Which UN3481 rules apply to lithium-ion batteries?

UN3481 is the classification code for lithium-ion batteries that are packed with equipment or contained in equipment. This also includes lithium-ion polymer batteries. This classification falls under the international regulations for dangerous goods.

The applicable transport rules depend, among other things, on three factors:

• Watt-hour rating: for certain simplified provisions, a maximum of 20 Wh per cell and a maximum of 100 Wh per battery
• Configuration: whether the battery is packed with equipment or contained in equipment
• Condition of the battery: new, used, damaged or defective

In addition, lithium-ion cells and batteries must generally comply with the applicable requirements of the UN Manual of Tests and Criteria, Part III, subsection 38.3. Specific alternative provisions exist for certain prototypes and small production runs.

It is essential to distinguish between lithium-ion batteries (UN3480/UN3481) and lithium metal batteries (UN3090/UN3091). Lithium-ion batteries are generally rechargeable. Lithium metal batteries are generally non-rechargeable and contain metallic lithium or a lithium alloy. This difference partly determines which UN number applies to your shipment.

The configuration is also decisive. Lithium-ion batteries shipped on their own fall under UN3480. When they are packed with equipment or contained in equipment, the UN3481 rules apply. The equipment must be the device for which the battery is intended to provide electrical power.

The overview below shows the difference between UN3481, UN3090, UN3480 and UN3091 at a glance.

Scroll from right to left

For air transport, UN3481 lithium-ion batteries with a capacity above 20 Wh per cell or 100 Wh per battery fall under Section I of PI 966 or PI 967. Cells up to 20 Wh and batteries up to 100 Wh may, when all other conditions are met, fall under Section II.

Make sure you determine the correct UN number before shipping: incorrect classification can result in rejection of your shipment, fines or safety risks during transport.

Unsure which UN number applies to your shipment? The step-by-step guide below helps you quickly work through the lithium battery classification and determine whether your shipment falls under UN3481, UN3090, UN3480 or UN3091.

1. Determine the battery type
   Check whether it is a lithium-ion battery or a battery containing metallic lithium or a lithium alloy. Lithium-ion batteries are generally rechargeable.
   Lithium-ion → go to step 2. Lithium metal → you fall under UN3090 or UN3091.
2. Check the configuration
   Are the batteries shipped on their own, contained in equipment, or packed together with the equipment for which they are intended but not installed?
   Standalone lithium-ion battery → UN3480. Lithium-ion battery contained in or packed with equipment → UN3481.
3. Check the Watt-hour rating
   Check the Watt-hour rating per cell and per battery. For UN3481 and UN3480, threshold values of a maximum of 20 Wh per cell and a maximum of 100 Wh per battery apply for certain simplified provisions.
   Above these thresholds? Then the fully regulated requirements apply and certain simplified provisions are not available.
4. Check whether a simplified provision applies
   Determine whether your shipment complies with the conditions for Section II of the applicable IATA Packing Instruction or Special Provision 188 (SP188) under ADR, RID or IMDG. These provisions only apply when all associated requirements relating to capacity, packaging, protection and testing are met.
   Simplified provision applies → certain documentation, packaging and labelling requirements are simplified. No simplified provision applies → the full requirements apply.
5. Consult the mode-specific Packing Instruction
   Select the correct Packing Instruction based on the mode of transport: PI 966 for UN3481 lithium-ion batteries packed with equipment and PI 967 for UN3481 lithium-ion batteries contained in equipment. For fully regulated road shipments, P903 is the standard Packing Instruction under ADR. Always check the latest edition of the relevant regulations, as requirements are periodically revised.
   You have now determined the correct UN number and the applicable Packing Instruction and can prepare your shipment correctly.

For air transport, IATA explicitly links UN3481 to PI 966 for packed with equipment and PI 967 for contained in equipment.

Specific packaging requirements apply to UN3481 lithium-ion batteries to ensure that they can be transported safely. These requirements are laid down in Packing Instructions that may differ by mode of transport.

Packaging requirements

• Batteries must be protected against short circuit
• Equipment containing installed batteries must be protected against unintentional activation during transport where such activation could result in dangerous heat generation
• Batteries and equipment must be protected against damage during transport
• Batteries packed with equipment must be secured in such a way that unwanted movement within the package is prevented
• For UN3481 batteries packed with equipment under IATA PI 966 Section II, the completed package must be capable of withstanding a 1.2-metre drop test in accordance with the Packing Instruction
• For certain non-UN specification packages under PI 966 Section II and PI 967 Section I and II, an additional requirement applies whereby the package must be capable of withstanding a stacking load equivalent to a 3-metre stack height for 24 hours

IATA specifically links the 1.2-metre drop test to, among others, PI 966 Section II; this requirement therefore does not apply indiscriminately to every UN3481 package. Since 2025, the 3-metre stacking capability also applies to, among others, PI 966-II and PI 967-I and II when non-UN specification packaging is used.

