From China to the US: A Compliance Checklist for International Battery Transportation

As China’s lithium battery industry continues to consolidate its dominant position in the global market, the United States, as one of the world’s largest new energy consumer markets, has become a core destination for Chinese battery enterprises going global. However, the U.S. import regulatory system for battery products is complex and stringent, covering multiple dimensions such as policies and regulations, technical certifications, transportation safety, and document declaration. Non-compliance in any link may result in detained goods, fines, return shipments, or even permanent bans from entering the market. Data in 2023 shows that losses caused by compliance issues for Chinese battery products exported to the U.S. exceeded 1.2 billion yuan, with 35% stemming from incomplete certifications, 28% from non-compliant transportation packaging, and 22% from errors in document declaration. Based on the latest U.S. regulatory policies and international transportation rules, this article compiles a full-process compliance checklist to provide enterprises with actionable operational guidelines.

I. Policy and Regulatory Compliance: Clarify “Red Lines” Before Initiating Transportation

The U.S. regulatory framework for battery imports features a triple control mechanism of “legislation + administration + tariffs.” Enterprises must first clarify core policy requirements to avoid crossing compliance red lines.

(I) Core Policy Checklist and Compliance Requirements

(II) Practical Policy Compliance Tips

1. Enterprise Qualification Verification: First confirm whether the enterprise is on the “prohibited procurement list” under H.R.1166. If supplying U.S. government projects, proactively change the cooperation entity or adopt a “third-party OEM + compliant brand” model.
2. Tariff Classification Confirmation: According to the U.S. Harmonized Tariff Schedule (HTS), the corresponding tariff codes for lithium batteries are 8507.60.00 (lithium-ion batteries) and 8507.90.40 (storage batteries). Accurate classification is required to avoid incorrect tariff payment.
3. Policy Dynamic Tracking: Real-time monitoring of tariff adjustments and policy updates (e.g., the proposed increase of energy storage battery tariffs from 7.5% to 25% in 2026) through the CBP official website and industry bulletins from the American Chemistry Council (ACC).

(III) Tariff Compliance Optimization Strategies

• Rational use of the “First Sale Rule”: Use the first sale price of the product as the dutiable value to reduce the tariff base;
• For products with high tariffs, consider setting up assembly plants in Mexico or Canada before exporting to the U.S. to enjoy duty-free treatment under the USMCA (United States-Mexico-Canada Agreement);
• Apply for “Duty Suspension”: Submit applications to the U.S. International Trade Commission (ITC) through industry associations to secure tariff reductions for eligible new energy battery products.

II. Technical Certification Compliance: Essential Certification Checklist and Application Process

The U.S. implements a combined system of “mandatory certifications + voluntary certifications” for battery products. Transportation shall not be initiated until core mandatory certifications are completed.

(I) Mandatory Certification Checklist (Indispensable)

1. UL Certification: The core safety certification in the U.S., with different standards for different types of batteries:

• Small lithium batteries (e.g., for consumer electronics): UL 1642 (safety standard for single cells);
• Battery packs (e.g., for energy storage and electric vehicles): UL 2054 (safety standard for battery packs);
• Lithium battery chargers: UL 991 (safety standard) + UL 60950-1 (electromagnetic compatibility standard);
• Power batteries: Additional compliance with UL 1973 (safety standard for electric vehicle batteries).
• Application Process: Select a UL-authorized laboratory in China (e.g., UL Suzhou, UL Guangzhou) → Submit product samples and technical documents → Conduct safety tests (short circuit, overcharge, high/low temperature, impact, etc.) → Obtain certification (cycle: 4-8 weeks).

2. FDA Registration: The U.S. Food and Drug Administration (FDA) regulates batteries as “electronic device accessories,” requiring:

• Enterprise FDA registration (processed via the FDA official website or authorized agents, valid for 2 years);
• Product Listing: Submit product specifications and Material Safety Data Sheet (MSDS);
• Note: If the battery contains harmful substances such as mercury or cadmium, additional FDA-recognized test reports are required.

3. FCC Certification: Addresses electromagnetic compatibility (EMC) requirements for battery products, requiring:

• Compliance with FCC Part 15 standard tests (radiated emission, conducted emission, etc.);
• Submission of test reports to FCC-authorized bodies to obtain certification (cycle: 2-3 weeks);
• Products must be marked with the FCC ID number; otherwise, customs inspection will not be passed.

