Customs Requirements for Exporting Lithium Batteries

Lithium batteries are extensively utilized in electronic devices, electric vehicles, and energy storage systems. With a growing number of lithium batteries being exported internationally, there is significant interest among exporters regarding the procedures for their smooth customs clearance. This article provides a detailed guide on the subject.

1. Definition and Classification of Lithium Batteries

A lithium battery is defined as a battery that employs lithium metal or lithium alloy as the negative electrode material and utilizes a non-aqueous electrolyte solution.

Lithium batteries are broadly categorized into two types: lithium metal batteries and lithium-ion batteries. Lithium metal batteries are typically non-rechargeable (primary batteries), such as Button Cells. Lithium-ion batteries are rechargeable (secondary batteries), such as those found in mobile phones.

2. Customs Supervision Requirements for Exporting Lithium Batteries

The “Law of the People’s Republic of China on Import and Export Commodity Inspection” stipulates that manufacturers of packaging intended for exporting dangerous goods must have the packaging design type tested by Customs. Furthermore, producers of dangerous goods for export must have the packaging inspected for its proper use (transport preparation) by Customs. Dangerous goods packed in non-certified packaging are prohibited from export. Consequently, for lithium battery products requiring dangerous goods packaging, exporters must not only use packaging that has passed design type testing but also apply to their local Customs for a packaging use inspection (transport approval).

(1) Design Type Testing for Export Lithium Battery Packaging

The applicant for the design type test is the packaging manufacturer. Customs administers a code system for such enterprises. A manufacturer must apply to its local Customs to obtain an export dangerous goods packaging manufacturer code before it can apply for the design type test. The validity period of the test report is determined by the packaging material and the nature of the contents. For lithium battery packaging, the validity is generally no more than 12 months from the date of container manufacture.

(2) Use Inspection for Export Lithium Battery Packaging

The applicant for the use inspection is the manufacturer of the lithium battery goods (the exporter). Prior to application, the enterprise should complete the following key preparations:

The lithium battery must be marked with its Watt-hour (Wh) rating. Each cell or battery must comply with all test requirements outlined in Section 38.3 of Part III of the UN Manual of Tests and Criteria (e.g., altitude simulation, thermal cycling). Testing is typically conducted by accredited laboratories which provide the requisite report.

The packaging used must have passed design type testing, and the corresponding “Performance Test Report for Inbound/Outbound Goods Packaging” must be obtained.

The packaging must bear clear, permanent, and correct markings, including the applicable UN number, the UN symbol, and the Class 9 dangerous goods label, all conforming to regulatory specifications.

Information on the packaging (name, specification/model, tare weight, user) must correspond with the details in the performance test report and related documents. The physical packaging used, its markings, and batch numbers must match the declarations.

Boxes are commonly used for lithium battery exports. The relevant Packing Instructions require the packaging to meet the performance level of at least Class II packaging (Packaging Group II). Batteries or battery packs must be secured within the packaging to prevent damage from movement. Batteries or battery packs exceeding 12 kg in gross weight, or those assembled with robust, impact-resistant casings, require additional sturdy outer packaging, protective overpacks, or load-bearing devices like pallets.

For wooden or fiberboard boxes fastened with nails, nails must be driven solidly and clenched; no nail points or heads may protrude. The box must be intact, secured with tight strapping. Corrugated boxes must be undamaged, sealed flat and firmly, with tight strapping.

Batteries packed with equipment have two approved configurations: a) Batteries are placed in regulation-compliant inner packaging, which is then placed with the equipment in an outer box; or b) Batteries are installed in the equipment, and the equipment is then placed in regulation-compliant packaging.

Any other special packaging provisions for lithium batteries specified in international transport regulations (e.g., IATA DGR, IMDG Code) must be followed.

3. Guidance on Common Export Issues for Lithium Batteries
4. How to determine the correct UN number for lithium battery products?
   According to the UN Model Regulations, cells and batteries, batteries contained in equipment, or batteries packed with equipment containing any form of lithium must be assigned one of the following four UN numbers as applicable:

UN 3090: Lithium metal batteries (including lithium alloy batteries)

UN 3091: Lithium metal batteries contained in equipment or packed with equipment (including lithium alloy batteries)

UN 3480: Lithium ion batteries (including Li-ion polymer batteries)

UN 3481: Lithium ion batteries contained in equipment or packed with equipment (including Li-ion polymer batteries)

How is Special Provision 188 applied?
If lithium batteries fully comply with all tests in UN Manual of Tests and Criteria, Part III, Section 38.3, and meet all conditions specified in Special Provision 188 (Chapter 3.3) of the UN Model Regulations, the exporter may be exempt from applying for the packaging use inspection. It is critical to verify full compliance with all clauses of SP188.