Marking and labelling

The required marking and labelling depend on the applicable mode of transport and the Packing Instruction and Section under which the shipment falls.

For fully regulated IATA shipments under Section I, requirements include:

• UN number UN3481 and the correct proper shipping name
• Proper shipping name: “Lithium ion batteries packed with equipment” or “Lithium ion batteries contained in equipment”
• Class 9 lithium battery hazard label
• Name and address of the shipper and consignee
• Cargo Aircraft Only label where applicable based on the way the shipment is offered for transport

For Section II, the battery mark with UN3481 applies where required. This mark shows a group of batteries, one of which is damaged and emitting a flame. It is therefore not a label featuring an aircraft symbol.

Exceptions to the battery mark apply under PI 967 Section II. For example, the mark is not required for packages containing only button cells installed in equipment. The mark may also be omitted for small consignments where the shipment consists of no more than two packages and each package contains no more than four cells or two batteries installed in equipment.

Documentation

The required documentation depends on the applicable provision.

For fully regulated air shipments under Section I, a “Shipper’s Declaration for Dangerous Goods” is required.

For UN3481 shipments that fully comply with Section II of PI 966 or PI 967, no Shipper’s Declaration for Dangerous Goods is required. Where a battery mark is mandatory for a Section II shipment and an air waybill is used, the applicable compliance statement must be included on the air waybill.

In addition, manufacturers and subsequent distributors must make a UN 38.3 test summary available for most lithium-ion cells and batteries manufactured after 30 June 2003. This test summary does not normally have to accompany every shipment as a paper document.

Packaging requirements may vary depending on the size, configuration, capacity and condition of the battery. Therefore, always consult the latest Packing Instructions that specifically apply to your type of lithium-ion battery.

With UN3481, it is not just about the correct label, document or UN number. Classification is an important starting point, but real safety only arises when the regulations are properly translated into the packaging itself. A shipment may be formally classified correctly, yet still pose a risk in practice if the equipment can move inside the packaging, terminals are insufficiently protected against short circuit, heat generation has not been properly considered or the packaging is not suitable for the selected mode of transport.

That is why at Faes we look beyond the outside of the packaging. We assess the entire system: the battery configuration, the equipment in which the battery is incorporated, the vulnerability of the product, the way it is handled, the storage conditions and the route the shipment will take. It also matters whether the shipment involves batteries installed in equipment, batteries supplied with equipment, prototypes, return flows or products that are intensively used in the field. Each situation places different requirements on protection, securing, accessibility and documentation.

Based on this analysis, we develop packaging solutions that align with both the regulations and practical use. Examples include custom cases, internal securing systems, protective foam interiors, compartmentalisation and provisions for marking and documentation. Where necessary, we advise on specifications, testing requirements and the practical translation of standards into a workable solution.

This integrated approach is particularly important for equipment containing lithium-ion batteries. The packaging should not only help prevent damage during transport, but should also contribute to clarity and control throughout the logistics chain. This is why at Faes we do not translate UN3481 into a standard package with a label, but into a robust and practical transport solution that is correct both on paper and in practice.

The rules for transporting UN3481 lithium-ion batteries differ by mode of transport. Each mode has its own requirements that must be complied with.

Road transport (ADR)

• Follows the ADR regulations for the international carriage of dangerous goods by road
• For fully regulated shipments, the applicable requirements for packaging, documentation, marking and labelling apply
• Whether a driver requires an ADR driver training certificate depends, among other things, on the applicable exemptions and the manner and quantity in which the dangerous goods are transported
• Special Provision 188 (SP188) may apply to lithium-ion cells up to 20 Wh and batteries up to 100 Wh, provided all conditions of SP188 are met
• For standard fully regulated shipments, P903 is the relevant Packing Instruction; other requirements and Packing Instructions may apply to damaged or defective batteries, for example

ADR 2025 has applied since 1 January 2025. The 20 Wh/100 Wh thresholds form part of the conditions of SP188 for lithium-ion batteries.

Sea transport (IMDG)

• Follows the IMDG Code (International Maritime Dangerous Goods Code)
• Requires packaging, protection against short circuit, marking, labelling and documentation in accordance with the applicable IMDG provisions
• Special Provision 188 may apply when all its conditions are met
• Specific stowage and handling provisions may apply
• Additional requirements apply to damaged or defective lithium-ion batteries

Since 1 January 2026, the IMDG Code 2024 Edition, including Amendment 42-24, has been mandatory.

Air transport (IATA/ICAO)

• Follows the IATA Dangerous Goods Regulations and the ICAO Technical Instructions
• UN3481 batteries packed with equipment fall under PI 966
• UN3481 batteries contained in equipment fall under PI 967
• Distinguishes between Section I and Section II, depending on factors including the Watt-hour rating and the conditions met by the shipment
• Distinguishes between transport on passenger aircraft and cargo aircraft, with different maximum quantities per package
• Personnel preparing fully regulated dangerous goods must comply with the applicable dangerous goods training requirements; for Section II shipments, an adequate instruction requirement applies
• Airlines may impose additional conditions through operator variations

For UN3481, IATA specifies a maximum net battery weight per package under PI 966 and PI 967 Section I of 5 kg on passenger aircraft and 35 kg on Cargo Aircraft Only shipments; for Section II, the limit is 5 kg per package.

