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How to Ship Batteries Internationally

Dangerous goods rules for exporting batteries: UN 2794, UN 2800 and special provision 238, lithium-ion UN 3480/3481, sodium-ion UN 3551/3552, IMDG vs IATA, packing and documents.

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Most batteries are regulated as dangerous goods in international transport, and the rules differ by battery type and transport mode: filled lead-acid, non-spillable and lithium-ion batteries each fall under different requirements. This guide summarises the classifications and the practical requirements for sea and air export. It is an orientation for buyers, not a substitute for the regulations: the shipper and freight forwarder must confirm classification, packing and documentation against the current rules and the carrier's own requirements for every booking.

The regulations

  • UN Recommendations on the Transport of Dangerous Goods (Model Regulations) form the common basis for the modal rules.
  • IMDG Code (International Maritime Dangerous Goods Code) governs sea transport. Amendment 42-24, adopted by the IMO as resolution MSC.556(108), became mandatory on 1 January 2026.
  • IATA Dangerous Goods Regulations (DGR) are applied by airlines to air cargo and incorporate the ICAO Technical Instructions. The 67th edition applies in 2026.
  • ADR and RID govern road and rail transport in Europe and other contracting states, and national rules such as the US 49 CFR apply domestically.

Classification at a glance

UN number Proper shipping name Class Typical batteries
UN 2794 Batteries, wet, filled with acid, electric storage 8 (corrosive) Filled flooded lead-acid starter, truck, deep cycle and traction batteries
UN 2800 Batteries, wet, non-spillable, electric storage 8 Valve-regulated lead-acid (AGM, gel) batteries of a non-spillable type
UN 2795 Batteries, wet, filled with alkali, electric storage 8 Wet batteries with alkaline electrolyte, including sodium-ion batteries with aqueous alkali electrolyte
UN 2796 Sulphuric acid with not more than 51% acid, or battery fluid, acid 8, packing group II Electrolyte shipped separately for dry-charged batteries
UN 3480 / UN 3481 Lithium ion batteries / contained in or packed with equipment 9 Lithium-ion batteries, including lithium 12 V and traction batteries
UN 3551 / UN 3552 Sodium ion batteries with organic electrolyte / contained in or packed with equipment 9 Sodium-ion batteries

In the IMDG Code, UN 2794 and UN 2800 have no packing group. All of these entries require battery terminals to be protected against short circuit.

Filled lead-acid batteries (UN 2794)

For sea transport, IMDG packing instruction P801 allows rigid outer packagings, wooden slatted crates or pallets, with conditions including:

  • stacked batteries in tiers separated by a layer of electrically non-conductive material;
  • battery terminals not supporting the weight of other items;
  • batteries packaged or secured to prevent inadvertent movement;
  • measures to prevent electrolyte leakage; and
  • protection against short circuits.

Special provision 295 allows batteries on a pallet to be marked and labelled at pallet level instead of individually. The IMDG entry assigns stowage category A and requires UN 2794 to be kept separated from alkalis. For air, UN 2794 falls under IATA packing instruction 870.

Non-spillable batteries (UN 2800) and special provision 238

Valve-regulated batteries can be shipped under UN 2800 if they are of a non-spillable type. IMDG special provision 238 sets two conditions:

  1. Non-spillable test. The battery must withstand, without leakage, a vibration test (simple harmonic motion of 0.8 mm amplitude, 10 Hz to 55 Hz, in three perpendicular positions) followed by a pressure differential test of at least 88 kPa for six hours at 24 °C ± 4 °C in each of three positions.
  2. Exemption. Non-spillable batteries are not subject to the IMDG Code if, at 55 °C, the electrolyte will not flow from a ruptured or cracked case, there is no free liquid to flow, and the terminals are protected from short circuit when packaged for transport.

The equivalent air provision is IATA special provision A67, under packing instruction 872. Industry documentation for batteries shipped under A67 notes that the words "Not Restricted" and the special provision number A67 must appear on the air waybill when one is issued. In the United States, 49 CFR 173.159a additionally requires the battery and outer packaging to be marked "NON-SPILLABLE" or "NON-SPILLABLE BATTERY".

Whether a specific AGM or gel battery qualifies is a manufacturer's determination based on testing. Some manufacturers publish certification statements; Power-Sonic, for example, states that its sealed lead-acid batteries comply with IMDG special provision 238 and IATA special provision A67. Ask for this statement for each battery type. Do not assume that "maintenance-free" or "sealed" on a flooded battery label means non-spillable.

Dry-charged batteries and battery acid

A lead-acid battery supplied dry-charged contains no electrolyte. EnerSys states that flooded lead-acid batteries supplied in dry-charged condition are classified as non-dangerous goods. The acid is a different matter: battery fluid shipped separately is UN 2796, class 8, packing group II, with its own packing and limits. Confirm the classification of both with the forwarder before booking.

