Lithium Battery Shipping Requirements: What Each Mode Needs

A battery order is a dangerous goods question before it is a freight question, and two things decide the answer: the chemistry of the cells and the way they are packed. Our alkaline line is not dangerous goods at all. Our lithium coin cells are, and which rules apply to them changes with the packing scenario.

None of this is a supplier preference. The classification comes from international transport regulations, so it can be checked before a booking is made and compared between two quotations. What follows is how it works for our own range under the 2026 rules, with the source of every rule named at the end.

What decides how a lithium battery order is shipped?

Two decisions, taken in order. The chemistry decides whether the shipment is dangerous goods at all: alkaline, zinc-carbon, silver-oxide and sealed NiMH cells are not, while a lithium metal coin cell is. The packing scenario then decides which UN number, which packing instruction and which marks apply.

For our range, that puts the 22 alkaline models on one side and the 7 lithium models on the other. The CR cells — CR1025, CR1220, CR2016, CR2025, CR2032, CR2450 and CR2477 — are lithium metal, which is also why they are the only models with a UN38.3 test summary. Every alkaline and silver-oxide model travels as an ordinary consumer good, with a safety data sheet and nothing more.

Which UN number applies to your consignment?

A lithium metal cell or battery packed by itself is UN 3090. The same cell packed with equipment, or fitted inside it, is UN 3091. Our coin cells are lithium metal, so a carton of loose CR cells is UN 3090, and the same cells sitting in a sensor, meter or circuit board travel as UN 3091.

Inside UN 3090, one number decides how the carton is prepared: the lithium content of the cell. A cell of 1 g or less, or a battery of 2 g or less, goes under Section IB; above that threshold it goes under Section IA, which is a heavier regime. A coin cell is a fraction of that gram, and the exact figure for your model is printed on its UN38.3 test summary rather than quoted from memory.

Why can loose lithium cells not fly on a passenger aircraft?

Because the rules forbid the consignment outright. Every lithium metal cell or battery shipped by itself is forbidden as cargo on passenger aircraft, and the same sentence covers the smallest coin cell and the largest battery pack. A loose-cell order therefore moves on a freighter, and each package carries a Cargo Aircraft Only label.

The limits on that route are set per package: up to 2.5 kg net under Section IB on cargo aircraft, or 35 kg under Section IA with UN specification packaging. Section IB also expects packaging capable of a 1.2 m drop test and a 3 m stack test, which is a property of the pack design rather than of the label, so we confirm the format against your order instead of assuming it for every carton. There is one narrow exception — a consignment may travel on a passenger aircraft under state approval, which is how urgent medical cells move — and it belongs to your forwarder to arrange.

Cells fitted in equipment are treated differently. UN 3091 consignments prepared under Section II may fly on passenger aircraft up to 5 kg net per package, which is why a device programme and a loose-cell programme do not always ship the same way.

What has to be printed on the carton?

Which marks apply follows from the same classification, and the marks carry the UN number so that the package identifies itself. A UN 3090 carton carries the battery mark, the Class 9 lithium battery hazard label and the Cargo Aircraft Only label; a Section II carton of installed cells carries the battery mark alone.

Two details worth knowing when you inspect a carton. The mark may be printed directly on the outer packaging if there is enough contrast, so it does not have to be a separate label. And where any face of a package is large enough for the full-size mark, the full size has to be used — the reduced 100 x 70 mm version is for small packages only.

What paperwork travels with an air consignment?

Three documents cover it, and which one your forwarder asks for follows the same line. A fully regulated consignment needs a Shipper’s Declaration for Dangerous Goods. A Section II shipment of PI 969 or PI 970 needs a compliance statement on the air waybill instead. Every lithium shipment is backed by the UN38.3 test summary and a safety data sheet.

One exception trims the paperwork on small programmes. A consignment of no more than two packages, each holding at most four cells or two batteries installed in equipment, does not need the battery mark — and without the mark there is no waybill statement to make. Anything above that, including a normal carton count of loose cells, is marked. What has to appear in the test summary is set out in our UN38.3 test summary guide, and the wider document set behind an order is described in the certificates and documents guide.

Is sea freight different for the same cells?

Yes, and for small cells it is the easier route: the exemption is written into the sea rules rather than granted case by case. Under Special Provision 188 of the IMDG Code, a lithium metal cell of 1 g or less is not subject to the other provisions of the Code once its packaging conditions are met.

Those conditions are specific: each cell in an inner packaging that completely encloses it, protected against short circuit, in a strong outer packaging, each package capable of withstanding a 1.2 m drop without damage or content shift, and no more than 30 kg gross mass per package. What the exemption removes is the UN specification packaging, the Class 9 label and the shipper’s declaration. What it keeps is the battery mark, which still goes on the package.

