TIANQIUMost battery orders arrive with a folder rather than a file, and one document in that folder gets misread more than any other: the safety sheet. Buyers file it as a certificate. Forwarders treat it as the paper that lets the cargo board. Both readings are wrong in ways that cost a shipment time, and the correction is not complicated once the document is separated from the two things it is constantly confused with.
The confusion starts with the product. A battery is a sealed manufactured object, not a drum of chemicals, and that single fact decides which rules reach it. Everything else on this page follows from it: why the sheet is voluntary in most markets, why a stamped cover proves nothing, and why the transport section is the one your forwarder actually reads.
What is a battery MSDS, and why do people call it an SDS?
MSDS and SDS name the same document at two points in time. Material Safety Data Sheet was the term in use before the Globally Harmonized System standardised the format; Safety Data Sheet is the name GHS and EU law use, and it arrives with a fixed sixteen-section order that the older sheets never had.
In trade you will meet at least four titles for the same idea: SDS, MSDS, Article Information Sheet and Product Safety Data Sheet. Which one is printed on the cover matters far less than two things inside it — whether page one names the chemistry you are shipping, and whether section 14 agrees with the way the cargo will actually travel. A sheet that is beautifully formatted and names a different chemistry is worse than no sheet, because it will be filed and trusted.
Why is a cell treated as an article rather than a chemical?
Because the chemistry is sealed inside a manufactured object. US hazard communication law defines an article as a manufactured item formed to a specific shape, whose end use depends on that shape, and which under normal conditions of use releases no more than trace amounts of a hazardous chemical — a description that fits a coin cell exactly.
Two consequences follow, and they pull in opposite directions. The GHS states that articles fall outside its classification system, and REACH asks for a safety data sheet from the supplier of a substance or a mixture, not of an article. So a formal SDS obligation does not land on a cell. But the article route does not mean silence either: REACH still requires information on any candidate-list substance present above 0.1 % by weight in an article, and the commercial pressure is stronger than the legal one, because carriers, marketplaces and retailers have built their own document requirements around the sheet.
That is why the document exists in a grey zone, and why reputable makers publish it anyway, under several names.
| Title and publisher | What it covers |
|---|---|
| Article Information Sheet (AIS) — Duracell, Energizer | Chemistry, handling and transport for a cell outside GHS classification |
| Product Safety Data Sheet (PSDS) — Panasonic | Same substance information, under the title used in Japanese industry practice |
| SDS per chemistry — FDK | One sheet each for alkaline, silver oxide, zinc air and carbon zinc |
Titles in circulation from three makers, read off their own published document libraries. Different covers, same job: tell a handler and a carrier what is inside and how it behaves.
What do the 16 sections contain, and which ones get read first?
Sixteen sections in a fixed order, and almost nobody reads all of them. In daily work three get opened: composition, when a marketplace asks what is inside the cell; transport, when a forwarder decides how the cargo moves; and disposal, when a retailer’s waste team wants to know what happens at end of life.
The rest of the sheet exists for the people who handle the product rather than the people who buy it, and that is worth knowing before you spend an afternoon reading a document nobody on your side will use.
| Sections | What they hold | Who opens them |
|---|---|---|
| 1 to 3 | Product and supplier identity, hazard classification, composition with CAS numbers | Marketplace onboarding, tenders |
| 4 to 6 | First aid, fire fighting media, spill and release handling | Warehouse and EHS programmes |
| 7 and 8 | Handling and storage conditions, exposure controls and protective equipment | Staff who repack or display the cells |
| 9 and 10 | Physical and chemical properties, stability and conditions to avoid | Engineering and QA questions |
| 11 and 12 | Toxicological and ecological information | Retailer sustainability screening |
| 13 | Disposal and end-of-life handling | Waste contractors and take-back schemes |
| 14 | Transport: UN number, class, packing and special provisions | The forwarder's decision |
| 15 and 16 | Regulatory information, revision history and issue date | Your own compliance file |
Section numbering follows the sixteen-part GHS layout that Annex II to REACH fixes for the EU. On most sheets the revision date sits in section 16 and is repeated on page one, which is the copy a compliance team will read first.
How does the sheet change with the chemistry?
