Labeling Lithium and Sodium Batteries

In recent years, the United Nations Model Regulations have introduced important changes concerning low-power, accepted lithium, and sodium batteries. One significant update is the modification of the lithium battery handling label, now referred to as the “Battery Mark.” A key change involves the removal of the requirement to include a phone number on the label, leaving only the UN number as mandatory.

Internationally, governing bodies such as the United Nations, ICAO (International Civil Aviation Organization), the IMDG (International Maritime Dangerous Goods) Code, and 49 CFR (the U.S. Code of Federal Regulations, Title 49) have all adopted this change, eliminating the phone number requirement. However, a common question arises in Canada: Does this change apply domestically, given that Transport Canada has not yet updated its regulations in Part 4? Many clients have asked whether they still need to include the phone number when shipping these products, despite the international exemption.

This is a valid and important question. Part 9.4 of the Transportation of Dangerous Goods Regulations (TDGR) specifies that if a product is marked and labeled in accordance with 49 CFR, ICAO Technical Instructions, or the IMDG Code, and the consignment originates outside of Canada but is subsequently shipped by ground within Canada, the label without the phone number is acceptable. However, it is crucial to ensure that the shipping document includes a statement indicating that the product has been marked and labeled in accordance with these international regulations. For example, the shipping document might state: “Dangerous goods safety marks in accordance with 49 CFR.”

For products imported into Canada for reshipment, this international labeling is permissible. The key consideration arises when products are manufactured and shipped domestically within Canada. In these cases, the Transportation of Dangerous Goods Regulations remain in effect, meaning that the requirement to include a phone number on the Battery Mark label is still mandatory. Some companies, such as Amazon, have obtained special permits from Transport Canada to remove the phone number requirement, but these are exceptions rather than the rule.

While we anticipate that Transport Canada will eventually update its regulations to reflect international standards, this change may take some time. Stay tuned for updates from ICC The Compliance Center as we monitor these developments.

Do you have any questions about shipping lithium batteries? Take a look at our Lithium Battery FAQ or contact our team of experts at 855.734.5469 or send us an email, we’re happy to help.