Beyond UN38.3: National Policies You Need to Know for Battery Transportation Besides Test Reports

In the global compliance system for battery trade, the UN38.3 test report has long been regarded as the “basic customs clearance document”—this UN standard for lithium battery transportation safety verifies battery stability under extreme conditions such as high/low temperatures, vibration, and short circuits through 12 rigorous tests, serving as the entry threshold for most countries worldwide. However, in recent years, with the explosive growth of the new energy industry and the restructuring of the global supply chain, relying solely on UN38.3 is no longer sufficient to address the increasingly complex trade barriers imposed by various countries. From the EU’s “Battery Passport” set to take effect in 2027, to the United States’ overlapping regulatory frameworks, and Southeast Asia’s quota and local content requirements, national-specific policies have become key variables determining the success of battery exports.

According to the latest 2024 data from the International Federation of Freight Forwarders Associations (FIATA), 59% of global battery trade compliance disputes result from failure to meet national-specific policies beyond UN38.3, an 18-percentage-point increase from 2023. Among these, disputes caused by non-compliant carbon footprints are growing the fastest in the EU market, while insufficient certifications and labeling violations dominate in the US market, and quota disputes account for over 30% in Southeast Asia. This article systematically dissects the core policy requirements of major global trade destinations, combined with practical cases and compliance pathways, to provide foreign trade enterprises with a comprehensive policy guide that goes beyond UN38.3.

I. New Global Policy Trends: From “Safety Bottom Line” to “Full-Chain Supervision”

The core positioning of UN38.3 is “transportation safety assurance,” but current national policies are showing three significant shifts: first, from single safety standards to multi-dimensional regulation encompassing “safety + environmental protection + industrial protection”; second, from end-product testing to full-lifecycle traceability; third, from paper document review to digital and intelligent supervision. Behind this transformation lies not only the global ongoing vigilance against lithium battery fire risks but also the inevitable result of countries competing for leadership in the new energy industry and fulfilling “dual carbon” goals.

New regulations represented by the EU’s New Battery Regulation and the US’s Reese’s Law no longer regard UN38.3 as the sole entry criterion but have established a three-tier system of “basic testing + specific certification + full-lifecycle compliance.” Under this system, UN38.3 serves only as the first-tier basic threshold, and enterprises must also meet multiple requirements such as carbon footprint, recycling, and supply chain due diligence. More notably, policy timeliness has significantly increased—the buffer period from regulation issuance to formal implementation has generally shortened to 1-3 years. For example, the EU Battery Passport has only a 4-year interval from legislation in 2023 to entry into force in 2027, requiring enterprises to establish a rapid-response compliance mechanism.

II. Analysis of Core Policy Dimensions: In-Depth Interpretation of Four Categories of National-Specific Requirements

(I) Carbon Footprint and Environmental Supervision: EU-Lead “Green Trade Barriers”

With the advancement of global “dual carbon” goals, carbon footprint has become a crucial “green passport” for battery exports, with the EU’s policies being the most stringent and representative.

The EU’s New Battery Regulation (effective in 2023) clearly stipulates that starting from 2024, the carbon footprint of power batteries exported to the EU must be ≤80kg CO₂eq/kWh, and will be further reduced to 60kg CO₂eq/kWh by 2030. Non-compliant products will be directly prohibited from entry. Unlike UN38.3’s laboratory testing, the EU’s carbon footprint accounting requires coverage of the entire lifecycle “from mine to recycling,” including raw material extraction, refining, cell production, module assembly, transportation, and recycling. This imposes extremely high data collection requirements on enterprises—not only must they calculate carbon emissions from their own production processes, but they also need to trace on-site data from upstream suppliers of cathode materials, electrolytes, separators, and even the carbon intensity of power sources.

