Lithium Battery Mark Exceptions

If you ship lithium batteries that fall under the smaller battery exceptions, you are probably familiar with the lithium battery marking. Generally speaking, this marking is a requirement for batteries that meet the conditions of 173.185 (c) in the 49CFR or Special Provision 34 in TDG which both provide some relief from the regulations. However, there are times when you may not be required to place this marking on the outside of your packaging depending on a few factors.

United States and Canada

If you are shipping lithium batteries in the United States, you are probably familiar with 173.185 in the 49CFR. As mentioned above, 173.185 (c) may provide you with some relief from the regulations when shipping smaller lithium batteries or cells that meet certain criteria. In the case of the lithium battery marking, at 173.185 (c) (3) it says that each package must display the lithium battery mark that falls under this exception, however when a package contains only button cell batteries contained in equipment or when a consignment contains two packages or fewer where each package contains not more than four lithium cells or two lithium batteries contained in equipment, the lithium battery marking is not required. If you are shipping in Canada, similarly in TDGR at Special provision 34, it says that the lithium battery mark isn’t required for a means of containment containing button cell batteries installed in equipment, including circuit boards, or no more than four cells installed in equipment or no more than two batteries installed in equipment. For example, let’s say you are shipping one UN3481 Lithium-ion battery contained in equipment by ground within the U.S. and Canada, and you only have package in your consignment. As long as the battery meets the criteria of the above-mentioned regulations (SP 34 and 173.185 (c)), you would not have to mark the outer package with the lithium battery marking. On the other hand, if you are shipping more than 2 lithium-ion batteries contained in equipment inside the outer packaging, you would have to mark the outer package with the lithium battery marking per the regulations.

International

If you are shipping by air, IATA also offers some exceptions to Section II lithium batteries contained in equipment located at PI 967 and PI 970. Additionally, if you are shipping lithium batteries by Sea internationally that meet the requirements of Special provision 188 in IMDG code there are also exceptions for smaller low powered batteries. Both of these regulations have similar exceptions when using the lithium battery marking. Both the IATA and IMDG code regulations mentioned above state that the requirements of the lithium battery marking requirements do not apply to packages containing only button cell batteries installed in equipment and packages containing no more than four cells or two batteries installed in equipment, where there are not more than 2 packages in the consignment. If you don’t meet all of the criteria above, the lithium battery marking would be required.

Contact Us

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.