TIANQIUTwo documents arrive in the same email folder, both about lithium cells and transport, and both looking like proof that a shipment may fly. They answer different questions, and a buyer who reads them as one document ends up either paying for a report nobody asked for or sending a booking without the paper the forwarder actually wants.
The confusion is easy to explain. One is a test written into international transport law. The other is a standard published by an electrotechnical committee, which specifies a very similar test set and issues it under a different cover. The overlap is real; the difference is what each one obliges you to do.
What is IEC 62281?
IEC 62281 is the IEC standard for the safety of primary and secondary lithium cells and batteries during transport. Its scope is transport only, excluding recycling and disposal, and the current text is the 2019 fourth edition, amended in 2021 and again in 2023.
The fourth edition is the one to know, because it changed several things a buyer will notice. The definition of a button cell was revised and moved to coin, cells and batteries that form an integral part of equipment got their own provision, every test on a secondary cell now carries a preconditioning of twenty-five charge and discharge cycles, and the separate test report and test certificate clauses were merged into one list of required items. The edition also added an informative annex setting out where the standard departs from the UN Manual — a useful page for anyone comparing the two.
What is UN 38.3, and why does it decide whether cargo moves?
UN 38.3 is subsection 38.3 of Part III of the UN Manual of Tests and Criteria. It is the text the UN Model Regulations point at when they say a lithium cell or battery must have passed the tests before transport, and the modal rulebooks — the air, sea and road regulations — carry that requirement into their own wording.
Eight tests make up the series: altitude simulation, thermal cycling, vibration, shock, external short circuit, impact or crush, overcharge and forced discharge. Which of them apply depends on what is being tested, and the Manual prints a table for it. Since 1 January 2020 the test result alone is not enough: manufacturers and distributors have to make a test summary available, and that summary is the document your forwarder is checking. The Manual is revised on its own cycle — the eighth revised edition dates from 2023, and a further amendment was issued in 2025 — which is why item (i) of the summary is a reference to the edition used.
| What is being tested | Tests required | Where it is used |
|---|---|---|
| Cell | T.1 to T.6 and T.8 | The design evidence everything else rests on |
| Primary (non-rechargeable) battery | T.1 to T.5 | Battery built from cells already tested |
| Rechargeable battery | T.1 to T.5 and T.7 | Overcharge is a battery-level test |
| Cell inside a battery, not shipped separately | T.6 and T.8 | The battery carries the rest of the series |
Which tests apply to which article, from paragraph 38.3.2.1 of the Manual. Overcharge is the one test a coin cell never meets, because a primary cell has no charging regime to test against.
Which one is mandatory: the standard or the regulation?
The regulation is mandatory and the standard is not. A consignment needs evidence that the cell type passed UN 38.3, and in practice that evidence is the test summary; a 62281 report is not something a dangerous goods inspector will demand by default.
That does not make the standard optional in trade. Contracts, tenders and some national schemes name it, and a public buyer writing “IEC 62281” into a specification is entitled to receive a document issued against that standard. The practical rule for a sourcing team is short: ship on UN 38.3, and quote IEC 62281 when a customer’s paperwork asks for it by name.
Where do the two texts actually differ?
Less than the covers suggest, and what does differ is narrow: how a cell built into equipment and never shipped on its own is treated, how a rupture is judged, what the reporting clause requires you to hand over, and an annex that lists every deviation rather than leaving you to find them.
The annex is the most useful part for a buyer, because it is the standard’s own admission that the two documents are not identical. If a tender names one and the file you hold names the other, that annex is what a technical reviewer will read before deciding whether your report answers the question.
| Point | UN 38.3 | IEC 62281:2019 |
|---|---|---|
| Status | Law, through the modal regulations | Standard, named by contract or scheme |
| Document the supply chain hands over | Test summary, paragraph 38.3.5 | Test report to the item list in the standard |
| Cells integral to equipment | May be tested installed in the equipment | Own provision, clause 5.4, added in the fourth edition |
| How a rupture is judged | Ejection of solid components | Forcible added to the criteria in the fourth edition |
| Comparison between the two | — | Informative annex listing the deviations |
Read from the IEC catalogue description of the 2019 edition and paragraph 38.3.2.1 of the Manual. The comparison row is deliberately blank on the UN side: the UN text does not compare itself to anything.
