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Background and Drivers of Policy Tightening

In recent years, lithium batteries and their application products have experienced rapid growth in global trade share, but the frequent occurrence of related safety accidents has also attracted high attention from regulatory authorities in various countries. In 2026, multiple major export destination countries have successively tightened lithium battery transportation regulatory requirements, and dangerous goods (DG) declaration compliance has become a rigid threshold that enterprises engaged in lithium battery product export businesses must directly face.

At the international level, the International Civil Aviation Organization (ICAO) and International Maritime Organization (IMO) have continuously revised lithium battery transportation classification, packaging, and documentation requirements, particularly regarding the transportation conditions for large lithium batteries (such as those used in energy storage systems). From China's domestic regulation perspective, the General Administration of Customs has significantly increased the inspection rates for lithium battery exports, and the penalties for dangerous goods concealment and misdeclaration have substantially increased.

As dangerous goods, lithium battery transportation compliance not only concerns shippers' own business safety but also directly affects public transportation safety and the smoothness of international logistics channels. Understanding and complying with the latest dangerous goods declaration requirements has become a required course for Chinese lithium battery export enterprises.

Classification System and Regulatory Framework for Lithium Battery Transportation

1. Classification System for Lithium Batteries

According to the United Nations "Recommendations on the Transport of Dangerous Goods Model Regulations" (UN RTDG) and the International Air Transport Association "Dangerous Goods Regulations" (IATA DGR), lithium batteries are divided into two major categories: Lithium Metal batteries and Lithium Ion batteries. The two differ significantly in chemical properties and transportation requirements.

Lithium-ion batteries are widely used in consumer electronics, new energy vehicles, and energy storage systems, with their transportation volume far exceeding that of lithium metal batteries. Different power capacities and sizes of lithium batteries correspond to different packaging levels and declaration requirements. Enterprises must accurately identify product attributes and prepare compliant documentation accordingly.

2. Regulatory Differences Between Sea and Air Transportation

For sea transportation, lithium battery transportation is primarily governed by the International Maritime Dangerous Goods Code (IMDG Code). Amendment 42, which took effect in 2024, further refined lithium battery packaging requirements and船舶载运限制. Notably, under船舶运输 conditions, most products containing lithium batteries are required to be declared as dangerous goods.

Air transportation restrictions on lithium batteries are even more stringent. According to IATA DGR regulations, the transportation of lithium battery cells and battery packs must meet specific conditions, and some types of lithium batteries are prohibited from air transportation under certain State of Charge (SOC) conditions. Airlines also have varying acceptance standards for lithium batteries, with some carriers imposing additional restrictions on lithium battery transportation.

3. China Customs Dangerous Goods Declaration System

China Customs implements a classified management system for dangerous goods. Lithium batteries and their product exports must be declared through the Dangerous Goods Safety Information Declaration System. During dangerous goods declaration, enterprises must accurately provide the goods' UN number, hazard class, packaging level, and emergency response measures.

China Customs has increased the intensity of dangerous goods declaration review, with errors or concealment facing rectification, penalties, and even risks of suspended export qualifications. Compliant declaration has become the primary prerequisite for lithium battery product exports.

Key Requirements and Practical Points for Dangerous Goods Declaration

1. Core Elements of Dangerous Goods Declaration Documents

Complete dangerous goods declaration documents typically include the following elements: Dangerous Goods Declaration (DG Declaration), Transport Condition Assessment Certificate, Material Safety Data Sheet (MSDS/SDS), Packaging Performance Inspection Certificate, UN packaging markings, and dangerous goods packaging certificate numbers.

Among these, UN packaging markings are key identifiers for compliant packaging. Each piece of dangerous goods packaging must be marked with the UN number, packaging type code, and production batch information to certify compliance with UN packaging specifications. Using uncertified packaging or fraudulently using dangerous goods packaging certificate numbers will constitute a serious compliance risk.

2. Special Requirements for Lithium Battery Export Declarations

When declaring lithium battery product exports, special attention must be paid to the following: accurately declaring battery type (lithium metal/lithium ion), battery capacity (watt-hours/Wh), quantity and arrangement of cells and battery packs, UN38.3 test compliance, and whether exemptions or special provisions apply.

Taking lithium batteries for new energy vehicles as an example, such products typically have high power ratings and must be declared under relevant UN numbers (such as UN3480 or UN3481) in the IMDG Code, with battery management system (BMS) protection function descriptions noted in transport documents. For devices with installed batteries, distinction must be made between battery transport and device transport with batteries, as the declaration requirements differ between the two.