(II) Voluntary Certifications (Recommended to Improve Approval Rates)

• UN 38.3 Test Report: Though not mandatory by the U.S. government, it is a core basis for safety clearance by CBP and airlines. Must be issued by ISO 17025-accredited laboratories, covering 8 test items including altitude simulation, thermal testing, vibration, impact, and short circuit;
• ENERGY STAR Certification: For energy storage batteries and charging equipment, this certification enhances market acceptance in the U.S. and complies with energy efficiency requirements of the California Energy Commission (CEC);
• REACH Compliance Statement: Though an EU standard, U.S. Customs often references its restrictions on harmful substances. It is recommended to provide test reports for elements such as lead, cadmium, and mercury.

(III) Certification Compliance Pitfall Avoidance Guide

• Avoid “fake certifications”: CBP verifies the authenticity of certification numbers via the UL official website. Fake certifications will result in permanent market bans;
• Timely certification renewal: UL certifications are generally valid for 5 years. If product design or raw materials change during this period, re-certification is required;
• Choose “one-stop certification services”: Collaborate with institutions authorized for UL, FCC, and FDA certifications (e.g., SGS, TÜV Rheinland) to shorten the certification cycle by over 30%.

III. Transportation Method Compliance: Differentiated Requirements for Sea, Air, and Land Transport

The U.S. classifies lithium batteries as Class 9 dangerous goods. Compliance requirements vary significantly across transportation methods. Enterprises must select appropriate methods based on product type and urgency while meeting corresponding standards.

(I) Sea Freight Compliance Checklist (Accounting for 75% of China-US Battery Transportation)

1. Packaging Compliance:

• Must use UN-certified dangerous goods packaging (e.g., UN 1486, UN 1485) with fireproof, leak-proof, and short-circuit prevention functions;
• Single cells must be individually packaged to avoid mutual collision, with anti-static separators and buffer materials inside;
• External packaging must be marked with: dangerous goods class (Class 9), UN number (UN 3480 for lithium batteries, UN 3481 for equipment containing lithium batteries), Chinese-English “Lithium Battery” label, and orientation label (“This Side Up”).

2. Transportation Documents:

• Dangerous Goods Declaration (DGD): Signed by the shipper, specifying goods name, UN number, quantity, weight, packaging class, etc.;
• Copy of UN 38.3 test report (stamped with the enterprise seal);
• Material Safety Data Sheet (MSDS): Compliant with ANSI Z400.1 standard, including 16 sections (chemical and enterprise identification, hazard identification, composition information, etc.);
• Packing List and Commercial Invoice: Must indicate “Lithium Batteries, Class 9 Dangerous Goods,” with invoice amount consistent with customs declaration amount.

3. Carrier and Port Selection:

• Select carriers with U.S. DOT dangerous goods transportation qualifications (e.g., COSCO Shipping, Maersk, Hapag-Lloyd) to avoid detained goods due to insufficient qualifications of small freight forwarders;
• Prioritize major ports such as the Port of Los Angeles, Port of Long Beach, and Port of New York, which are equipped with professional dangerous goods inspection facilities and offer higher customs clearance efficiency;
• Submit the “Dangerous Goods Declaration” to the carrier at least 48 hours before loading.

(II) Air Freight Compliance Checklist (Suitable for High-Value and Urgent Orders)

1. Core Restrictions:

• Prohibited batteries for air transport: Damaged/leaking lithium batteries, batteries failing UN 38.3 tests, lithium batteries (pure batteries) with single-cell energy exceeding 100Wh;
• Permitted batteries for air transport: Equipment containing lithium batteries (e.g., laptops, electric vehicles), pure lithium batteries with single-cell energy ≤100Wh (IATA-approved).

2. Packaging and Labeling:

• Use IATA-designated dangerous goods packaging (e.g., PI965 packaging) with anti-static and short-circuit prevention functions;
• External packaging must be marked with “Cargo Aircraft Only,” lithium battery label, UN number, and “Static Sensitive Device” label;
• Quantity restrictions per package: ≤2 pure batteries/box, ≤10 pieces of equipment containing batteries/box.

3. Documents and Testing:

• Additional “Lithium Battery Air Transport Declaration” as required by IATA Dangerous Goods Regulations (DGR);
• Airlines may require a “1.2-meter drop test report” to verify packaging impact resistance;
• Select airlines with dangerous goods air transport qualifications (e.g., Air China, United Airlines) to avoid refusal of shipment.

(III) Land Transport Compliance Checklist (Suitable for Transit via China-Mexico Border)

1. Cross-Border Land Transport Requirements:

• Transport vehicles must comply with U.S. DOT dangerous goods transport vehicle standards (e.g., equipped with fire-fighting facilities and emergency equipment);
• Drivers must hold a U.S. Hazardous Materials Endorsement (HME) and receive lithium battery safety transportation training;
• Goods must be accompanied by a “Dangerous Goods Transport Manifest” specifying cargo location, quantity, and emergency contact information.