Lithium-ion batteries (UN 3480 and UN 3481)

Lithium-ion batteries are class 9 and carry the lithium battery hazard label (model 9A). Before they can be shipped under these entries:

  • UN 38.3 testing. Each cell and battery type must be proved to meet the tests in the UN Manual of Tests and Criteria, Part III, subsection 38.3.
  • Test summary. Manufacturers and subsequent distributors of cells and batteries manufactured after 30 June 2003 must make the UN 38.3 test summary available, so that shippers can confirm compliance. IATA notes this can be done by publishing it online.
  • Construction and quality requirements. Cells and batteries need protection against external short circuits and must be manufactured under a quality management programme.

Air transport is considerably more restrictive than sea. According to IATA's 2026 guidance:

  • lithium-ion batteries shipped on their own (UN 3480, packing instruction 965) are forbidden on passenger aircraft and must be offered at a state of charge not exceeding 30% of rated capacity;
  • from 1 January 2026, lithium-ion batteries packed with equipment (packing instruction 966) must also be at no more than 30% state of charge under Section I, and under Section II for batteries above 2.7 Wh; a reduced state of charge is recommended, not mandatory, for batteries contained in equipment.

At sea, the IMDG Code assigns lithium-ion batteries stowage category A. Damaged or defective batteries and batteries shipped for disposal are subject to separate special provisions and packing instructions. IATA forbids lithium-ion and sodium-ion batteries that are damaged or identified as defective for safety reasons, with the potential to produce heat, fire or short circuit, from air transport. The IMDG Code also allows the older lithium battery mark that includes a telephone number to be used until 31 December 2026.

Sodium-ion batteries (UN 3551 and UN 3552)

Sodium-ion batteries now have their own entries. UN 3551 and UN 3552 were introduced into the UN Model Regulations and apply under IMDG Amendment 42-24 and ADR 2025. Requirements mirror lithium-ion: UN 38.3 testing, short-circuit protection, a quality management programme and an available test summary. Two IMDG special provisions are specific to them:

  • Special provision 400 exempts sodium-ion cells and batteries that are short-circuited so that they contain no electrical energy, with the short-circuit easily verifiable (for example a busbar between terminals), subject to further conditions including package marking and a 1.2 m drop test.
  • Special provision 401 confirms that sodium-ion batteries with organic electrolyte are UN 3551 or UN 3552, while those with aqueous alkali electrolyte are UN 2795.

By air, IATA's 2026 guidance places sodium-ion batteries shipped on their own under packing instruction 976, forbidden on passenger aircraft.

Sea and air compared

Aspect Sea (IMDG Code) Air (IATA DGR)
Filled lead-acid (UN 2794) Permitted under P801 Packing instruction 870; carrier acceptance often restricted
Non-spillable (UN 2800) Exempt if SP 238(2) met Not restricted if A67 met; air waybill annotation
Lithium-ion alone (UN 3480) Class 9, stowage category A Cargo aircraft only; 30% state of charge

Documents

Document Required for
Dangerous goods transport document with shipper's declaration (IMDG 5.4.1) or IATA shipper's declaration Regulated battery shipments
Container packing certificate (IMDG 5.4.2) Dangerous goods packed into a container for sea transport; signed by whoever packed the container
UN 38.3 test summary Lithium-ion and sodium-ion batteries
Non-spillable certification UN 2800 batteries shipped under SP 238 or A67
Safety data sheet Requested by forwarders and consignees; EnerSys notes that under the EU REACH regulation batteries are articles that do not legally require an SDS, so manufacturers issue equivalent safe-handling information

Container loading

The container packing certificate confirms, among other things, that packages requiring segregation have not been packed together, that all packages were inspected for damage, and that goods are properly loaded and secured. The IMDG Code refers to the IMO/ILO/UNECE Code of Practice for Packing of Cargo Transport Units (CTU Code) for securing. For batteries:

  • load on pallets, upright, with terminals protected and tiers separated as P801 requires;
  • keep heavy battery pallets on the container floor and brace them against movement;
  • check segregation against every other dangerous good in the same container;

Mixed loads with other auto parts are covered in mixed container auto parts and shipping and logistics.

Used and waste batteries

Waste lead-acid batteries are listed as hazardous waste (entry A1160) under the Basel Convention, so cross-border shipments of used batteries follow Basel procedures in addition to transport rules. By air, waste batteries and batteries shipped for recycling or disposal fall under IATA special provision A183 and require approval from the authorities concerned.

Before booking

  1. Identify the technology and UN number for every battery type on the order.
  2. Obtain the SDS, and the non-spillable certificate or UN 38.3 test summary where relevant.
  3. Confirm the carrier accepts the goods on the route, and any surcharges or restrictions.
  4. Agree who packs, marks, labels and signs the declarations under the chosen Incoterms.

For Thailand-specific sourcing and documents, see the Thailand battery export guide. To quote batteries with shipping, use the battery requirement form.

References

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