3. Packaging and Labeling Standards

Lithium battery packaging must meet the packaging instruction requirements specified in IATA DGR or IMDG Code. Taking PI965 (lithium-ion battery cells shipped alone) as an example, packaging must meet Level II or Level IA requirements, inner packaging must be short-circuit protected, outer packaging must bear exclusive markings and be accompanied by complete transport documents.

Transport marks and hazard warning labels are equally indispensable. Lithium battery exclusive marks must be affixed to each outer packaging surface, and Class 9 miscellaneous dangerous goods labels must be applied as required. For air freight cargo, a Lithium Battery Mark must also be attached.

4. Common Declaration Errors and Risk Points

In practice, the most common errors in lithium battery dangerous goods declarations include: incorrect UN number selection (misdeclaring lithium-ion batteries as lithium metal batteries), incorrect capacity calculation (failure to correctly convert watt-hours), inaccurate packaging level markings, mismatched dangerous goods packaging certificate numbers and actual packaging, and failure to note UN38.3 test status during declaration.

These errors may result in cargo being inspected and detained at ports, shipping companies refusing to load, return shipments, or even penalties. Professional international logistics service providers typically have dangerous goods declaration professional teams that can help shippers accurately complete the declaration process and reduce compliance risks.

Professional Value of Freight Forwarders in Dangerous Goods Transportation

1. DG Qualifications and Network Coverage

Dangerous goods international logistics has high qualification requirements for participating enterprises. Freight forwarding enterprises with dangerous goods transportation qualifications have indispensable advantages in booking space with shipping companies, airport security checks, and customs declarations. Quality freight forwarding services not only help enterprises complete compliant declarations but also can争取危品货物的优先出运通道 when space is tight.

2. Professional Support for Dangerous Goods Declarations

Professional freight forwarding enterprises typically equip operations teams with dangerous goods transportation qualification certifications, capable of providing customers with dangerous goods declaration document pre-review services to ensure declaration information matches actual cargo conditions. When dangerous goods declarations encounter questions or disputes, the professional experience of freight forwarders can quickly定位问题 and propose solutions.

3. Flexible Combination of Multiple Transportation Solutions

Lithium battery product transportation requires comprehensive channel selection based on product characteristics and time requirements. For high-value, urgent replenishment scenarios, air transportation channels can be chosen; for large-volume, non-urgent cargo, maritime shipping remains a more cost-advantageous choice. Professional freight forwarders can flexibly integrate maritime and air resources based on customer needs to provide suitable logistics solutions.

4. Overall Supply Chain Compliance Control

DG compliance extends beyond transportation to involve product design (such as battery safety valve settings), packaging design (such as inner packaging structures meeting transportation requirements), and destination compliance (such as various countries' import permits for lithium battery products) across the entire chain. Freight forwarding service enterprises with global perspectives can provide compliance recommendations across all supply chain stages.

Best Practices for Compliance Management

1. Establish Dangerous Goods Compliance Management System

Lithium battery export enterprises should incorporate dangerous goods compliance into the company quality management system, designate personnel responsible for dangerous goods declarations and compliance management, establish declaration document review mechanisms, regularly conduct dangerous goods compliance training, and continuously track regulatory policy changes.

2. Select Logistics Partners with DG Qualifications

When selecting international logistics service providers, focus on evaluating their dangerous goods transportation qualifications, professional team experience, depth of cooperation with shipping companies/airlines, and dangerous goods emergency response capabilities. A reliable freight forwarding service enterprise can help enterprises avoid dangerous goods transportation risks and serves as an important guarantee for supply chain security.

3. Monitor Policy Developments and Industry Standard Updates

International standards for lithium battery transportation and regulatory policies in various countries continue to evolve. Enterprises must maintain attention to policy developments and promptly adjust compliance strategies. It is recommended to maintain close communication with industry associations, dangerous goods consulting institutions, and freight forwarding partners to ensure enterprises always stand at the compliance frontier.

Trends and Outlook

Looking ahead, the regulatory trend for lithium battery product exports will continue to tighten. Various countries' requirements for full lifecycle management of lithium battery products will become more systematic, from dangerous goods production permits at the production end, to dangerous goods declaration systems at the transportation end, to recycling and processing systems at the usage end—compliance requirements will cover every link of product circulation.

For Chinese lithium battery export enterprises, compliance capability will become an important component of international competitiveness. Establishing long-term cooperation with professional freight forwarding service enterprises and building comprehensive dangerous goods compliance management systems are key to steady development in the global market.

In the field of dangerous goods declaration, the value of professional freight forwarding services lies in precise grasp of complex regulations and full-process risk control. Freight forwarding prices are certainly a consideration factor, but in the dangerous goods compliance domain, professional capability and compliance safety assurance are standards that shipper enterprises cannot compromise on.

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