies to the cells/batteries as packaged for shipment. Manufacturers comply by partial-charging at end of line. Repackagers and e-commerce sellers either need to discharge or need certification from their supplier. There is a separate article on the PI 965 SoC limit with the practical compliance approaches.

The rule does not apply to UN3481 (batteries in or with equipment) or to lithium metal entries — but several operators apply the same 30% limit voluntarily. Always check the operator variation.

6. Marks, labels and the lithium battery mark

For Section II shipments by air, the package must bear:

• The lithium battery mark — a rectangular mark with the UN number(s) inside, red hatched borders, telephone number for additional information, and a battery group symbol. The current mark replaced the old "lithium battery handling label" in 2019.
• The shipper and consignee details, the proper shipping name, and the UN number.

For Section I (fully regulated) shipments by air you instead apply the Class 9 lithium battery hazard label (the diamond with the battery group symbol), in addition to the UN number marked on the package.

Both labels are 100 × 100 mm minimum for hazard labels and 100 × 100 mm for the lithium battery mark (with a permitted reduction to 100 × 70 mm when the package is too small).

7. Documents you must include

For a Section I (fully regulated) lithium battery shipment by air:

• Shipper's Declaration for Dangerous Goods — two original copies, in English, with the UN number, proper shipping name, class, packing group (II for lithium batteries), number and type of packages, quantity per package, packing instruction, and the 24-hour emergency contact.
• Air waybill — must reference "Dangerous Goods as per attached DGD" and the number of packages.

For a Section II shipment by air:

• No Shipper's Declaration required.
• The air waybill, when issued, must include the statement "Lithium ion batteries in compliance with Section II of PI 967" (or 966, 969, 970 as appropriate). The exact wording matters. See our walk-through of the Shipper's Declaration for what each block actually requires.

8. By sea (IMDG) and by road (49 CFR / ADR)

The same four UN numbers apply, but the regime is more permissive. IMDG (Amendment 41-22 onwards) classifies lithium batteries as Class 9 with Special Provision 188 for small cells, and 230 / 348 / 360 for the general entries. Marine pollutant designation does not apply to lithium batteries themselves.

Under 49 CFR in the US, lithium batteries are governed by §173.185. PHMSA largely harmonizes with ICAO/IATA for air transport and provides reduced requirements for ground transport: small cells in equipment can ship as fully excepted ground freight under §173.185(c). Misdeclaration penalties under 49 CFR §107.329 reach $96,624 per day per violation for hazmat (the statutory cap is updated annually for inflation).

Under ADR in Europe, lithium batteries fall in Transport Category 2 with a 333 kg per transport unit limit before full ADR placarding kicks in. SP 188 of ADR mirrors the IMDG SP 188 closely.

For deeper coverage of each mode see the IMDG quick reference, the 49 CFR checklist and the ADR beginner's guide.

9. The 10 mistakes that get shipments grounded

1. Wrong UN number for the chemistry. Calling a CR123A (lithium metal) UN3480 instead of UN3090.
2. No 30% SoC certification for UN3480 by air.
3. Mixing damaged or recalled cells into the same package as good cells. Damaged, defective or recalled (DDR) lithium batteries are forbidden by air.
4. Using the old handling label instead of the lithium battery mark introduced in 2019.
5. Missing the air waybill statement on Section II shipments. The most common AWB rejection.
6. Watt-hour rating not marked on the battery. Required since 2009 for lithium-ion batteries manufactured for commerce.
7. Stacking too many Section II packages on a single consignment and silently exceeding the per-overpack limits.
8. Inadequate inner packaging. Cells must be packed so that terminals cannot short.
9. No 24-hour emergency contact on the Shipper's Declaration. A common cause of full-shipment rejection.
10. Treating a power bank as "an electronic device". Power banks are standalone lithium-ion batteries (UN3480) for regulatory purposes, not equipment.

Most of these are not subtle. They are the result of a shipper picking the wrong row on a spreadsheet at the start of the day and not catching it. See the broader hazmat fines article for the dollar consequences.

FAQ

Can I ship a power bank as carry-on? Yes — passengers can carry power banks up to 100 Wh in cabin baggage without operator approval, and 100–160 Wh with operator approval. They are forbidden in checked baggage. Cargo shipments follow PI 965 with the 30% SoC limit.

What about prototype batteries? Pre-production prototypes that have not completed UN 38.3 testing must ship under Special Provision A88 (air) or A99/equivalent in other modes, with competent authority approval. Plan ahead — A88 approval is not a same-day process.

Used batteries for recycling? UN3480 / UN3090 still apply, with additional provisions for damaged/defective. There are explicit packing instructions PI 908 and PI 909 for damaged or recalled cells. Do not put them on a passenger aircraft.

Lithium batteries are the regulator's favourite case study because the consequences of getting them wrong are vivid and the rules update every year. The good news: the structure is stable. UN number → packing instruction → section → marks → documents. Get those four steps right and the rest is paperwork hygiene.