Rail transport (RID)

• Follows the RID regulations (Regulations concerning the International Carriage of Dangerous Goods by Rail)
• Is harmonised with ADR for many lithium battery provisions
• Special Provision 188 may apply when all conditions are met
• For fully regulated shipments, the applicable packaging, marking, labelling and documentation requirements apply
• Additional provisions apply to damaged or defective lithium batteries

The current edition is RID 2025.

Air transport is subject to additional restrictions that do not apply in the same way to road, sea and rail transport, including specific Packing Instructions, Section classifications, quantity limits and State of Charge requirements. For all modes of transport, personnel involved must comply with the training or instruction requirements applicable to the relevant activity and regulatory provision.

State of Charge during shipment: what are the requirements?

The State of Charge (SoC) indicates the charge level of a battery as a percentage of its maximum capacity. For UN3481 lithium-ion batteries, the SoC is particularly important in air transport.

For lithium-ion batteries packed with equipment under IATA PI 966, stricter requirements have applied since 1 January 2026:

• PI 966 Section I: lithium-ion cells and batteries must be offered for transport at a State of Charge not exceeding 30% of their rated capacity
• PI 966 Section II: cells and batteries with a Watt-hour rating above 2.7 Wh must be offered for transport at a State of Charge not exceeding 30%
• A SoC above 30% in these situations is only permitted under the applicable approval procedure and conditions imposed by the competent authorities

For lithium-ion batteries contained in equipment under PI 967, the 30% limit is not a general mandatory requirement. However, IATA strongly recommends that these batteries be offered for transport at a State of Charge not exceeding 30% of rated capacity or an indicated battery capacity not exceeding 25%.

The SoC requirements should therefore not be confused with the classification as UN3481: UN3481 is determined by the battery type and configuration. The SoC then partly determines the transport conditions with which the shipment must comply.

Additional restrictions apply to damaged or defective lithium batteries. Lithium-ion batteries identified by the manufacturer as defective for safety reasons, or that are damaged to such an extent that they may produce dangerous heat, fire or short circuit, are forbidden for air transport. This also applies when the battery is installed in equipment.

There are various simplified provisions and special arrangements that may simplify the transport of UN3481 lithium-ion batteries under certain conditions. These provisions do not mean that no requirements apply.

The main provisions are:

• Smaller lithium-ion cells and batteries: cells up to 20 Wh and batteries up to 100 Wh may, depending on the mode of transport and provided all other conditions are met, make use of simplified provisions
• IATA Section II: smaller UN3481 batteries may fall under PI 966 Section II or PI 967 Section II when the applicable conditions are met
• Special Provision 188: under ADR, RID and IMDG, SP188 may exempt lithium-ion cells and batteries that fully comply with its conditions from many of the other dangerous goods provisions
• Batteries contained in equipment: UN3481 batteries actually installed in equipment are subject in certain respects to different requirements from batteries that are merely packed with the equipment
• Personal carriage: separate provisions exist for passengers and private carriage; these may not automatically be applied to commercial freight shipments
• Prototypes and small production runs: specific provisions and approval procedures exist for cells and batteries that have not yet been tested in accordance with UN 38.3, or for certain small production runs; this is not a general exemption

IATA explicitly distinguishes between Section I and Section II for UN3481 under both PI 966 and PI 967. Under land transport regulations, SP188 is the specific simplified provision for smaller lithium-ion batteries; “Limited Quantities” should not be regarded as a separate general exemption route for UN3481.

Even when a simplified provision is used, basic requirements remain in force depending on the applicable provision, including:

• Protection against short circuit
• Protection against damage
• Suitable and sufficiently strong packaging
• Correct marking and labelling where required
• Compliance with the applicable testing requirements
• Required training or adequate instruction of personnel

Always check the most recent regulations before applying an exemption or simplified provision, as the requirements are periodically updated.

Navigating the complex rules surrounding UN3481 lithium-ion batteries requires care and attention to detail. Correct classification, packaging, marking and documentation are essential for safe and compliant shipment.

By understanding the specific requirements for different modes of transport and knowing which simplified provisions may apply, you can ensure that your lithium-ion batteries are transported safely and in accordance with the applicable regulations. This helps prevent delays, rejected shipments, fines and safety risks.

At Faes, we understand the challenges involved in transporting sensitive and dangerous goods such as lithium batteries. As a specialist in packaging solutions for the defence sector and other regulated industries, we can help you with packaging that aligns with the relevant UN and transport regulations while optimally protecting your valuable equipment. Would you like to know more? Visit our Lithium-ion packaging page or contact us.