Transporting lithium batteries under ADR

Batteries for e-bikes, power tools, laptops and energy storage end up on almost every delivery round now. Under ADR they are Class 9. Whether a consignment needs the full treatment, with danger labels, a transport document and a transport category, or just a mark on the box comes down to three questions: what kind of battery is it, how big is it, and is it in good condition? The ADR exam asks the same questions.

Picking the UN number

Cells and batteries containing lithium in any form are assigned to one of four UN numbers (ADR 2.2.9.1.7.1):

UN number	What is carried
UN 3480	Lithium ion batteries on their own
UN 3481	Lithium ion batteries contained in equipment or packed with equipment
UN 3090	Lithium metal batteries on their own
UN 3091	Lithium metal batteries contained in equipment or packed with equipment

‘Contained in equipment’ means the battery is fitted in the device, a cordless drill for example. ‘Packed with equipment’ means the drill and a spare battery share the same box. Equipment powered by lithium batteries, such as lawn mowers or model aircraft, also goes under UN 3091 or UN 3481 (ADR 3.3.1, special provision 388). Batteries installed in a container that only supply power outside it have their own entry, UN 3536 (ADR 3.3.1, special provision 389). Table A also lists sodium ion batteries with an organic electrolyte, UN 3551 and UN 3552, which carry label 9A as well.

No UN 38.3 test, no transport

Before a lithium battery can travel under these entries at all, it has to meet a set of conditions (ADR 2.2.9.1.7.1 (a) to (g)):

• Every cell and battery is of a type proved to meet all the tests in the Manual of Tests and Criteria, Part III, sub-section 38.3.
• It has a safety venting device or is designed to preclude a violent rupture under normal conditions of carriage, and it has an effective means of preventing external short circuits.
• Batteries with cells connected in parallel are protected against dangerous reverse current, for example by diodes or fuses.
• It is made under a quality management programme.
• For cells and batteries manufactured after 30 June 2003, manufacturers and later distributors make the test summary set out in 38.3.5 available. Button cells installed in equipment are exempt.

Lithium batteries that meet neither these requirements nor special provision 188, 230, 310, 636 or 670 are not accepted for carriage (ADR 2.2.9.2). Separate rules cover prototypes and low production runs (special provision 310) and damaged batteries (special provision 376).

Small batteries under special provision 188

Small cells and batteries are not subject to the rest of ADR as long as every condition of special provision 188 is met (ADR 3.3.1):

• Cell: no more than 1 g of lithium (lithium metal) or no more than 20 Wh (lithium ion).
• Battery: no more than 2 g of lithium in total, or no more than 100 Wh. Lithium ion batteries show the watt-hour rating on the outside case, unless they were made before 1 January 2009.
• Packaging: loose cells and batteries in inner packagings that enclose them completely and protect against short circuits, inside a strong outer packaging.
• Drop test: the package survives a 1.2 m drop without damage to the batteries, unless they are fitted in equipment.
• Weight: no more than 30 kg gross per package, unless the batteries are fitted in or packed with equipment.

Each of these packages carries the battery mark: a rectangle or square with red hatched edging and, in black, a group of batteries with one damaged and in flames above the UN number. It is at least 100 × 100 mm and may come down to 100 × 70 mm on a small package (ADR 5.2.1.9). The older version of the mark, valid until 31 December 2022, still had a box for a telephone number. It may be used until 31 December 2026 (ADR 1.6.1.49). The mark is not needed on packages containing only button cells fitted in equipment, or on consignments of no more than two packages, each holding no more than four cells or two batteries fitted in equipment (special provision 188 (f)).

When full ADR applies

Larger batteries travel as Class 9 dangerous goods. Table A gives UN 3090, 3091, 3480 and 3481:

• Label 9A on the package: seven black stripes at the top, a group of batteries with one on fire below (ADR 5.2.2.2.2). The other models are covered in our guide to danger labels.
• Placards: on the vehicle or container it is always model 9, never 9A (ADR 5.3.1.1.4).
• Transport category 2, which allows up to 333 kg per transport unit under the exemption (ADR 1.1.3.6.3). How to combine that with other goods is explained in the 1,000 points rule.
• Tunnel restriction code E, and no carriage as limited quantities: column (7a) shows 0.

Damaged batteries and batteries for recycling

A battery counts as damaged or defective when it no longer conforms to the tested type. That includes batteries that have leaked or vented, have mechanical damage or cannot be diagnosed before carriage (ADR 3.3.1, special provision 376). For these:

• pack to P908, or LP904 for large packagings;
• if the battery is liable to catch fire, overheat dangerously or give off toxic, corrosive or flammable gases under normal conditions of carriage, use P911 or LP906;
• mark the package ‘DAMAGED/DEFECTIVE LITHIUM ION BATTERIES’ or ‘DAMAGED/DEFECTIVE LITHIUM METAL BATTERIES’, and add ‘Transport in accordance with special provision 376’ to the transport document.

Waste batteries going for disposal or recycling may be packed to P909, mixed with other kinds of battery if needed. Paragraphs (a) to (g) of 2.2.9.1.7.1 do not apply to them, and the packages are marked ‘LITHIUM BATTERIES FOR DISPOSAL’ or ‘LITHIUM BATTERIES FOR RECYCLING’. Any damaged battery among them goes back under special provision 376 (ADR 3.3.1, special provision 377).

Put it into practice

With lithium batteries the battery mark and the 9A label are easy to mix up. Work out first what a consignment needs, then learn the special cases. Our guide to the dangerous goods classes explains what else falls under Class 9.

In the free test you get an explanation and the ADR reference after every answer. In the app you can drill every Class 9 question until it sticks.

Sources

ADR 2025: 1.6.1.49, 2.2.9.1.7.1 and 2.2.9.2, Chapter 3.2, Table A (UN 3090, 3091, 3480, 3481, 3536, 3551, 3552), Chapter 3.3 special provisions 188, 376, 377, 388 and 389, 1.1.3.6, 5.2.1.9, 5.2.2.2.2 and 5.3.1.1.4. In Great Britain, ADR applies through the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009. This guide explains the basics. For an actual consignment, the wording of ADR is what counts.