The chemistry decides the transport half of the sheet, and it is that half which stops consignments. Alkaline, zinc-carbon, silver-oxide and zinc-air primary cells are not classified as dangerous goods, so section 14 says the cargo is not regulated. Lithium cells are treated differently in every mode of carriage.
| Family | Transport status | What section 14 has to say |
|---|---|---|
| Alkaline — LR6, LR03, LR14, LR20, 6LR61 | Not dangerous goods | Not regulated; no UN number or class |
| Zinc-carbon — R6P, R03, 6F22 | Not dangerous goods | Not regulated; no UN number or class |
| Lithium manganese — CR coin cells | Class 9 dangerous goods | UN 3090 as cells alone, UN 3091 packed with or in equipment |
| Silver oxide — SR watch cells | Not dangerous goods | Not regulated; no UN number or class |
| Zinc air — hearing aid cells | Not dangerous goods | Not regulated; no UN number or class |
Transport classification by chemistry. The lithium line is the one that also needs a test summary in the same folder, which is a separate document with its own content rules.
This is where the two documents people confuse get separated. A UN38.3 summary exists because a lithium design had to pass eight transport tests; it is issued for the lithium range and has no equivalent for alkaline cells, because nothing was tested and nothing needed to be. Our compliance pages set out which of our ranges carries which document, and the test summary guide walks through the eight tests and the ten items a summary has to contain.
What does a forwarder check before the cargo flies?
Four consistency checks, and none of them is about chemistry. Does the product named on page one match the invoice and the packing list; does section 14 carry the same UN number the booking uses; does the goods description match the test summary in the same folder; and is the sheet the current revision.
A mismatch on any of those four is what turns a routine booking into a two-day delay, and it is almost always a paperwork mismatch rather than a safety problem. The cell did not change; the description on the sheet was written for a different model or a different chemistry than the one in the carton.
When is an “MSDS certificate” not a certificate?
When nobody issued a certificate — which is every time. Neither the UN Model Regulations nor the GHS define an MSDS certificate, and no testing house can certify a document whose content is compiled from composition data rather than measured in a lab. A stamp or a chamber-of-commerce seal on the cover changes nothing.
What a stamped cover does achieve is confusion in a tender pack, where a reader may take it as evidence that the cell passed something. Four questions separate the two:
- Who issued the sheet — the factory that makes the chemistry, or a third party?
- What revision date is printed, and does it postdate the last change to the composition?
- Which chemistry and which model family does page one name?
- Does section 14 describe the mode of carriage you are actually using?
If the answer to the second or the fourth is vague, the sheet is a placeholder, and a placeholder in a customs file is worse than a gap because it looks finished.
What should you ask a supplier for, in one email?
Ask for five things at once, name the models, and say which market the goods are going to. Suppliers answer faster when the request is a list rather than a question, and a named market saves a round of correspondence about which document set applies.
- The safety sheet for each chemistry in the order, current revision, as a PDF
- The revision or issue date, and whether the sheet names the model family or only the chemistry
- The transport classification per chemistry, matching the mode you are booking
- The UN38.3 test summary as well, if any line in the order is lithium
- The EU declaration of conformity per model, if the destination is in the European Union
Two of those five are frequently missing: the revision date, because a PDF that has been forwarded three times loses its thread, and the model family, because sheets are written for a chemistry and tenders are written for a part number.
How do you get the sheet for our cells?
Ask with the model list for the project, and tell us where the goods are going. Every shipment leaves with the safety sheet for the chemistry actually ordered, alongside the EU declaration of conformity; lithium lines also carry the UN38.3 transport documentation, and alkaline and silver-oxide lines do not, because they are unregulated for transport.
If the request is for a tender or a marketplace account rather than a shipment, say so — the file those reviewers want is usually wider than the one that travels with a carton, and it is cheaper to assemble it once than to answer questions one document at a time. The document set for an order is described on the downloads page, and the model data sheets behind it are per model.
Where the claims on this page come from
The regulatory statements on this page are checked against primary texts rather than trade summaries, because the gap between an obligation and a habit is exactly where battery paperwork goes wrong. Where a claim rests on our own documents, it restates a split already published on the site.
- OSHA 29 CFR 1910.1200(c), the definition of “article”, and OSHA’s letter of interpretation of 1 December 2022 on lithium-ion cells and packs
- The GHS, section 1.3.2.1.1, on the scope of the system and the treatment of articles
- REACH Regulation (EC) 1907/2006, Article 31 on safety data sheets for substances and mixtures, and Article 33 on information on substances in articles
- CLP Regulation (EC) 1272/2008, which carries the GHS hazard classification and labelling into EU law; the sixteen-section sheet layout itself sits in Annex II to REACH, as amended by Commission Regulation (EU) 2020/878
- ANSI C18.4M on portable cells and batteries, which provides a template for an article information sheet
- Published document libraries from Duracell, Energizer, Panasonic and FDK, used here only as examples of the titles in circulation
- Our own transport statements on the certifications page, and the range-by-range split already published in the UN38.3 guide
No capacity, voltage or certification number is asserted on this page that is not already published elsewhere on the site. Where a figure depends on the model, the model data sheet is the document to read.