Lithium batteries: documents and marks by air, sea and road
Lithium batteries (UN 3090, UN 3091, UN 3480 and UN 3481) need different documents and marks in each mode, and DGAssistant applies the rules of all three: within the small-battery limits they travel by road and sea under special provision 188, with the battery mark and no dangerous goods document, whereas by air only Section II of packing instructions 966, 967, 969 and 970 avoids the Shipper's Declaration. Above those limits, the battery is fully regulated Class 9 cargo in all three modes.
Editions and chapters
This guide is based on ADR 2025 (2.2.9.1.7, Chapters 3.2 and 3.3, 5.2.1.9 and 5.4.1), on the IMDG Code, Amendment 42-24 (2.9.4, Chapters 3.2 and 3.3, 5.2.1.10 and Chapter 5.4), and on the ICAO Technical Instructions, 2025-2026 edition, valid until 31 December 2026 (Part 2, Chapter 9; Part 3, Chapters 2 and 3; Part 4, Chapter 11; Part 5, Chapters 2, 3 and 4). Operators apply the IATA DGR, which uses the same numbers 965 to 970; check its current edition and any State or operator variation before booking.
Which UN number applies
| UN number | Proper shipping name | Packing instruction by air |
|---|---|---|
| UN 3090 | LITHIUM METAL BATTERIES | 968 |
| UN 3091 | LITHIUM METAL BATTERIES CONTAINED IN EQUIPMENT | 970 |
| UN 3091 | LITHIUM METAL BATTERIES PACKED WITH EQUIPMENT | 969 |
| UN 3480 | LITHIUM ION BATTERIES | 965 |
| UN 3481 | LITHIUM ION BATTERIES CONTAINED IN EQUIPMENT | 967 |
| UN 3481 | LITHIUM ION BATTERIES PACKED WITH EQUIPMENT | 966 |
All of them are Class 9 with no packing group, and none has a limited or excepted quantity: ADR and the IMDG Code show 0 and E0, and the ICAO list shows E0 with no Y instruction. Vehicles, batteries installed in cargo transport units and sodium ion batteries have entries of their own.
Every cell or battery type must have passed sub-section 38.3 of the UN Manual of Tests and Criteria and be made under a quality management programme, and manufacturers and distributors must keep the test summary accessible: ask for it before you classify the goods. Prototypes sent for testing and production runs of up to 100 cells or batteries follow special provision 310 by road and sea, and A88 by air.
Special provision 188: small batteries by road and sea
Special provision 188 says the same in substance in ADR and in the IMDG Code, and it releases small batteries from the rest of those regulations if all its conditions are met:
- Size: lithium metal up to 1 g per cell and 2 g per battery; lithium ion up to 20 Wh per cell and 100 Wh per battery, with the watt-hour rating on the outside case of the battery unless it was made before 1 January 2009. A battery with both kinds of cell, which goes under UN 3090 or UN 3091, is limited to 1.5 g and 10 Wh.
- Type: tested, with a quality programme and a test summary.
- Batteries not installed: inner packagings that enclose them completely, protection against short circuits and a strong outer packaging. The package must withstand a 1.2 m drop and, unless the batteries are packed with equipment, stay within 30 kg gross.
- Batteries installed: protection against damage and short circuits, no accidental activation, and a strong outer packaging unless the equipment gives equivalent protection.
- Mark: the battery mark on every package, except those with only button cells installed in equipment and those with up to four cells or two batteries installed in equipment, in a consignment of up to two packages. An overpack keeps the mark visible or repeats it, and shows OVERPACK in letters at least 12 mm high.
In exchange, there is no dangerous goods description on any document, no Class 9 label, no placard and no tested design type for the packaging.
The battery mark and the hazard label
The battery mark is set out in ADR 5.2.1.9, in IMDG Code 5.2.1.10 and in Part 5, Chapter 2 of the Technical Instructions (Figure 5-3), with one specification: a rectangle or square with red hatched edging, at least 100 mm × 100 mm (100 mm × 70 mm on small packages), hatching at least 5 mm wide, and a black symbol of batteries on a contrasting background above the UN number. That number is UN 3090 or UN 3480 for batteries on their own and UN 3091 or UN 3481 for batteries contained in or packed with equipment, and every UN number in the package must appear.
