Lithium Battery Transport: ADR & IATA DGR Rules

Lithium battery transport is one of the most error-prone areas in dangerous goods compliance — and one of the most enforced. Whether you move cells and batteries by air under the IATA DGR 67th edition or by road under ADR 2025, the same shipment can be fully regulated or lightly regulated depending on a handful of numbers and, critically, on which label or mark ends up on the box. This guide walks through classification, the all-important difference between the lithium battery mark and the diamond Class 9 label, packing instructions, and the documentation basics.

Why lithium batteries are dangerous goods (Class 9)

Lithium cells and batteries are assigned to Class 9 — Miscellaneous dangerous goods because they can short-circuit, overheat and ignite. Every lithium cell or battery type has a UN number that drives the rules:

• UN3480 — lithium-ion batteries shipped on their own.
• UN3481 — lithium-ion batteries packed with equipment or contained in equipment.
• UN3090 — lithium-metal batteries shipped on their own.
• UN3091 — lithium-metal batteries packed with or contained in equipment.

An adjacent, fast-growing case is sodium-ion: UN3551 (batteries) and UN3552 (packed with / contained in equipment), added to the regulations for 2025. They are also Class 9 and broadly mirror the lithium rules. Almost every cell must pass the UN 38.3 test series before it can move; keep the test summary on file. You can confirm the exact classification data for any of these entries with our ADR substance lookup.

Section I vs Section II — the thresholds that decide everything

Both IATA and ADR split lithium consignments by size. Smaller, lower-energy shipments fall into Section II (reduced requirements); anything above the limits is Section I / fully regulated. The boundary is set by energy and lithium content:

• Lithium-ion: Section II caps at 20 Wh per cell and 100 Wh per battery.
• Lithium-metal: Section II caps at 1 g lithium per cell and 2 g per battery.

On the air side, IATA further splits Section I of PI965/PI968 into Section IA (largest) and Section IB (cells/batteries at or below the Wh/g values above but exceeding Section II package quantity limits). The split changes the labels, paperwork and training you need. If you are unsure which side of the line a battery sits on, use the free calculators on the MYDG HUB before you build the package.

The lithium battery mark vs the Class 9 label — do not confuse them

This is where most non-compliance happens, so read it twice. There are two different graphics, and they are not interchangeable:

• The lithium battery mark is a rectangle with a red diagonal hatched border (minimum 5 mm wide) showing a group of batteries and the UN number(s).
• The Class 9 lithium battery hazard label is the black-and-white diamond with the "9" and the battery hatching. It is the hazard label for fully regulated shipments.

The rule of thumb: smaller Section II batteries carry the lithium battery mark and not the Class 9 label. Fully regulated (Section IA) shipments carry the diamond Class 9 label. IATA Section IB is the overlap case: it requires the Class 9 label and the lithium battery mark and the Cargo Aircraft Only label. Putting a Class 9 diamond on a package that only needed the mark — or shipping a fully regulated box with just the mark — is a classic rejection at the counter. We stock compliant, BS5609-durable versions of both graphics in the battery labels collection.

Packing by air — IATA DGR PI965 to PI970 and state of charge

Under the IATA DGR 67th edition, the packing instruction follows the UN number and the "with/contained in equipment" split:

• PI965 — UN3480, lithium-ion cells/batteries alone.
• PI966 — UN3481, lithium-ion packed with equipment.
• PI967 — UN3481, lithium-ion contained in equipment.
• PI968 — UN3090, lithium-metal cells/batteries alone.
• PI969 — UN3091, lithium-metal packed with equipment.
• PI970 — UN3091, lithium-metal contained in equipment.

Key air-only points to build into your process:

• State of charge: lithium-ion cells and batteries shipped alone (UN3480) — and sodium-ion under UN3551 — must be at a state of charge not exceeding 30% of rated capacity. Higher SoC needs State approval.
• Mark exemption: under Section II of PI967 and PI970, the lithium battery mark is not required on consignments of two packages or fewer where each package holds no more than four cells or two batteries installed in equipment.
• Quantity limits: for "packed with equipment" (PI966/PI969), the number of batteries is limited to what is needed to power the device plus two spare sets.

Air packaging must survive drop and stacking tests and prevent short circuits and movement. If your team is not current on the DGR, please contact us by email at contact@mydg.shop

Packing by road — ADR 2025 and Special Provision 188

On the road, ADR 2025 treats most everyday, tested lithium batteries as "excepted" under Special Provision 188 (SP188). To travel under SP188 the cells/batteries must be UN 38.3 tested, individually protected against short circuit, secured against movement, packed in strong outer packagings, and the package must display the lithium battery mark. SP188 also sets net-mass and per-package conditions — confirm the exact figures before you ship.

Batteries that exceed the SP188 limits are fully regulated under ADR and use the standard packing instructions:

• P903 — intact cells/batteries and equipment.
• P908 / P911 and LP904 / LP906 — damaged or defective cells/batteries (P911/LP906 for the higher-risk cases).
• P909 — batteries for disposal or recycling.
• P910 — small production runs and prototypes.

Fully regulated ADR packages carry the diamond Class 9 label, orange plates on the vehicle where required, and a transport document. A MYDG consultancy DGSA can confirm which packing instruction and marks your specific SKU needs.

Damaged batteries, overpacks and documentation

• Damaged, defective or recalled (DDR) batteries are high-risk: generally forbidden by air and, by road, requiring the stricter P908/P911 (or LP904/LP906) packagings with non-conductive, non-combustible cushioning. Never ship a swollen, hot or leaking battery as a normal consignment.
• Overpacks: mark the word "Overpack" on the outside and reproduce every required mark and label. An overpack does not downgrade the contents.
• Documentation: fully regulated shipments need a Dangerous Goods Declaration / transport document with UN number, proper shipping name, class, packing instruction and quantities. Section II air shipments need no DGD but still require the mark. Keep the UN 38.3 test summary on request.

Frequently asked questions

Is the lithium battery mark the same as the Class 9 label?

No. The lithium battery mark is a red-hatched rectangle used mainly on smaller Section II shipments, while the Class 9 hazard label is the black-and-white diamond used on fully regulated shipments. Section IB air consignments need both, plus a Cargo Aircraft Only label. Using the wrong one is a common reason packages are rejected.

What are the Section II limits for lithium batteries?

For lithium-ion, Section II applies at up to 20 Wh per cell and 100 Wh per battery; for lithium-metal, up to 1 g lithium per cell and 2 g per battery. Above these values the shipment is fully regulated (Section I). Verify each battery's Wh rating or lithium content against the manufacturer's data before you decide.

Can I ship a damaged lithium battery?

Damaged, defective or recalled lithium batteries are normally forbidden for air transport and, by road under ADR 2025, must use the specialised P908/P911 (or LP904/LP906) packagings. If a battery is swollen, hot, leaking or has been recalled, stop and get DGSA advice before moving it.

Ready to label correctly? Browse UN-certified lithium battery marks and Class 9 labels in the battery labels collection, or talk to our DGSA team if you are not sure which mark your shipment needs.

By the MYDG.SHOP Dangerous Goods Team — DGSA-certified