Choosing the right entry
Lithium-ion batteries are Class 9 dangerous goods. A retired EV pack shipped on its own is normally UN 3480, lithium-ion batteries. If the battery is still installed in equipment, or packed with it, UN 3481 applies. Vehicles themselves have separate entries. Getting the entry right determines which packing instructions and special provisions apply.
The rules differ by mode: ADR for road in Europe and many other countries, RID for rail, the IMDG Code for sea and the ICAO Technical Instructions, applied through IATA rules, for air. National rules such as the US Hazardous Materials Regulations follow the same principles with their own details. Consignors must check the rules for every mode the shipment will use.
Batteries for recycling
Batteries carried for disposal or recycling are recognised as a distinct case. Under ADR, for example, special provisions and packing instructions such as P909 allow such batteries to be carried under specified conditions, while large batteries can use large packagings or be carried unpackaged in certain circumstances with appropriate protection. These provisions reflect the practical reality of moving used batteries in bulk.
Air transport is far more restrictive. Waste batteries and batteries for recycling are generally forbidden by air unless approved by the relevant authorities, and for most EV packs road and sea are the only realistic options. Planning logistics around that constraint avoids delays and non-compliant shipments.
| Situation | Typical references |
|---|---|
| Batteries for disposal or recycling | SP 377, P909, LP903/LP904 where applicable |
| Damaged or defective batteries | SP 376, P908, LP904 |
| Damaged and liable to react dangerously | SP 376, P911, LP906 |
| Large batteries in good condition | P903, LP903 |
Field note
Marking, labelling and documents
Packages must carry the UN number and the appropriate Class 9 lithium battery hazard label, and vehicles may need orange plates or placards depending on quantities. The transport document must show the UN number, proper shipping name, class, packing group where applicable and quantity, together with any special provision notes required for waste or damaged batteries.
Drivers need appropriate dangerous goods training, and consignors, packers and loaders each have defined responsibilities. Emergency information and contact details should travel with the load. Keeping a standard pack of documents for every collection reduces the chance of a shipment being stopped.
- UN number and Class 9 lithium battery label on each package
- Transport document with the correct shipping description
- Special provision references for waste or damaged batteries
- Trained driver and emergency contact information