More disruptive is the “Battery Passport” system set to take effect on February 18, 2027. According to requirements, all rechargeable industrial batteries, light transport batteries, and electric vehicle batteries with a capacity exceeding 2kWh must hold an electronic passport containing 7 categories and 107 core data points to enter the EU market. This data covers battery material composition, carbon footprint, recycling rate, supply chain due diligence, performance durability, etc., and must be updated in real-time until the end of the battery’s lifecycle. The Battery Passport is presented as a QR code, allowing regulatory authorities, certification bodies, and the public to query through authorized scanning, achieving full-chain transparent supervision. Liang Rui, Vice President of Sunwoda, revealed that the core challenges of the Battery Passport lie in data allocation for multi-site production, acquisition of confidential data from upstream suppliers, and alignment with EU accounting standards (stricter than ISO standards), for which there is no mature management system in China to directly reference.

Beyond the EU, California in the United States has introduced the Advanced Clean Fleets Regulation, requiring the carbon footprint of batteries installed in new energy vehicles sold in the state to meet specific thresholds after 2035; South Korea plans to implement a battery carbon footprint labeling system from 2025, allowing consumers to directly compare the environmental performance of different products through labels.

(II) Specific Certification and Regulatory Systems: Differentiated “Technical Thresholds” by Country

If UN38.3 is a globally recognized “basic driver’s license,” then national-specific certifications are “local permits” for entering specific markets. Based on their own industrial characteristics and safety standards, different countries have established differentiated certification systems, most of which complement or overlap with UN38.3 requirements.

The US regulatory system is characterized by “overlapping multiple regulations.” In addition to federal-level Hazardous Materials Regulations (HMR) and Consumer Product Safety Improvement Act (CPSIA), there are also specific regulatory constraints such as Reese’s Law. In terms of certification requirements, batteries exported to the US must meet both UL certification (UL 1642 for lithium-ion batteries, UL 2054 for battery packs) and FDA registration, with neither being dispensable. UL certification not only focuses on battery safety performance but also imposes requirements on the quality control system of the production process; FDA registration, on the other hand, focuses on chemical safety management, requiring enterprises to submit detailed lists of hazardous substances in batteries. In the declaration process, US Customs and Border Protection (CBP) requires the submission of dangerous goods declarations 48 hours in advance through the Automated Manifest System (AMS), with key information such as UN number, hazard class, and packaging category clearly indicated. Any inconsistency in information may trigger cargo detention and inspection.

The EU and European Economic Area (EEA) take CE certification as the core entry threshold. Battery products must comply with EN 62133 standards (for portable batteries) or EN 62660 standards (for electric vehicle batteries) to affix the CE mark. Unlike UN38.3, CE certification not only includes safety testing but also needs to meet additional requirements such as electromagnetic compatibility (EMC) and radiofrequency exposure. Furthermore, countries such as Germany and France have introduced localized policies—German airports require pure battery packaging to be equipped with real-time temperature monitoring labels that automatically alarm when the temperature exceeds 60℃; France requires battery products to provide safety instructions and labels in French.

Asia’s certification system presents “technical refinement” characteristics. Japan requires all batteries entering the market to pass PSE certification (complying with JIS C 8712 standards) and has extremely high precision requirements for capacity labeling—products with a deviation exceeding ±10% are deemed unqualified. Unlike UN38.3’s universal testing, PSE certification specifically focuses on the charging and discharging safety of batteries under Japan’s grid voltage (100V) and seismic performance (due to Japan’s earthquake-prone geographical characteristics). South Korea’s KC certification requires battery products to pass 16 tests including overcharge, over-discharge, short circuit, and extrusion, adding two specific items—”forced discharge test” and “high-temperature storage test”—compared to UN38.3.

Certification in the Middle East emphasizes “environmental adaptability.” Saudi Arabia requires battery products to pass SASO certification and additionally provide a high-temperature environment test report to prove that the product can operate normally in high-temperature environments above 50℃; the UAE’s ESMA certification imposes strict requirements on the electromagnetic compatibility and radiofrequency interference of batteries to avoid impacts on local communication networks.

(III) Quota and Local Content Restrictions: “Industrial Protection Barriers” in Emerging Markets

In emerging markets such as Southeast Asia and South America, the core orientation of national policies is “industrial protection,” restricting pure battery imports and encouraging the development of local industrial chains through quota management, local content requirements, import bans, and other measures. These policies are unrelated to UN38.3’s technical testing but directly determine the feasibility of trade.

