Can Firmware Change Lithium Battery Shipping Requirements?

When shipping lithium batteries, understanding the regulations is essential to ensure they are transported safely and in compliance with dangerous goods requirements. One important factor in determining how lithium-ion batteries are classified for transportation is their watt-hour (Wh) rating. But what happens when a battery’s capacity is electronically limited by software, commonly referred to as firmware? Transport Canada recently published a new safety advisory addressing this question and providing guidance on the transportation of firmware-limited lithium-ion cells and batteries.

What is Firmware?

In simple terms, firmware is software built into a battery or its battery management system that controls how the battery operates. In this case, the firmware limits how much of the battery’s energy capacity can actually be used. For example, let’s say a lithium-ion cell has the physical capability to store 25 Wh, but the manufacturer has designed its firmware to electronically limit its usable energy capacity to 20 Wh.

Why Does Firmware Matter for Lithium Battery Shipping?

So, why does this matter when shipping dangerous goods? Under Canada’s Transportation of Dangerous Goods Regulations (TDG), lithium-ion cells rated at 20 Wh or less may qualify for certain exemptions under Special Provision 34. But can a cell originally rate at 25 Wh qualify for these exemptions simply because its capacity has been electronically limited?

What Does Transport Canada’s New Guidance Say?

Transport Canada recently addressed this question in a new safety advisory, explaining that firmware-limited lithium-ion cells and batteries may be transported based on their reduced capacity, provided certain conditions are met. In our example, the cell could potentially be shipped under the requirements applicable to a 20 Wh cell, as long as the firmware limitation remains active during transportation and all other applicable conditions are satisfied. However, if the firmware limitation is deactivated and the cell operates at its full 25 Wh capacity, the shipping requirements for the higher capacity would apply.

What Happens if the Firmware Limitation Is Deactivated?

To qualify for the reduced capacity requirements again, the firmware limitation would need to be reactivated before the cell is offered for transport.

Review the Guidance Before Shipping

Click HERE for full access to Transport Canada’s guidance document.

Before shipping, make sure your lithium batteries are classified correctly and meet all applicable regulatory requirements. Need guidance? Contact ICC for expert assistance with lithium battery compliance, or explore our Lithium Battery FAQ for answers to common shipping questions.