2025 HAZMATEAM LITHIUM AND SODIUM ION BATTERY SHIPPING GUIDE

Need help getting a lithium or sodium ion battery shipment out the door?    The 2025 HAZMATEAM Lithium and Sodium Ion Battery Shipping Guide summarizes lithium and sodium ion battery classification, package marks/labels, documentation and packaging requirements.  CLICK HERE TO DOWNLOAD the free HAZMATEAM Lithium and Sodium Ion Battery Shipping Guide (pdf).  See the LITHIUM BATTERY TRANSPORTATION NEWS section below for significant 2025 updates to the HAZMATEAM Lithium and Sodium Ion Battery Shipping Guide.  New to the 2025 HAZMATEAM Lithium and Sodium Ion Battery Guide - sodium ion batteries and updated battery powered vehicle shipping descriptions.   NOTE:  Some browsers may not support downloads; if this happens try switching to another browser.   For best results use Adobe Acrobat Reader.

Watch the video to see how to use the Guide:


 

            

           

LITHIUM BATTERY TRAINING COURSES

Training is required if you prepare a shipment of lithium batteries for transportation. HAZMATEAM offers several online and classroom lithium battery courses. The course you need is dependent upon which lithium battery you ship, the size of the battery and mode of transport. The grid below summarizes the online and classroom Lithium Battery courses offered at Hazmateam.

 
Course Battery Type Sizes Modes Approx. Duration
Lithium Batteries Rechargeable &
Non-Rechargeable
 All Sizes Ground (49 CFR), Air (IATA) & Vessel (IMDG)   10 - 11 hours
Lithium Batteries Ground & Air Rechargeable & Non-Rechargeable  All Sizes Ground (49 CFR) & Air (IATA)   8.5 - 10 hours
Small Lithium Batteries Rechargeable & Non-Rechargeable Small & Medium Ground (49 CFR) & Air (IATA) 7 - 8 hours
Lithium Ion Batteries by Ground Rechargeable Fully Regulated Ground (49 CFR) 6 - 7 hours
Classroom 8-Hour Transportation of Lithium Batteries Rechargeable & Non-Rechargeable All Sizes Ground (49 CFR) & Air (IATA) 8 - hours

* We offer an 8-hour classroom version of TRANSPORATION OF LITHIUM METAL AND LITHIUM ION BATTERIES that addresses ground (49 CFR) and air (IATA) transportation at the HAZMATEAM Training Center in Hudson, NH.

LITHIUM AND SODIUM ION BATTERY TRANSPORTATION NEWS

January 29, 2025 UPDATE

The 2025–2026 International Civil Aviation Organization’s Technical Instructions for the Safe Transport of Dangerous Goods by Air (ICAO Technical Instructions) and Amendment 42-24 of the International Maritime Organization, International Maritime Dangerous Goods Code (IMDG Code) include several updates to lithium battery transportation regulations.    The 66th Edition (2025) of the International Air Transport Association (IATA) Dangerous Goods Regulations (DGR), which are based on the ICAO Technical Instruction, and Amendment 42-24 of the IMDG Code include the following:

  1. Adoption of a new battery chemistry, “Sodium Ion Batteries”.    These batteries are rechargeable and are similar to Lithium Ion Batteries.      There are 3 new shipping descriptions:

    1. UN 3551, Sodium Ion Batteries
    2. UN 3552, Sodium Ion Batteries Contained in Equipment
    3. UN 3552, Sodium Ion Batteries Packed with Equipment

For air and vessel transportation there are two sizes of batteries and cells:  “small” and “fully regulated”.     The sizes are based on the watt hour rating of the cell or battery.   Small cells have a watt hour rating no greater than 20 Wh and small batteries have a watt hour rating no greater than 100 Wh.   There is a noteworthy twist to all of this is for air transport of UN 3551, Sodium Ion Batteries (no equipment).  According to IATA PI 976, UN 3551 shipped air, there are no “small” cells and batteries.    Therefore, all UN 3551 cells and batteries shipped air transport, regardless of the watt hour rating, are “fully regulated”.