Indonesia is a typical representative of quota management. As the world’s largest nickel ore exporter, Indonesia has implemented nearly comprehensive import restrictions on pure lithium-ion batteries (UN 3480) to promote the development of its local battery industry—the 2024 import quota for pure batteries is only 60% of that in 2023, and annual quotas must be applied for in advance. Insufficient quotas require waiting for the next year’s allocation. More strictly, the “30% local content requirement” stipulates that 30% of the raw materials, components, or production processes of imported battery products must originate from Indonesia, otherwise, an additional 20% tariff will be imposed. This means that for enterprises to enter the Indonesian market, they must either establish production bases locally or cooperate with local enterprises to purchase raw materials; relying solely on exporting finished batteries is no longer feasible.

Malaysia adopts a “local importer endorsement + license management” model. Sea transportation of pure batteries must be preceded by local Malaysian importers applying for a “dangerous goods import license” from customs in advance, and imports of used and refurbished batteries are prohibited. Additionally, products must pass SIRIM certification, with clear certification numbers and UN 3480 marks on the packaging, otherwise, they will be detained by port customs.

Countries such as Vietnam and Thailand have also introduced similar policies. Vietnam has implemented quota management for power battery imports since 2024, prioritizing foreign-funded battery enterprises cooperating with local automakers; Thailand requires imported batteries to meet the “20% local assembly” requirement after 2025, otherwise, they will face higher tariffs. The essence of these policies is to force foreign-funded enterprises to transfer production capacity through trade restrictions and build local battery industrial chains, posing significant challenges to enterprises relying solely on trade exports.

(IV) Labeling, Packaging, and Declaration: Easily Overlooked “Compliance Details”

UN38.3 only specifies basic safety performance requirements for battery transportation packaging, but countries often formulate more detailed labeling and packaging specifications based on this. These details, though seemingly trivial, have become a “high-risk area” for many enterprises’ customs clearance failures.

The EU requires all battery packaging to be labeled with the “EU Battery Recycling Mark” (a circular mark with an arrow) and indicate the carbon footprint value and performance grade; countries such as Germany and France also require pure battery packaging to use recyclable materials and print safety warnings in German or French. The US Federal Regulation 49 CFR Part 172 clearly stipulates that battery packaging must be labeled with UN number, hazard class, packaging category, shipper information, etc., with label size not less than 10×10 centimeters and text clearly legible; for pure lithium-ion batteries (UN 3480), additional labels such as “Lithium Ion Battery” and “Cargo Aircraft Only” (for air transportation scenarios) are required.

Japan’s labeling requirements are highly specific: electrodes of pure battery packaging must be wrapped with insulating tape and labeled in Japanese “絶縁済み” (Insulated); packaging of equipment containing batteries must be printed with the Japanese phrase “電池付き機器” (Equipment with Batteries), and it must be proven that batteries will not fall off or short-circuit due to vibration or collision during transportation. The Middle East emphasizes high-temperature adaptability labels—countries such as Saudi Arabia and the UAE require packaging to be labeled “-20℃~60℃ Applicable” (operating temperature range), and some ports also require a high-temperature resistance test report for packaging materials.

In the declaration process, there are also differences in timeliness and document requirements among countries. The US and EU require dangerous goods declarations to be submitted 48 hours in advance, along with additional documents such as MSDS (Material Safety Data Sheet), certification certificates, and carbon footprint reports; Japan requires the submission of Japanese MSDS and capacity test reports, with MSDS complying with JIS Z 7253 standards; Southeast Asian countries generally require quota certificates, local content certificates, and other documents to be submitted simultaneously with customs declarations, otherwise, they will be deemed incomplete declarations.

III. Typical Market Compliance Cases: From Failure Lessons to Success Paths

(I) Failure Case: EU Return Due to Lack of Carbon Footprint Documentation

A Chinese power battery enterprise exported a batch of new energy vehicle batteries to Germany, possessing both UN38.3 test report and CE certification, but the goods were detained by customs upon arrival at the Port of Hamburg. The reason was that the enterprise failed to provide a full-lifecycle carbon footprint test report meeting EU requirements and was unaware of the 80kg CO₂eq/kWh threshold. The actual carbon footprint of the batch of batteries was 89kg CO₂eq/kWh, exceeding the limit by 9kg, and the goods were ultimately forced to be returned. The enterprise suffered losses totaling over 3 million yuan, including transportation fees, port demurrage, and tariffs.

