Don’t Let Batteries Become “Bombs”: Classification and Prohibition Regulations for Batteries in International Logistics

Against the backdrop of the explosive growth of the global new energy industry, batteries, as core energy storage carriers, have seen an exponential surge in their international trade volume. However, the inherent thermal runaway risk of lithium batteries—fires and explosions caused by short circuits, overcharging, or extrusion—has made them “high-risk goods” in international logistics. According to statistics from the International Air Transport Association (IATA), 47 battery-related safety accidents occurred in global air transport in 2023, 12 of which resulted in emergency landings of cargo planes; in the maritime transport sector, 8 container ships were damaged by battery self-ignition in the first half of 2023 alone, with economic losses exceeding 500 million US dollars. Behind these accidents, 80% stem from confusion about battery classification standards and disregard for prohibition regulations. This article will deeply analyze the battery classification system in international logistics and the prohibition red lines of major countries worldwide, providing a comprehensive guide for enterprises to avoid compliance risks.

I. Internationally Universal: Core Standards and Logic of Battery Classification

Battery classification in logistics is not simply divided into “lithium batteries/lead-acid batteries” but forms a classification system led by the United Nations and refined by various countries, based on three core dimensions: hazard level, energy density, and packaging form. Among them, the United Nations Recommendations on the Transport of Dangerous Goods (TDG) serves as the “universal language” for global classification, and all internationally traded batteries must comply with its basic classification rules.

(I) By Hazard Level: Subdivision Logic of Class 9 Dangerous Goods

According to TDG regulations, the vast majority of rechargeable batteries (lithium batteries, nickel-cadmium batteries) fall under Class 9 Miscellaneous Dangerous Goods, with the core basis being their “potential thermal runaway risk.” However, the hazard levels of different types of batteries are further subdivided, directly determining transportation conditions:

1. High-Hazard Batteries (Strictly Controlled Category):

• Lithium-ion batteries (UN 3480): In pure battery form with energy density ≥100Wh/kg, including small lithium batteries for consumer electronics and power batteries for new energy vehicles. Once thermal runaway occurs, they are difficult to extinguish, so they are classified as a “high-risk subclass” under Class 9, requiring the most stringent packaging and declaration requirements for transportation;
• Lithium metal batteries (UN 3090): Batteries containing metallic lithium (not lithium ions), such as disposable lithium primary batteries. Those with a single-cell lithium content exceeding 1g (or 2g for battery packs) are deemed high-risk, and most airlines impose restrictions on their air transport;
• Nickel-cadmium batteries (UN 2800): Contain highly toxic cadmium and are prone to hydrogen gas generation during charging, posing both chemical toxicity and explosion risks. They are listed as “restricted transport batteries” by the EU and the United States.

2. Low-Hazard Batteries (Generally Controlled Category):

• Equipment containing batteries (UN 3481): Batteries installed in equipment (e.g., laptops, electric toothbrushes). Due to the equipment structure’s ability to buffer impact and dissipate heat, the risk is significantly reduced, and transportation restrictions are relatively loose;
• Lead-acid batteries (UN 2800): Disposable lead-acid batteries (non-sealed) are classified as Class 8 Corrosive Dangerous Goods due to their corrosive electrolyte; sealed lead-acid batteries (e.g., for UPS power supplies) have lower risks and can be transported as general goods but require a “no-leakage certificate”;
• Dry batteries (UN 3091): Disposable carbon-zinc batteries and alkaline batteries have no charging function and low energy density, so they are generally not classified as dangerous goods but must meet “short-circuit prevention packaging” requirements.

(II) By Transport Method: Differentiated Classification Requirements for Sea, Air, and Land Transport

For the same type of battery, due to different transportation environments (high altitude and low pressure for air transport, long-term sealing for maritime transport), classification standards and control intensities vary significantly:

(III) Easily Confused Points: These Classification Misunderstandings Must Be Avoided

1. “Lithium battery” ≠ “Lithium-ion battery”: Lithium metal batteries (UN 3090) are subject to stricter prohibitions than lithium-ion batteries (UN 3480). For example, the U.S. DOT explicitly prohibits cross-border land transport of lithium metal batteries;
2. “Equipment containing batteries” ≠ “Exempt from control”: Even if batteries are installed in equipment, if the single-cell energy exceeds 160Wh (e.g., large energy storage equipment), they must still be declared as high-risk batteries;
3. “Sample batteries” ≠ “Risk-free”: Even sample batteries for testing must comply with the full set of dangerous goods transport rules if they meet Class 9 classification standards, and cannot be mailed as ordinary samples.

II. Global Red Lines: Battery Prohibition Regulations in Major Countries/Regions

Based on safety prevention and control, industrial protection, and environmental requirements, different countries have formulated differentiated prohibition rules on the basis of UN classification standards. Enterprises must accurately identify the “red lines” of target markets to avoid violating compliance taboos.

