Skip to main content

Shipping lithium batteries can be a daunting task on its own, but there are also specific types of lithium batteries that have more detailed instructions in regards to the dangerous goods regulations. Whether you have defective/damaged lithium batteries, lithium batteries shipped for recycling/disposal, or prototype lithium batteries, careful consideration must be taken to follow the correct regulations and use the appropriate packaging, labeling, and paperwork to remain within compliance. Specifically, prototype batteries may seem like they look the same and function the same as standard lithium batteries, however they are certainly different in the eyes of the various regulations.  

What is a Prototype Battery? 

Before a specific designed lithium battery or cell can be transported, they must successfully pass certain tests. These designed tests are found in Part III, subsection 38.3 in the United Nations (UN) Manual of Tests and Criteria. The tests include altitude simulation, shock, vibration, and impact to name a few. Essentially, a prototype lithium battery is one that has not yet been proven to meet the criteria in Part III, subsection 38.3 of the UN Manual of Tests and Criteria. Often times, battery manufactures are looking to ship these prototype batteries to test facilities in order to achieve a passing grade of the 38.3 tests. The problem is, how do they ship these batteries to lab if they are not allowed to be transported? Both the United States and Canadian Dangerous Goods Regulations touch on this subject and fully explain how to do so to remain in compliance.  

United States 

In the United States, we would go to 49CFR 173.185 (e) for specifics on how to ship prototype batteries for testing purposes. In terms of packaging, each battery must be individually packed in a non-metallic packaging, such as an anti-static bag for example. In addition, once the battery is individually packaged, it must be completely surrounded by cushioning material that is non-combustible and electrically non-conductive such as Vermiculite or Extover to prevent shocks or movement during transport or it must be contained in equipment. If the prototype is contained in equipment, the equipment must be packaged in a manner to prevent accidental operation while the prototype is being transported. Now the key here is, what type of outer packaging can be used in this configuration? Well, per 173.185 (e) (3) i and ii, the outer packaging must be a packing group I metal, wooden, or plastic box, or a metal, plastic, or plywood drum. This means you cannot use a 4G box as the outer package to ship a prototype battery within the United States. In addition, if a battery’s net mass exceeds 30 kg, you can only put one in the UN tested outer package. There is one exception to the packaging guidelines mentioned above. Lithium batteries, including lithium batteries contained in equipment, that weigh 12 kg or more and have a strong impact-resistant outer casing may be packed in strong outer packagings, protective enclosures, or on pallets instead of UN packaging. However, the battery or battery assembly must be secured to prevent shifting and moving during transport. As a side note in regards to shipping prototype batteries by air, they are not permitted for transportation by passenger-carrying aircraft, and may be transported by cargo aircraft only if approved by the Associate Administrator prior to transportation. Hazmat labels and shipping papers are required as they normally would be when shipping Lithium batteries. Shipping papers must include the following statement: “Transport in accordance with § 173.185(e).” 

Canada  

If you are shipping Prototype batteries for the purpose of testing within Canada, we would take a look at Special Provision 123 in TDG. This special provision has a similar exception for prototype batteries that have a total net mass of 12 kg or more that is almost exactly the same as mentioned in the previous paragraph from 49CFR 173.185 (e). If that is not the case, this special provision sends us to packing instruction P910 in The UN Recommendations for specific details on how prototype batteries must be packaged when shipped on a road vehicle, railway vehicle, or ship on a domestic voyage. P910 In the UN Recommendations allows for use of various drums (1A2, 1B2, 1N2, 1D, and 1G) as the outer package as well as boxes including metal, plastic, wooden, and unlike the 49CFR, 4G boxes are allowed. All of these outer packages must be at least tested to a PG II performance level. Much like previously mentioned in the 49CFR, each battery must be individually packaged on its own before going into an outer packaging. In addition, each inner packaging has to be completely surrounded by sufficient non-combustible and non-conductive thermal insulation material (such as Extover or Vermiculite) to protect against a dangerous evolution of heat and a cell or battery with a net mass of more than 30 kg is limited to one cell or battery per outer packaging. The main difference here as mentioned, is you are allowed to use a corrugated 4G box if you are shipping a prototype battery within Canada, which certainly gives you more options. In addition to the lithium battery labels and shipping papers that are also required per Transport Canada when shipping prototype batteries. 

Here at ICC we offer various 4G packaging options as well as cushioning that is considered non-conductive and non-combustible. If you are interested in more details, please call us at 1-888-442-9628 in the USA or 888-977-4834 in Canada. 

Resources:
https://www.phmsa.dot.gov/lithiumbatteries 

Stay up to date and sign up for our newsletter!

We have all the products, services and training you need to ensure your staff is properly trained and informed.

UN Manual of Tests and Criteria, 7th Edition, English
UN Manual of Tests and Criteria, 7th Edition, English
Vermiculate, Grade A4 - 4 cu ft
Vermiculate, Grade A4 – 4 cu ft

Extover® Fire Extinguishing Agent
Michael Zendano

Michael Zendano started with ICC Compliance Center back in 2016 with several years in the packaging field as a Quality Control Manager. In addition, he has 8 years experience in teaching. Michael works at the Niagara Falls Office as the Regulatory Packaging Expert where he manages packaging projects and procedures and is a member of the Institute of Packaging Professionals (IOPP) and The Chemical Packaging Committee (CPC) . Degrees: M.S. Science of Education.

Welcome to ICC

Which site would you prefer?