(II) Success Case: Early Layout of Battery Passport to Seize the EU Market

To meet the EU Battery Passport requirements in 2027, Sunwoda launched the construction of a full-lifecycle data management system as early as 2023. By establishing a data sharing mechanism with upstream cathode material suppliers, adopting a “production-based allocation” carbon footprint accounting method, building a full-chain data platform covering mining, production, transportation, and recycling, and cooperating with EU-recognized third-party certification bodies for pre-audit in advance. As of the beginning of 2025, Sunwoda has completed the pilot issuance of Battery Passports for the first batch of power batteries, becoming one of the few domestic enterprises with compliance capabilities. It is expected that after the new regulations take effect in 2027, its market share in the EU will further increase.

(III) Warning Case: Order Loss Due to Insufficient Indonesian Quotas

A foreign trade company signed a contract to export 1,000 sets of pure lithium-ion batteries to an Indonesian customer, completing UN38.3 testing and SNI certification. However, before shipment, it was discovered that Indonesia’s 2024 import quota had been exhausted. Due to failing to apply for quotas in advance, the goods could not clear customs upon arrival at the Port of Jakarta, and the customer ultimately canceled the order. The enterprise not only lost the payment but also bore round-trip transportation and warehousing fees, totaling over 2 million yuan.

IV. Compliance Practical Guide: Full-Process Response Strategies Beyond UN38.3

(I) Establish a Dynamic Policy Tracking Mechanism

National battery policies are updated frequently. Enterprises need to establish a dedicated compliance team or cooperate with professional consulting institutions to track policy changes in target markets in real-time. Focus on key information such as updates to the EU Battery Passport implementation rules, adjustments to carbon footprint thresholds in US states, and quota release times in Southeast Asian countries, and reserve sufficient policy adaptation periods in advance. It is recommended to update the “Target Market Compliance Manual” quarterly, clarifying timelines, required documents, and responsible departments for each requirement.

(II) Build a Full-Lifecycle Data Management System

To meet carbon footprint and Battery Passport requirements, enterprises need to build a data collection and management system from the source. First, sort out carbon emission nodes in each link of the supply chain, sign data sharing agreements with upstream suppliers, and clarify responsibilities and confidentiality clauses for data provision; second, select accounting standards meeting target market requirements (such as EU-specific accounting methods), establish a digital traceability platform to realize real-time data upload and update; third, conduct pre-accounting in advance to identify high-carbon emission links (such as power consumption and raw material extraction), and reduce carbon footprint through technological transformation (such as using green power and optimizing production processes) to ensure compliance with threshold requirements.

(III) Plan Certifications and Quota Applications in Advance

For specific certifications, it is recommended that enterprises align with the certification standards of target markets during the product R&D phase to avoid subsequent rectification costs. For example, products exported to the US need to simultaneously carry out UL certification and FDA registration, while products exported to the EU need to complete CE certification and carbon footprint testing in advance; for markets with quota requirements such as Indonesia and Vietnam, import quotas should be applied for 3-6 months in advance to ensure approval before shipment. At the same time, pay attention to the validity period of certification certificates and renew them in a timely manner to avoid customs clearance delays due to expired certificates.

(IV) Standardize Labeling, Packaging, and Declaration Documents

Develop standardized labeling and packaging templates, clearly indicating key information such as UN number, hazard class, certification marks, carbon footprint values, and recycling marks according to target market requirements, ensuring clear text and compliant dimensions. In the declaration process, establish a document review mechanism to ensure consistency of information across all documents including bills of lading, packing lists, declarations, MSDS, and certification certificates—especially core data such as battery type, energy parameters, and UN number—to avoid inspections due to information contradictions.

(V) Optimize Contract Compliance Clauses

Clearly define the compliance responsibilities of both parties in trade contracts. It is recommended to include clauses such as: “The seller shall provide all documents meeting the specific policies of the target market (including but not limited to carbon