Do coin cells need either one?
Yes, both routes reach a CR cell. A lithium metal coin cell is Class 9 dangerous goods whatever its capacity, so the eight tests apply to the cell type and a summary has to be made available for the consignment, exactly as for a much larger lithium battery.
Size changes the paperwork rather than the obligation. Cells shipped loose are UN 3090; cells packed with or inside a device are UN 3091; the packing instruction follows the route and the mode, and the shipping requirements guide takes the split mode by mode. The test evidence does not change with the pack format, which is why one report covers a model however it is later carded, blistered or boxed.
What has to be in the paper you hand over?
Ten items in the summary, and a good deal more in the report behind it. The summary is short on purpose: who made the cell, who tested it, the report number and date, a physical description with the watt-hour rating or lithium content, the tests with pass or fail against each, and a signature.
The report is the laboratory’s record and is where a technical reviewer goes when the summary raises a question. Neither is a certificate, and a stamped cover does not turn either into one. Our UN 38.3 summary guide walks the ten items one by one.
| Document | What it contains | Who asks for it |
|---|---|---|
| Test report | Samples, conditions, measurements, pass or fail per test | A customer's quality or engineering team, a tender |
| Test summary | The ten items defined in 38.3.5, no more | Forwarder, carrier, customs, marketplace onboarding |
| Certificate | An attestation from a body, not a test record | Some marketplace and retail programmes only |
Three documents, three readers. The summary is the one the transport chain is obliged to make available; the other two are commercial requests.
How do you read a report someone sends you?
Five checks settle most of it. Does the model on the cover match the invoice; is the cell lithium metal or lithium ion, which decides the UN number; is the test list complete for what ships; is the Manual edition one the current rules still accept; and does the summary carry a named signature.
A report that fails the first check is not necessarily wrong — one report can cover a family of models — but the model list has to say so. A report that fails the fourth is the common one: an old edition, cited confidently, that a booking clerk will not question and an inspector will. Our certifications page sets out which range carries which document.
What belongs in the request you send?
Ask for three things, name the models and name the market. The test summary for the cell type; the report behind it; and a line saying which standard each document was issued against, so nobody has to guess whether a 62281 report exists for the model you are buying.
Add the UN number you expect and the way the goods will travel. Those two lines remove the most common follow-up, which is not about testing at all but about whether the consignment is being described as cells alone or as cells in equipment. The shipping policy sets out how we describe a consignment by default.
How do you get these documents for our cells?
Name the model list and the destination market, and the answer comes back with the test summary for the lithium line and the report it rests on. Our alkaline, zinc-carbon and silver-oxide ranges travel without any of it, because they are not classified as dangerous goods; the CR range is the one that carries the lithium paperwork.
If a tender cites IEC 62281 by name, say so in the request. Whether a 62281 report exists is a question about a specific model rather than about the brand, and it is cheaper to settle that in one email than after the documents have been sent to a reviewer.
Where the claims on this page come from
Edition numbers, clause references and the deviation annex come from the published catalogue entries rather than from supplier summaries, because those summaries tend to merge the two documents into one. Where a statement rests on our own file, it repeats something already published on the site.
- IEC 62281:2019, fourth edition, consolidated with AMD1:2021 and AMD2:2023, “Safety of primary and secondary lithium cells and batteries during transport” — scope, the fourth-edition changes, and the informative annex on deviations from the UN Manual, as described in the IEC catalogue entry
- UN Manual of Tests and Criteria, Part III, subsection 38.3 — the eight tests, the table of tests required per article in 38.3.3, and the test summary requirement in 38.3.5
- The UN Model Regulations, which make the 38.3 tests a condition of transport and, since 1 January 2020, require the test summary to be made available through the supply chain
- The air, sea and road rulebooks that carry that requirement into their own provisions, and the UN numbers 3090, 3091, 3480 and 3481 that follow from it
- Our own transport statements on the certifications page, which set out which range carries which document
No test result, certificate number or capacity figure is asserted on this page for any model. Where the document depends on the model, the model list is what settles it.