2. Border Customs Clearance Key Points:

• Prioritize major border ports such as Laredo and El Paso, which have dedicated inspection channels for dangerous goods;
• Submit the “Advanced Manifest System (AMS)” declaration to U.S. Customs no later than 4 hours before goods arrive at the border;
• Cooperate with customs unpacking inspections and provide packaging compliance certificates and product certification documents.

IV. Document Declaration Compliance: A “Zero-Error” Declaration Document Checklist

U.S. Customs requires “comprehensive, accurate, and consistent” declaration documents for battery products. Any inconsistency will cause customs clearance delays. Below is a list of essential documents and filling specifications.

(I) Core Declaration Document Checklist

1. Commercial Invoice:

• Mandatory information: Names, addresses, and contact details of buyer and seller; product name (specify “Lithium Battery” and type), specifications, quantity, unit price, total price; HS code (starting with 8507); origin declaration (“Made in China”);
• Notes: Amounts must be settled in USD; avoid “estimated amounts”; for samples, indicate “Sample for Testing, No Commercial Value” with a value not exceeding $2,500 (otherwise, tariffs apply).

2. Packing List:

• Must be fully consistent with invoice information, with additional details: weight (gross/net) and dimensions of each package, packaging type (e.g., “UN 1486 Carton”); single-cell energy and total energy of batteries;
• Example: “10 Cartons, Each Carton Contains 50 Units of Lithium-ion Battery Packs (UL 2054 Certified), Nominal Voltage: 3.7V, Single Cell Energy: 20Wh, Total Energy per Carton: 1000Wh, Gross Weight per Carton: 15kg”.

3. Customs Entry Form (CBP Form 7501):

• Can be filled out by a local U.S. customs broker. Core information includes: importer details, goods description, HS code, declared value, tariff rate, and Incoterms (e.g., FOB, CIF);
• For tariff reduction eligibility (e.g., USMCA origin), an additional Certificate of Origin (Form 434) is required.

4. Compliance Statement Documents:

• Copies of certification certificates: UL, FDA, and FCC certificates (stamped with the enterprise seal and accompanied by English translations);
• Safety Statement: Declaration that products comply with U.S. HMR, UL standards, and UN 38.3 test requirements;
• Hazardous Substance Statement: Declaration that products do not contain prohibited substances (mercury ≤0.1%, cadmium ≤0.01%, etc.), accompanied by third-party test reports.

(II) Document Filling Pitfall Avoidance Guide

• Information Consistency: Product name, quantity, amount, and HS code must be identical across the invoice, packing list, and customs entry form. Avoid trivial errors such as “500 units on invoice vs. 490 units on packing list”;
• Terminology Standardization: Avoid vague descriptions like “battery”; specify “Lithium-ion Battery” or “Lithium Polymer Battery”;
• Accurate Translation: All Chinese documents must have English translations issued by professional translation agencies. Avoid semantic ambiguity from machine translation (e.g., “安全认证” translated as “Safety Certification” instead of “Security Certification”);
• Record Retention: Keep electronic and physical copies of all declaration documents. U.S. Customs may conduct reviews within 3 years after goods clearance.

V. Product Marking and Labeling Compliance: Visible “Compliance Signals”

The U.S. has clear mandatory requirements for battery product marking and labeling, which are not only key to customs inspection but also a prerequisite for market entry and sales.

(I) Product-Specific Marking Requirements

1. Core Marking Content:

• Product name, model, rated voltage, rated capacity (Ah/Wh);
• Manufacturer’s name, address, and contact information (must include U.S. local contact or agent details);
• Safety Warnings: “Do Not Short Circuit,” “Do Not Disassemble,” “Keep Away from Heat” (in uppercase English, font size ≥10pt);
• Certification Marks: UL Logo, FCC ID number, FDA registration number.

2. Special Marking Requirements:

• Power Batteries: Must be marked with “For Vehicle Use Only” and battery cycle life;
• Energy Storage Batteries: Must be marked with “For Energy Storage System” and operating temperature range (-20℃~60℃);
• Equipment Containing Lithium Batteries: Must be marked on the device housing with “Contains Lithium Battery, Risk of Fire if Damaged”.

(II) Transportation Packaging Label Requirements

(III) Marking Compliance Inspection Points

• Secure Label Application: Use waterproof and tear-resistant materials to prevent detachment during transportation;
• Language Standardization: All labels must be primarily in English; Chinese can be added as a supplement but not a replacement;
• Avoid Information Errors: Ensure UN numbers match product types (e.g., pure batteries shall not be marked with UN 3481) and rated capacity matches test reports.

VI. Risk Prevention and Control Compliance: Proactively Avoid Potential “Minefields”

The China-U.S. battery transportation process is long and involves multiple links. In addition to meeting the above compliance requirements, enterprises must establish risk prevention and control mechanisms to address