Two classification systems
Waste batteries are classified under waste law and under dangerous goods transport rules. Waste law, for example the European List of Waste, assigns codes that determine permitted handling and whether the waste is hazardous. Transport rules, based on the UN Model Regulations, assign UN numbers such as UN 3480 for lithium-ion batteries shipped alone and UN 3481 for those packed with or contained in equipment.
The two systems answer different questions. A waste code tells authorities what the material is and how it may be managed. A UN number tells carriers how it must be packaged, labelled and moved. A consignment can be compliant under one and non-compliant under the other, so both need checking.
| System | Example | Purpose |
|---|---|---|
| UN dangerous goods | UN 3480 / UN 3481 | Transport packaging, labelling and carriage |
| Special provisions | Provisions for damaged or defective batteries | Additional transport controls |
| Waste list codes | Jurisdiction-specific battery waste codes | Permitted handling and reporting |
| Basel Convention | Entries for hazardous and other wastes | Transboundary movement controls |
Damaged, defective and end-of-life batteries
Transport rules treat damaged or defective lithium batteries more strictly than intact ones, because they are more likely to overheat or leak. Specific packaging instructions and special provisions apply, and some damaged batteries may be forbidden from certain modes of transport altogether. Classifying a damaged pack as a normal one is a serious error.
Batteries shipped for disposal or recycling also have their own provisions under the dangerous goods rules. Shippers should check the current edition of the relevant code, such as ADR for road transport in Europe, because provisions are updated regularly.
- Declare damage, swelling, leakage or thermal history before collection
- Use packaging approved for the declared condition
- Check the current edition of the applicable transport code
- Record the classification basis on the consignment file
The black mass question
Black mass sits between battery waste and a commodity intermediate. Several authorities have moved to classify it clearly as hazardous waste for shipment purposes, which brings prior notification and consent requirements under transboundary rules. The EU, for example, has taken steps to classify black mass as hazardous waste.
Because classification affects whether and how black mass can be exported, sellers and buyers should confirm the position in every jurisdiction involved before agreeing trade terms. Getting it wrong can mean shipments are held at the border or returned.