  1. Adoption of three new shipping descriptions for battery powered vehicles.     A “vehicle” is a self-propelled apparatus designed to carry one or more persons or goods.    The new shipping descriptions are:

    1. UN 3556, Vehicle, Lithium Ion Battery Powered
    2. UN 3557, Vehicle, Lithium Metal Battery Powered
    3. UN 3558, Vehicle, Sodium Ion Battery Powered 

These shipping descriptions are to be used instead of UN 3171, Battery-Powered Vehicle.   Although you may continue to use UN 3171 until 31-March 2025.

Most noteworthy battery powered vehicle updates are:

  1. Use of the “Class 9  Lithium or Sodium Ion Battery label”, instead of the “Class 9 label”.

  1.  For vessel transport, the exception for package marks/labels and placarding vehicles was eliminated in IMDG Amendment 42-24.      If a vehicle is packaged (the vehicle is not visible) and placed into a freight container, the package must be marked/labeled, and the freight container must be placarded.    This is described in updated IMDG special provisions 961 and 962.

  1. For air transport of UN 3556 and UN 3557, if the battery has a watt hour rating greater than 100 Wh, the battery state of charge should not exceed 30% of the rated design capacity or an indicated battery capacity not exceeding 25% capacity.   Effective 1-January 2026, “should not” will be replaced with “must not”.    This is described in IATA PI 952.

  1. Most notable updates to lithium ion batteries (UN 3480 and UN 3481) and lithium metal batteries (UN 3090 and UN 3091) are as follows:

  1. For air transport of all sizes of UN 3481, Lithium Ion Batteries Packed with Equipment, the battery state of charge should not exceed 30% of the rated design capacity.  Effective 1-January 2026, “should not” will be replaced with “must not”.    This is described in IATA PI 966.
  2. For air transport of all sizes of UN 3481, Lithium Ion Contained in Equipment, the battery state of charge should not exceed 30% of the rated design capacity.  This will remain a recommendation 1-January 2026.    This is described in IATA PI 967.
  3. For air transport of all sizes of UN 3481, Lithium Ion Batteries Contained in Equipment and UN 3091, Lithium Metal Batteries Contained in Equipment, the package must be capable of withstanding, without damage to the cells or batteries contained therein and without any reduction of effectiveness, a force applied to the top surface equivalent to the total weight of identical packages stacked to a height of 3 m (including the test sample) for a duration of 24 hours (the “stacking test”).    This is described in IATA PI 967 & 970.

These updates to the international regulations (ICAO/IATA & IMDG Code) have not yet been incorporated into 49 CFR 171-180.    However, according to a December 9, 2024 notice from PHMSA, if all or part of transportation is by air or vessel, PHMSA will allow use of these updated international rules.   For the full text of this notice please refer to:

https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/2024-12/Notice%20of%20Enforcement%20Policy%20Regarding%20International%20Standards%202024.pdf

As for ground transportation, DOT PHMSA has not made any updates to the lithium battery regulations.   Note that DOT PHMSA has not addressed ground shipments of Sodium ion batteries or the new battery powered vehicle shipping descriptions.    To ship Sodium Ion Batteries (UN 3551, UN 3552 or UN 3558), the December 9, 2024 PHMSA Notice allows the use of the IMDG Code for ground shipments.    As such, all of the ground shipping requirements in the HAZMATEAM Lithium and Sodium Ion Battery Guide for sodium ion batteries are based on IMDG Code requirements.   Those who ship lithium ion or lithium metal battery powered vehicles should continue to use "UN 3171, Battery-Powered Vehicles" for ground only shipments until DOT PHMSA issues a final rule sometime in 2025 (mid year??).

DOT PHMSA does not anticipate release of any updates to 49 CFR in the foreseeable future.   Updates will likely occur sometime in mid-year 2025.         Stay tuned….