The earlier version, with a telephone number, may be used only until 31 December 2026 in all three modes (ADR 1.6.1.49 and notes in the other two texts), so any remaining stock should be replaced now.
The mark does not replace the hazard label. A fully regulated package carries label 9A (Figure 5-26 by air) and, by road and sea, no battery mark; only Section IB by air requires both. Where placards are required, vehicles and other cargo transport units use model No. 9, never 9A (ADR 5.3.1.1.4; special provision 384 of the IMDG Code).
By road: ADR 2025
| Special provision | Case and instruction | On the package | On the transport document |
|---|---|---|---|
| 188 | Small batteries | Battery mark, unless excepted | No dangerous goods description |
| 230 | Full regime; P903 | UN number, label 9A | UN 3480 LITHIUM ION BATTERIES, 9, (E), number and description of packages, total quantity, consignor, consignee |
| 376 | Damaged or defective; P908, LP904, P911, LP906 | Same and "DAMAGED/DEFECTIVE LITHIUM ION BATTERIES" or its lithium metal equivalent | Same description and "Transport in accordance with special provision 376"; with P911 or LP906, also "Transport category 0" |
| 377 | For disposal or recycling; P909 | Same and "LITHIUM BATTERIES FOR DISPOSAL" or "LITHIUM BATTERIES FOR RECYCLING" | Same description, with WASTE before the name if the batteries are waste |
The description runs in a fixed order with nothing in between: UN number, name, class and tunnel code (5.4.1.1.1). The class is written "9", although the label is 9A, as 5.4.1.1.1 (c) states for these UN numbers. There is no packing group, and the code (E) appears only when the route includes tunnels with restrictions. For batteries in equipment, the quantity declared is that of the batteries (Note 2 to 5.4.1.1.1 (f)).
These entries are in transport category 2: the 1.1.3.6 exemption admits up to 333 kg per transport unit, counted without packagings, and the document then shows the quantity and the calculated value. Under the full regime, the crew also carries instructions in writing (5.4.3).
By sea: IMDG Code, Amendment 42-24
| Special provision | Case and instruction | On the package | On the dangerous goods document |
|---|---|---|---|
| 188 | Small batteries | Battery mark, unless excepted | No dangerous goods document |
| 230 | Full regime; P903 | Proper shipping name, UN number, label 9A | UN 3480, LITHIUM ION BATTERIES, 9, total quantity, number and kind of packages |
| 376 | Damaged or defective; P908, LP904, P911, LP906 | Same and DAMAGED/DEFECTIVE | Same, DAMAGED/DEFECTIVE in the description and a statement of transport under special provision 376 |
| 377 | For disposal or recycling; P909 | Same and LITHIUM BATTERIES FOR DISPOSAL or LITHIUM BATTERIES FOR RECYCLING | Same, those words in the description and a statement of transport under special provision 377 |
The Dangerous Goods List assigns EmS F-A, S-I and stowage category A. Whoever packs a container or vehicle issues the container/vehicle packing certificate (5.4.2), and the Multimodal Dangerous Goods Form (5.4.5) can combine it with the document.
By air: ICAO Technical Instructions
By air there is no special provision 188. The thresholds are the same (20 Wh per cell and 100 Wh per battery for lithium ion, 1 g and 2 g for lithium metal), but each packing instruction has sections with different consequences, and the limits count the net quantity of cells or batteries per package. In the table, "9A" is the Class 9 lithium battery label (Figure 5-26) and "CAO" is the cargo aircraft only label (Figure 5-28).
| Instruction and section | Contents | Passenger aircraft | Cargo aircraft | On the package | Paperwork |
|---|---|---|---|---|---|
| 965 IA, 968 IA | UN 3480 or UN 3090 above the threshold | Forbidden | 35 kg | 9A, CAO | Declaration |
| 965 IB | UN 3480 up to the threshold | Forbidden | 10 kg | Battery mark, 9A, CAO | Declaration, 965 IB |
| 968 IB | UN 3090 up to the threshold | Forbidden | 2.5 kg | Battery mark, 9A, CAO | Declaration, 968 IB |
| 966 I, 967 I, 969 I, 970 I | UN 3481 or UN 3091 as Class 9 | 5 kg | 35 kg | 9A; CAO above 5 kg | Declaration |
| 966 II, 967 II, 969 II, 970 II | UN 3481 or UN 3091 up to the threshold | 5 kg | 5 kg | Battery mark | Air waybill statement |
Outside Section II, the package also shows the proper shipping name, the UN number and the names and addresses of shipper and consignee (Part 5, Chapter 2).