The exemption is also why a sea booking of coin cells is quoted without a dangerous goods surcharge, while an air booking of the same carton is not. If your order mixes lithium-ion packs with coin cells, the packs are above the threshold and the shipment follows the fully regulated route — we flag that before booking rather than after the forwarder does.

Do alkaline and rechargeable cells need any of this?

No. Alkaline, zinc-carbon and silver-oxide cells are not dangerous goods: no UN number, no transport mark, no UN38.3 report. Sealed NiMH cells are not lithium either, so the same applies. Everything in this article concerns the lithium CR line, and it applies to the cells rather than to the brand on the jacket.

That distinction is worth holding on to at quotation stage. Two suppliers can quote an identical CR2032 with the same capacity and price, and only one of them will produce the test summary and the transport documents behind it. The per-model picture — standards, chemistries and which documents follow which line — is set out on our certification matrix, and the model pages carry the specification for each cell.

What should you send your forwarder?

Six facts cover it, and all six come from the quotation rather than from guesswork. Send them with the enquiry and the forwarder can classify the consignment, price the mode and book the space before production starts, instead of coming back with questions after the carton is built:

• The models and quantities. Model code, cell count and units per carton, so the lithium content and the net weight per package can be checked against the limit for the mode.
• The packing scenario. Cells loose in a carton, cells packed with equipment, or cells fitted inside it — that single answer decides UN 3090 against UN 3091 and the packing instruction that follows.
• Whether your order includes lithium-ion packs. Packs change the classification, the state-of-charge rule and the surcharge.
• The transport documents you need. Say which market is asking, and we send the matching safety data sheet and UN38.3 test summary for the models in the order.
• The destination and the delivery term. Port or airport, and whether the quotation is EXW, FOB, CIF or DDP decides who books the dangerous goods and who carries the liability.
• Any packaging rule that comes from your market. Child-resistant requirements sit on the pack design, not on the transport documents, and they are settled before artwork is printed rather than after.

The commercial side of the same shipment — what is declared on the invoice, how freight and duties are allocated, and what happens between production and delivery — is set out in our shipping policy. Passenger baggage is a different rule set and is covered in the batteries on a plane guide. First orders with us begin at 50 cartons per product line, and the transport documents are prepared per model, so a mixed order is covered line by line.

Where every claim here comes from

Nothing here is our own convention. Each rule below is traceable to the document that carries it, and the claims about our own range come from our published product data. The list names those sources, so a buyer, a forwarder or an auditor can check a classification without taking our word for it.

• Classification, UN numbers and packing instructions — the IATA Battery Guidance Document revised for the 2026 Regulations, built on the 2025-2026 ICAO Technical Instructions and the 67th edition (2026) of the IATA Dangerous Goods Regulations: UN 3090 for lithium metal batteries shipped by themselves (PI 968, Sections IA and IB), UN 3091 for cells packed with or contained in equipment (PI 969 and PI 970), UN 3480 and UN 3481 for lithium-ion.
• The passenger aircraft prohibition and the cargo limits — the same document: lithium metal cells and batteries shipped by themselves are forbidden as cargo on passenger aircraft, every PI 968 Section IA and IB package carries a Cargo Aircraft Only label, and the limits are 35 kg per package under Section IA and 2.5 kg under Section IB.
• The 1 g and 2 g thresholds — the classification flow chart for lithium metal batteries in the same guidance, which routes cells of 1 g or less and batteries of 2 g or less to Section IB of PI 968, and to Section I or II of PI 969 and PI 970.
• The marks and the waybill statement — the marking section of the same guidance: the battery mark is required under Section II of PI 966, 967, 969 and 970 and under Section IB of PI 965 and PI 968, alongside the Class 9 and Cargo Aircraft Only labels where those apply; its minimum size is 100 x 100 mm, reducible to 100 x 70 mm, with the UN number at least 12 mm high; the two-package exception covers four cells or two batteries installed in equipment.
• The rename of the mark — the significant changes list for the 66th edition of the IATA Dangerous Goods Regulations, effective 1 January 2025, which records the lithium battery mark being renamed the battery mark, and the transition that allows the earlier telephone-number format until 31 December 2026.
• The sea exemption and its conditions — Special Provision 188 of the IMDG Code Amendment 42-24, voluntary from 1 January 2025 and mandatory from 1 January 2026: the 1 g and 2 g thresholds, the inner and outer packaging conditions, the 1.2 m drop test, the 30 kg gross limit per package, and the battery mark with its exceptions for button cells installed in equipment.
• The test summary — paragraph 38.3.5 of the UN Manual of Tests and Criteria, Part III, sub-section 38.3, which requires manufacturers and distributors to make the summary available, and permits doing so by publishing it with a QR code or URL rather than on paper with every consignment.
• Our own lines and model counts — our published product data and the certification matrix: 22 Zn-MnO2 models, which are not dangerous goods, and 7 Li-MnO2 models, the lithium line, with UN38.3 applicable to the lithium models only.