- Lithium batteries are the #1 product category requiring 危包证 from China, accounting for the highest volume of DG Packaging Certificate applications.
- UN38.3 test report is a prerequisite: it must be completed before the DG certificate application can begin. No UN38.3, no 危包证.
- SP188 exemption: small lithium cells (20 Wh or less) and batteries (100 Wh or less) may not need full DG packaging certificate if packed per the exemption rules.
- Air transport certificate validity: 3 months only. Sea transport: 12 months. Plan your certification timeline accordingly.
1. Why lithium batteries are different for 危包证
Lithium batteries occupy a unique position in the DG Packaging Certificate system. According to IATA Dangerous Goods Regulations, lithium batteries are the single most regulated DG category in international transport, with requirements that have been updated in every edition since 2015. Unlike most other DG products where the packaging is a straightforward container for the goods, lithium batteries require packaging that must simultaneously:
- Prevent short circuits between batteries, between batteries and conductive packaging materials, and between battery terminals and anything else in the package.
- Contain potential thermal runaway. While packaging cannot prevent a thermal event, it must be designed so that a single cell failure does not propagate to adjacent cells through physical contact or heat transfer.
- Meet UN performance testing at the PG II level (1.2m drop test), even though lithium batteries are Class 9 with no packing group assignment.
- Accommodate the battery's state of charge (SOC) requirements, which vary by carrier and port. Overcharged batteries pose higher risk during transport.
Because of these requirements, the 危包证 process for lithium batteries includes an additional step not required for other DG classes: the UN38.3 test report. This document is the gateway to everything that follows.
2. UN38.3 test report: the mandatory prerequisite
UN38.3 refers to Section 38.3 of the UN Manual of Tests and Criteria. According to the International Maritime Organization (IMO), UN38.3 compliance is mandatory for all lithium battery shipments under the IMDG Code and is verified at major Chinese ports as part of the DG declaration process. It specifies eight tests that all lithium cells and batteries must pass before they can be transported. The UN38.3 test report is a non-negotiable prerequisite for the 危包证 application.
The eight UN38.3 tests
| Test | Purpose | Samples required |
|---|---|---|
| T1: Altitude simulation | Simulates low pressure at 15,000m altitude (air transport). Pressure of 11.6 kPa for 6+ hours. | Fully charged cells and batteries |
| T2: Thermal test | Rapid temperature cycling between -40C and +75C, 10 cycles, 6+ hours at each extreme. | Fully charged cells and batteries |
| T3: Vibration | Sinusoidal vibration 7-200 Hz, 3 hours per axis. | Fully charged cells and batteries |
| T4: Shock | Half-sine shock, 150g peak for small cells, 50g for large cells. 3 shocks per direction. | Fully charged cells and batteries |
| T5: External short circuit | Short circuit at 55C. No disassembly, rupture, or fire within 6 hours. | Fully charged cells and batteries |
| T6: Impact/crush | 9.1kg mass dropped from 61cm onto cylindrical cell; 15.8mm bar crush for prismatic/pouch cells. | Cells only |
| T7: Overcharge | Charge at twice the manufacturer's recommended maximum current for specified time. | Rechargeable batteries only |
| T8: Forced discharge | Forced discharge at manufacturer-specified maximum current. | Cells only |
Who issues UN38.3 test reports in China?
UN38.3 testing is conducted by accredited laboratories. In China, the most commonly used labs for lithium battery testing are:
- Shanghai Chemical Institute (上海化工研究院): the largest and most widely recognized DG testing lab in China. Handles the highest volume of lithium battery testing.
- China North Vehicle Research Institute (中国北方车辆研究所): specializes in large-format batteries for EVs and energy storage.
- Various CNAS-accredited labs (China National Accreditation Service for Conformity Assessment). Check that the lab's accreditation scope includes UN38.3.
UN38.3 timeline and cost
- Timeline: 10-20 working days for standard testing. Expedited: 5-7 working days. Large battery systems may take longer due to the volume of cells to test.
- Cost: RMB 8,000-15,000 for single cell/battery type with standard battery count. RMB 15,000-25,000 for multiple battery types or custom battery configurations. Higher for large-format EV or BESS batteries.
- Validity: The UN38.3 report does not have a fixed expiry date, but it becomes invalid if the cell or battery design, chemistry, or manufacturing process changes. For practical purposes, most carriers and MSA offices accept UN38.3 reports up to 2 years old, assuming no design changes. Confirm with your carrier.
3. UN number guide for lithium batteries
Using the correct UN number is the first step in the 危包证 process. Using the wrong UN number will cause your entire application to be rejected and may require a new DG Classification Report.
| UN Number | Proper Shipping Name | What it covers | Class | Typical China export |
|---|---|---|---|---|
| UN3480 | Lithium ion batteries | Standalone Li-ion cells and batteries, not packed with or contained in equipment | Class 9 | Individual battery packs, spare laptop batteries, power tool batteries shipped separately |
| UN3481 | Lithium ion batteries packed with or contained in equipment | Equipment with Li-ion batteries installed, or packed together | Class 9 | Laptops with battery inside, power tools with battery, medical devices |
| UN3536 | Lithium batteries installed in cargo transport unit | Large BESS installed in containers | Class 9 | Containerized energy storage systems. See UN3536 guide |
| UN3090 | Lithium metal batteries | Standalone Li-metal (primary, non-rechargeable) cells and batteries | Class 9 | Primary lithium coin cells, lithium metal battery packs for industrial equipment |
| UN3091 | Lithium metal batteries packed with or contained in equipment | Equipment with Li-metal batteries installed | Class 9 | Electronic devices with primary lithium batteries, sensors, meters |
UN3480 vs UN3481 distinction: This is a frequent point of confusion. If the battery is inside the equipment (installed in a laptop, built into a medical device), use UN3481. If the battery is separate (a spare battery, a standalone battery pack not connected to equipment), use UN3480. Getting this wrong at the DG Classification Report stage will cause the 危包证 application to be rejected because the packaging requirements differ between the two.