The Declaration. The Shipper's Declaration gives the UN number, proper shipping name, class, number and type of packages with the net quantity of each, packing instruction, with IB added for that section, and aircraft limitation. The shipper signs it and, on paper, hands over two copies (Part 5, Chapter 4). A typical line reads UN 3480, Lithium ion batteries, 9, 1 fibreboard box x 7 kg, 965 IB.
Section II. These packages stay off the Declaration. An air waybill, if used, states that the batteries comply with Section II of the instruction, naming the battery type and the instruction number. Under 967 and 970 the mark has the same two exceptions as in special provision 188, and then no statement is needed; 966 and 969 have no such exceptions. The mark must fit on one side of the package unfolded, and anyone preparing these packages needs suitable training.
State of charge (lithium ion only). Instruction 965 requires at most 30 % of rated capacity in both sections; more needs the approval of the State of origin and the State of the operator. Instruction 966 has applied the same limit since 1 January 2026 in Section I and, in Section II, above 2.7 Wh; at 2.7 Wh or less it is a recommendation. Under 967 it remains a recommendation, at 30 % state of charge or 25 % indicated battery capacity.
What cannot fly, or only with approval. Damaged or defective cells and batteries are forbidden under all six instructions (A154). Specific approvals are needed for waste and for batteries sent for recycling or disposal under 965 and 968 (A183), for UN 3480 and UN 3090 on passenger aircraft (A201) and for cells or batteries above 35 kg (A99).
Several modes. A Section IB package of 965 or 968, with the battery mark and label 9A, is deemed to meet special provision 188 by road and sea (note to that provision). The reverse does not hold: a special provision 188 package needs label 9A, the CAO label and the Declaration before it can fly.
Three worked cases
| Consignment | Road and sea | Air |
|---|---|---|
| 20 laptop batteries, 14.4 V × 4 Ah = 57.6 Wh, 7 kg net, one box of 8.5 kg gross | Special provision 188: battery mark UN 3480, no dangerous goods document | 965 IB: state of charge up to 30 %; battery mark, 9A, CAO, Declaration |
| One electric bicycle battery, 36 V × 14 Ah = 504 Wh, 3 kg net | Full regime: P903, label 9A; by road, UN 3480 LITHIUM ION BATTERIES, 9, (E), 1 box, 3 kg | 965 IA: state of charge up to 30 %; 9A, CAO, Declaration, no battery mark |
| Two boxes of two barcode scanners, each scanner with one 11 Wh lithium ion battery | Special provision 188, mark exception: no mark, no document | 967 II, same exception: no mark, no air waybill statement |
A third box would bring back the mark in every mode and, by air, the statement.
Frequent errors
- Taking special provision 188 to the airport. A package valid by road cannot fly as it is.
- Writing 9A on the document. The label is 9A; the class stated is 9.
- Citing 5.2.1.9 for sea. In the IMDG Code that is the limited quantity mark; the battery mark is 5.2.1.10.
- Declaring a spare battery under UN 3480. Packed with its device it is UN 3481, instruction 966, which admits passenger aircraft; 965 does not.
- Listing Section II on the Declaration. Its statement goes on the air waybill.
How DGAssistant handles it
The IATA declaration function covers lithium ion and lithium metal batteries on their own, packed with equipment or contained in equipment, in every section of packing instructions 965 to 970. DGAssistant includes the battery mark on the packages that require it, leaves Section II packages off the Declaration and prepares the statement for the air waybill. It also selects the packing instruction and checks the quantity limits.
A product defined once serves for IATA, IMDG and ADR. The ADR transport document writes the entry in the order and wording of Chapter 5.4.1 and calculates the 1.1.3.6 exemption, the IMDG function issues the multimodal form and the container packing certificate, and each consignment produces the checklist and the package marking. The questions on regulations and compliance cover how lithium batteries are handled.
The IATA section of the manual and the video tutorial show the steps. The blank forms are free:
Download for free the IATA Dangerous Goods Declaration template (Word)
Download for free the ADR 2025 transport document template (Excel)