Lithium-ion battery shipping sees new regulations
The FBDi e.V. (German Professional Association of Component Distribution) summarizes the most important changes as follows:
Labeling requirement – The number of shipment items not subject to labeling requirements according to Pi 967 and PI 970 (max. 2 batteries / 4 cells) is limited to 2 per shipment. This affects lithium-ion and lithium-metal batteries integrated into a device. They require a label even where not more than 2 batteries or 4 cells per shipment are contained per shipment item (not subject to labelling), but more than 2 shipment items per shipment are shipped.
In principle, every packaging item containing lithium batteries (UN 3090, UN 3480) must bear a ‘Cargo Aircraft Only’ label, in addition to all other required marks and/or labels.
Instructions for shipment of Section II lithium batteries – Since 1 January 2017, the Dangerous Goods Regulations (Section 1.6.2) contains an exact definition of ‘sufficient instructions’ as required in the packaging requirements for persons who prepare or provide lithium batteries for shipment.
Changes in labelling and documentation – Since 1 January 2017, the previous Class 9 lithium battery label and lithium battery handling label (Section II) have been replaced by new Class 9 labels. There is a transitional period until 31 December 2018. Simultaneously, since the beginning of the year transport documentation for lithium batteries is no longer required.
New hazard label for lithium batteries;
The new 9A hazard label now expressly refers to the package contents with lithium batteries (instead of ‘miscellaneous substances and articles’ as previously with the Class 9 label). However, this is only valid for packaging lithium batteries, and its use is mandatory from 1 January 2019.
For labeling the outer envelopes (e.g. containers), the requirement only to use the Class 9 label for lithium batteries remains applicable. It is important to ensure that the label contains all UN numbers relevant to the contents. This also applies to the telephone number of the sender if it does not appear elsewhere. This is required so that information may be obtained from the sender if necessary.
“In this connection, we would like to draw attention to two more aspects”, says Wolfram Ziehfuss, Managing Director of the FBDi association. “An ancillary agreement must be concluded for the shipment of lithium-ion batteries subject to labelling requirements. Batteries integrated into boards (‘CoinCells’) are not subject to labelling requirements.”
A comprehensive set of guidelines is available on the IATA website: www.iata.org/whatwedo/cargo/dgr/Documents/lithium-battery-guidance-document-2017-en.pdf
The FBDi e.V. (www.fbdi.de) – Fachverband der Bauelemente Distribution e.V. (Professional Association of Component Distribution), founded in 2003, represents a large portion of distributors of electronic components with operations in Germany. In addition to the preparation and advancement of numerical data and statistics concerning the German distribution market for electronic components, work group engagement and reporting on important industry themes (amongst others, education, liability and rights, traceability, and environmental themes) form essential pillars of the association’s work. The FBDi is a member of the International Distribution of Electronics Association (IDEA).