April 12, 2024 UPDATE

A harmonization final rule, DOT HM-215Q, was issued by DOT PHMSA in the April 10, 2024 FR.    Highlights of this update includes:

1) Removal of the requirement to include a telephone number on the lithium battery handling mark, 49 CFR 173.185 (c)(3).    This update was recently made in the 64th Edition (2023) of IATA Dangerous Goods Regulations and the 41-22 Amendment (2022) of the IMDG Code.    All three regulations allow the old mark, with the telephone number, to be used until December 31, 2026  (DOT: 49 CFR 173.185 (c)(3); IATA DGR: 7.1.5.5; IMDG Code: 5.2.1.10.2).    

2) Removal of the exception in 49 CFR 173.185 (c)(4).  This air transportation exception allowed one package to contain up to 2 small lithium ion batteries (UN 3480) or 2 small lithium metal batteries (UN 3090) without a Dangerous Goods Declaration form.   This aligns with the update to the 63rd Edition (2022) of the IATA DGR that eliminated PI 965 Section II and PI 968 Section II.      So, all air shipments of any size UN 3480 or UN 3090 must be accompanied by a Dangerous Goods Declaration form.

On April 4, 2024 DOT PHMSA released the electronic versions of the 2024 Emergency Response Guidebook.   Updates relative to lithium batteries include an updated ERG GUIDE 147 (updated fire fighting procedures) and a new section "Considerations for Lithium Battery and Electric Vehicle (EV) Fires".    

HAZMATEAM Lithium and Sodium Ion Battery Shipping Guide Revision History

January 29, 2025 - Sodium ion batteries (UN 3551 and UN 3552) and Vehicle, Lithium Ion Battery Powered (UN 3556), Vehicle, Lithium Metal Battery Powered (UN 3557) and Vehicle, Sodium Ion Battery Powered (UN 3558).

April 11, 2024 - Updated lithium battery handling marks (removal of telephone number) per DOT HM-215Q.   Also, emergency response information  (ERG Guide 147) was updated following the April 4, 2024 release of the 2024 Emergency Response Guidebook.

January 1, 2024 - Addition of USPS hazmat rules.

January 19, 2023 - Correction to small UN 3091 air page

January 14, 2023 - Addition of activated tracking device rules; added a new OVERPACK guidance page; updates to the lithium battery handling mark; new markings according to 49 CFR 173.185 (c)(1)(iii)

January 1, 2022 - Removal of IATA PI 965/968 Section II

January 14, 2021 --- Emergency Response Guides information was updated to reflect the 2020 Emergency Response Guidebook.   A new “UN 3171, Battery-Powered Vehicle” section was added to the Guide.

January 3, 2020 --- Updated to reflect lithium battery test reports, use of the term ‘aggregate lithium content’ and segregation requirements if shipping per IATA PI 965 or 968.

March 18, 2019 … Updated to reflect HM-224I.  

October 21, 2018 ... Updated to reflect 2019 (60th Edition) IATA DGR and 2018, Amendment 39-18 of IMDG Code.  Shipping paper examples updated to reflect new IATA declaration format and hybrid battery description.

November 28, 2017 … Updated to reflect 2018 IATA DGR.   Sections added to the Guide: Package performance testing requirements and Emergency Response requirements.   We also doubled the number of shipping paper (BOL and declarations) examples and re-formatted the battery size definition sections for clarity.

March 31, 2017 … Incorporation of HM-215N following the re-release of the final rule on March 30, 2017.

March 15, 2017 … Incorporation of 27-Feb-2017 DOT Notice. Also, updated to clarify use of address labels on packages.

February 1, 2017… Removal of HM-215N requirements as a result of Regulatory Freeze executive memorandum

January 22, 2017…  Incorporated HM-215N DOT final rule

January 1, 2017 …Incorporated 2017 DOT, IMDG and IATA Updates

May 17, 2016 ... Incorporated 2016 ERG Guide pages; clarified scope of Guide; added disclaimer