Lithium Cell and Battery Transport Requirements

Determine whether the product contains lithium metal or lithium ion cells or batteries, and whether they travel alone, packed with equipment or installed in equipment. Capacity, lithium content, condition and intended transport mode affect the applicable provisions. A small battery is not automatically unregulated. Returned, damaged, defective, prototype and recycling shipments need particular review because the ordinary distribution pathway may not apply.

Section 173.185 references the UN Manual of Tests and Criteria for design testing, subject to specified exceptions. The test evidence must correspond to the actual cell or battery type, not simply another item sold by the same manufacturer. Assembled batteries can raise questions different from their individual cells. Record the design identity and relevant test basis before approving a new battery configuration for routine distribution.

Manufacturers and subsequent distributors have test-summary responsibilities under the regulation, with a stated exception for certain installed button cells. The summary contains standardized information linking the design to the test organization, report, tests and results. It is not the complete test report and does not alone describe every shipment requirement. PHMSA provides a specific guide explaining the summary's role and how it supports traceability through distribution.

Packaging controls address short circuits, movement damage and accidental equipment activation. Depending on the applicable pathway, a shipment can also require specified outer packaging, marks, labels, shipping papers and other hazard communication. The exact battery arrangement and quantities matter. A package prepared correctly for ground transport should not be assumed acceptable aboard an aircraft without reviewing the additional modal and air-transport restrictions.

Damaged or defective batteries, batteries shipped for disposal or recycling, and low-production or prototype designs have specific provisions. Some circumstances require special packaging or an approval, and some air shipments are prohibited. Establish an identified returns route so a customer does not send an unsafe battery through the normal sales channel. A supplier's original test summary does not remove the need to assess the condition of a returned unit.

Keep the battery specification, test-summary reference, product configuration and approved shipping instruction connected. Review cell sourcing, protection electronics and battery assembly changes before reusing earlier evidence. Shipping personnel need instructions for the actual mode and condition, while purchasing personnel need the correct design documents. Treat UN 38.3 evidence as one part of transport conformity rather than a general certificate of electrical safety, battery quality or approval for every use.