(I) Air Transport: Globally Unified “Strictest Prohibition Rules”

Due to the sealed space and high-pressure environment, air transport has the strictest prohibition rules for batteries. IATA DGR rules are universally applicable worldwide, and no airline is exempt:

1. Absolutely Prohibited Battery Types:

• Damaged/leaking lithium batteries (regardless of energy level);
• Lithium batteries not tested to UN 38.3 standards;
• Pure lithium metal batteries (UN 3090) (unless special exemption from IATA is obtained);
• Pure lithium batteries with single-cell energy ＞100Wh or battery pack energy ＞160Wh (e.g., large power batteries).

2. Restricted Transport Battery Types:

• Pure lithium batteries with single-cell energy ≤100Wh: Only allowed for cargo plane transport (prohibited on passenger planes), with no more than 20 boxes per shipment and 10 batteries per box;
• Equipment containing lithium batteries: Allowed on passenger planes, but each device can only be equipped with 1 spare battery, which must be individually packaged;
• Power banks (portable chargers): Prohibited from checked luggage, only allowed to be carried on board, with rated energy ≤100Wh (approval from the airline is required for exceeding this limit).

(II) United States: Dual Prohibition Barriers of Policy + Technology

U.S. prohibition rules for batteries have dual attributes of “safety control” and “industrial protection,” with core bases being the Hazardous Materials Regulations (HMR) and the Battery Decoupling from Adversaries Act (H.R.1166):

1. Safety-Related Prohibitions:

• Prohibits importation of lithium batteries not certified to UL standards (UL 1642/2054/1973);
• Prohibits lithium metal batteries (UN 3090) from entering the U.S. via land or air transport;
• Energy storage batteries with a carbon footprint exceeding the threshold of the EU’s New Battery Regulation (starting from 2027) will be prohibited from importation.

2. Policy-Related Prohibitions:

• Prohibits U.S. government departments (Department of Homeland Security, Department of Defense) from purchasing products from 6 major Chinese battery enterprises including CATL and BYD;
• Battery products not registered with the FDA are prohibited from entering the U.S. market via any transport method;
• Energy storage batteries with anti-dumping duties exceeding 48.4% are essentially prohibited from entering the U.S. civilian market.

(III) European Union: “Compliance-Based Prohibitions” Oriented to Environmental Protection

The EU has established a dual prohibition system of “environmental protection + safety” based on the New Battery Regulation (BPR) and the ADR (European Agreement Concerning the International Carriage of Dangerous Goods by Road):

1. Environmental Protection-Related Prohibitions:

• Starting from 2027, power batteries without a “battery passport” will be prohibited from importation;
• Batteries with a carbon footprint exceeding the threshold (power batteries ≤80kg CO₂eq/kWh) are prohibited from entering the EU market;
• Batteries with lead content ＞0.01% or cadmium content ＞0.002% are fully prohibited.

2. Safety-Related Prohibitions:

• Lithium batteries not tested to UN 38.3 standards or certified with CE are prohibited from transport;
• Pure lithium batteries (UN 3480) entering the EU via land transport must use ADR-certified dangerous goods transport vehicles;
• Additional requirements from countries such as Germany and France: Battery transport vehicles must be equipped with real-time temperature monitoring devices that automatically alarm if the temperature exceeds 60℃.

(IV) Emerging Markets: Prohibition Risks Amid Policy Volatility

Prohibition rules in emerging markets such as Southeast Asia and Africa are not unified, but they feature high policy volatility and opaque implementation, leading to higher risks:

1. Indonesia:

• Prohibits importation of finished lithium batteries that do not meet “local content requirements”;
• Importation of pure lithium batteries (UN 3480) requires quota application, and the 2024 quota is only 60% of that in 2023.

2. India:

• Prohibits importation of used and refurbished batteries;
• Air transport of pure lithium batteries requires special approval from the Directorate General of Civil Aviation (DGCA) of India, with an approval cycle of up to 3 months.

3. Africa (South Africa, Nigeria):

• Due to weak infrastructure, pure lithium batteries (UN 3480) are essentially prohibited from maritime and land transport;
• Equipment containing batteries must provide third-party safety test reports recognized locally, otherwise, they will be directly detained.

III. Practical Guide: Compliant Operation Process for International Battery Logistics

The core of avoiding prohibition red lines is to establish a full-process compliance system of “classification confirmation → compliant declaration → packaging and transport → document retention.” Below are actionable operation steps:

(I) Step 1: Accurate Classification to Clarify Transport Eligibility

1. Confirm battery type: Whether it is a lithium-ion battery (UN 3480), lithium metal battery (UN 3090), or equipment containing batteries (UN 3481);
2. Test key parameters: Single-cell energy (Wh), weight, sealed status, and rechargeability;
3. Align with rules of the target transport method: For example, confirm if single-cell energy ≤100Wh for air transport, and if UN packaging is required for maritime transport.

