Lithium is Class 9 dangerous goods — LFP included
Lithium batteries are assigned to Class 9 under ADR/IATA/IMDG. Two UN numbers are relevant: UN 3480 for lithium-ion batteries shipped on their own and UN 3481 for batteries installed in equipment or packed with equipment. The battery, firmly installed in the vehicle, falls under UN 3481.
One point that keeps slipping through in the design: for transport law, LiFePO4 counts as lithium-ion. The higher thermal stability of LFP (onset of thermal runaway roughly at 200–250 °C instead of around 150 °C for NMC) is a safety advantage in operation, but it changes nothing about the dangerous-goods classification. Choosing LFP for the chemistry does not save you UN 38.3.
UN 38.3: eight tests, on two levels
UN 38.3 (UN Manual of Tests and Criteria, Part III, sub-section 38.3) requires a test series that the cell and the battery have to pass before the first shipment:
- T.1 altitude simulation — 6 h at 11.6 kPa (corresponds to a cargo hold at flight altitude)
- T.2 thermal cycling — cycles between +72 °C and −40 °C
- T.3 vibration — sinusoidal, 7 Hz to 200 Hz
- T.4 shock — mechanical impact load
- T.5 external short circuit — at 57 °C
- T.6 impact/crush (cell level)
- T.7 overcharge (battery level)
- T.8 forced discharge (cell level)
The decisive mistake: a UN 38.3 report for the cell (which the cell manufacturer supplies) does not cover the finished battery pack. As soon as several cells are interconnected into a pack, a new battery arises for transport law that needs tests such as T.7 (overcharge) at system level. It is exactly this second level that gets overlooked in projects — and in the end blocks the delivery, not the cell.
Prototypes and pre-series: special provision 310
But what if a prototype or a pre-series has to go to a field test before the full UN 38.3 testing is complete? For exactly this case there is special provision 310 (SP 310) in ADR and IATA. It permits the transport of small pre-series quantities (up to 100 cells or batteries) and of prototypes that have not yet been tested to UN 38.3 — but under significantly stricter conditions.
Concretely this means: each unit individually in type-tested inner packaging, surrounded by non-combustible and non-conductive cushioning material (packaging per P910 or LP905). On road and sea this is manageable under SP 310; for air freight an additional individual approval from the competent authority is required. Add to that the appropriate marking and the transport documents.
We take this route routinely in development projects: the prototype travels under SP 310 to the customer or into the field test, and as soon as the UN 38.3 testing is complete, the series runs via regular shipping. That way the approval does not delay the test — and the test does not block the approval.
The regulations of the modes of transport
Road (ADR), air (IATA DGR) and sea (IMDG) have their own requirements, and air freight is the strictest. The practically most important difference: in air freight, lithium-ion batteries may only be loaded with a maximum of 30 % SoC. That is not a recommendation, but a regulation — a fully charged pack is rejected. Whoever only finds this out at the airport has to discharge or rebook.
| Mode of transport | Regulation | Particularity |
|---|---|---|
| Road | ADR | European agreement for the carriage of goods by road; SP 310 manageable for prototypes. |
| Air freight | IATA DGR | Strictest requirements; max. 30 % SoC mandatory; SP 310 only with authority approval. |
| Sea freight | IMDG Code | Own stowage and segregation rules; SP 310 manageable for small quantities. |
Checklist before the first export
Freeze cell chemistry and cell count early
Any later change invalidates the UN 38.3 report.
Test at BOTH cell and system level
The manufacturer's cell report is not enough for the pack.
Define the mode of transport (road/air/sea)
It determines the SoC limit and the packaging.
Procure UN type-approved packaging
Improvised cardboard is not permitted.
Bring the SoC down to ≤ 30 %
Mandatory if air freight is planned — not a recommendation, but a regulation.
Apply the marking
Class 9 dangerous-goods label and lithium battery mark permanently on the package.
Prepare the transport documents
UN number and proper shipping name; keep the UN 38.3 report to hand.
Transport is part of the product responsibility, not just logistics. If you are designing a custom pack for export, we are happy to clarify the UN 38.3 levels together at the start — so that the finished product does not stand un-shippable in the warehouse.