(II) Step 2: Compliant Declaration to Avoid “Hidden Prohibitions”

1. Declaration information must be true and accurate:

• Prohibit “underreporting energy”: For example, declaring a 150Wh battery as 90Wh. Once detected, it will result in confiscation of goods + heavy fines;
• Prohibit “confusing categories”: Do not declare pure lithium batteries as “equipment containing batteries,” as IATA and customs both have professional testing equipment for verification;
• Mandatory declaration content: The goods name must indicate “Lithium-ion Battery, UN 3480, Class 9,” and energy parameters, UN number, and hazard class are indispensable.

2. Essential declaration documents:

• Dangerous Goods Declaration (DGD): Must be signed by the shipper to clarify the hazard of the goods;
• UN 38.3 Test Report: Issued by ISO 17025-accredited laboratories, valid for 2 years;
• Material Safety Data Sheet (MSDS): Compliant with ANSI Z400.1 standard, including 16 core sections;
• Special documents for target countries: For example, UL/FDA/FCC certification copies for the U.S., and CE certification + battery passport (starting from 2027) for the EU.

(III) Step 3: Professional Packaging to Block Risk Transmission

1. Packaging requirements for high-hazard batteries:

• Must use UN-certified dangerous goods packaging (e.g., UN 1486 for lithium batteries), which must pass the 1.2-meter drop test;
• Single batteries must be individually packaged, sealed in anti-static bags, and equipped with buffer materials (e.g., EPE foam, bubble wrap) to avoid electrode contact;
• Complete labels must be affixed to the outer packaging: Class 9 dangerous goods label, UN number label, orientation label, anti-static label, and emergency contact label.

2. Packaging requirements for low-hazard batteries:

• For equipment containing batteries, ensure batteries are securely installed, and electrodes are wrapped with insulating materials (e.g., tape);
• Lead-acid batteries must be placed upright, with packaging featuring leak-proof functions and marked with “Corrosive” warning;
• Prohibit mixed loading: Batteries shall not be transported in the same box as metal products, flammable goods, or corrosive goods.

(IV) Step 4: Select Compliant Logistics Providers to Avoid “Hidden Risks”

1. Essential qualifications of logistics providers:

• Hold IATA dangerous goods transport qualification (for air transport) and IMDG dangerous goods declaration qualification (for maritime transport);
• Have cooperative carriers certified by the U.S. DOT and EU ADR;
• Have local branches or agents in the U.S. and EU to quickly respond to customs inspections.

2. “Pitfalls” to avoid:

• Reject “three-no freight forwarders”: Unqualified freight forwarders may transport batteries as general goods. Once detected, goods will be detained + enterprises will be blacklisted;
• Be wary of “low-price temptations”: Compliant dangerous goods transport costs are higher than general goods, and excessively low quotes may indicate non-compliant operations;
• Prioritize large logistics enterprises: COSCO Shipping, Maersk, DHL, etc., have sound dangerous goods transport systems, with an accident rate only 1/10 that of small freight forwarders.

IV. Risk Prevention and Control: Avoid Batteries Becoming “Bombs” from the Source

In addition to complying with classification and prohibition rules, enterprises must establish a full-chain risk prevention and control system from three dimensions: product design, quality control, and emergency preparedness.

(I) Product End: Reduce Inherent Risks

1. Adopt safety designs: Such as adding overcharge protection, short-circuit protection, and temperature sensors to reduce the probability of thermal runaway;
2. Control energy density: For batteries exported by air, the single-cell energy is recommended to be controlled within 80Wh to avoid touching the 100Wh prohibition red line;
3. Select compliant raw materials: Prohibit the use of prohibited substances such as cadmium and mercury, and ensure the content of harmful substances meets the standards of target countries.

(II) Logistics End: Establish Emergency Mechanisms

1. Purchase sufficient insurance: Dangerous goods transport insurance + liability insurance with coverage not less than 10 million US dollars, covering risks such as fire, explosion, and goods detention;
2. Formulate emergency plans: Prepare the “Battery Safety Emergency Manual” in advance, specifying fire-fighting methods (using ABC dry powder fire extinguishers, prohibiting water) and leakage handling procedures;
3. Real-time cargo tracking: Use the logistics provider’s GPS positioning system to monitor the real-time transport status of goods and respond promptly to abnormal situations.

(III) Compliance End: Dynamically Track Policy Updates

1. Establish a policy tracking mechanism: Real-time monitor changes in classification standards and prohibition rules through the official websites of IATA, CBP, and the European Commission (e.g., the U.S. plan to raise energy storage battery tariffs in 2026);
2. Regular employee training: Logistics, sales, and R&D teams must participate in regular dangerous goods transport compliance training to master the latest classification and declaration requirements;
3. Retain compliance records: All certification reports, declaration documents, and transport records must be retained for at least 3 years for customs review.

V. Typical Cases: These Violation Lessons Must Be Heeded

1. Case 1: Misdeclaration Leading to Permanent Prohibition of Goods

In 2023, a Chinese battery enterprise exported energy storage batteries to the U.S