4. Packaging requirements by UN number
| UN Number | Typical packaging | UN packaging code | Key requirements | SOC limit |
|---|---|---|---|---|
| UN3480 | Fiberboard box with individual battery inner packaging | 4G | Each battery must be in separate inner packaging or separated by non-conductive dividers. Terminals must be protected against short circuit (insulating caps, tape). Strong outer packaging capable of passing 1.2m drop test. | 30% or below (most carriers) |
| UN3481 | Equipment casing + outer packaging | 4G or equipment case | Battery must be securely installed within equipment and protected against accidental activation. Outer packaging prevents movement during transport. For batteries packed WITH equipment (not installed), follow UN3480-style inner packaging rules. | No SOC limit for installed batteries (equipment protection) |
| UN3536 | Cargo Transport Unit (container) | CTU (container certification) | Container must have valid CSC Safety Approval Plate. Battery strings must be disconnected at BMS level. Container structural testing per 2025 Container Inspection Rules. See full UN3536 requirements. | 30-50% depending on carrier |
UN packaging marking for lithium batteries
Every package must bear a UN packaging mark. For a typical UN3480 shipment in fiberboard boxes, the mark looks like this:
4G/Y/15/S/26/CN/C39001
Where: 4G = fiberboard box, Y = tested for PG I/II/III (meets highest standard), 15 = maximum gross mass 15kg, S = for solids or inner packagings, 26 = year of manufacture (2026), CN/C39001 = manufacturer identification code assigned by Chinese authorities.
5. Air vs sea transport: different certificate validity periods
This is one of the most important practical distinctions for lithium battery exporters, and it catches many companies off guard.
| Factor | Air freight (IATA DGR) | Sea freight (IMDG Code) |
|---|---|---|
| Performance Certificate validity | 3 months | 12 months |
| Use Appraisal Certificate validity | Single shipment | Single shipment |
| SOC limit | 30% or below | 30-50% (varies by carrier) |
| Packaging test standard | PG II (1.2m drop test) | PG II (1.2m drop test) |
| Label size | 120mm x 110mm (IATA size) | 100mm x 100mm (IMDG size) |
| UN marking size | 12mm min character | 12mm min character |
This 3-month vs 12-month disparity means that exporters who use both air and sea freight for lithium batteries need a strategy. Options include:
- Separate certifications: maintain an air-specific Performance Certificate renewed every 3 months, and a sea-specific one renewed every 12 months.
- Sea-only strategy: use sea freight exclusively for lithium battery exports to avoid the 3-month renewal cycle.
- Just-in-time certification: initiate the Performance Certificate renewal 1 month before each planned air shipment.
6. SP188 exemption explained: when you may not need full 危包证
SP188 is Special Provision 188 in the IMDG Code. It provides relaxed requirements for small lithium cells and batteries that meet specific thresholds. This is not an exemption from all requirements, but it reduces the packaging and documentation burden significantly.
SP188 thresholds
- For lithium-ion cells: watt-hour rating of 20 Wh or less.
- For lithium-ion batteries: watt-hour rating of 100 Wh or less.
- For lithium metal cells: lithium content of 1g or less.
- For lithium metal batteries: lithium content of 2g or less.
What SP188 gets you (vs full 危包证)
| Requirement | Full 危包证 (standard DG) | SP188 (small batteries) |
|---|---|---|
| UN38.3 test report | Required | Required (cells and batteries must still pass UN38.3) |
| Performance Certificate | Required | Not required (but packaging must pass 1.2m drop test) |
| Use Appraisal Certificate | Required | Not required |
| Maritime DG Declaration | Required | Not required (ship as non-DG) |
| Class 9 label | Required (100mm x 100mm) | Not required (use lithium battery handling mark instead) |
| Packaging | UN-spec packaging (e.g., 4G) | Strong outer packaging capable of passing 1.2m drop test, but does not need UN marking |
| Package limit | No SP188 limit (carrier limits apply) | Max 10kg gross per package (sea/road/rail) |
Important caveat: SP188 shipment packages must still pass a 1.2m drop test. While the packaging does not need to be UN-certified with formal marking, it must be strong enough to survive the drop test without damage to the batteries or exposure of contents. Many exporters choose to use UN-spec packaging (4G boxes) even under SP188, because it eliminates the burden of proving the packaging passed the drop test if questioned by authorities.
7. 2025 updates: new UN numbers for EVs
In 2025, the UN Model Regulations introduced three new UN numbers for lithium and sodium-ion batteries installed in vehicles. According to the International Maritime Organization (IMO), these new UN numbers are expected to be incorporated into the IMDG Code by 2027, providing a standardized framework for the growing EV export sector. These reflect the rapidly growing volume of electric vehicle shipments from China, the world's largest EV exporter.
| UN Number | Description | Applies to | 危包证 implications |
|---|---|---|---|
| UN3556 | Lithium-ion batteries installed in a vehicle, not for propulsion | Vehicles with auxiliary Li-ion batteries (e.g., RV house batteries, auxiliary power units) | New packaging assessment required. The vehicle structure serves as the primary packaging. |
| UN3557 | Lithium metal batteries installed in a vehicle | Vehicles with primary lithium metal batteries | Special provisions apply. Typically smaller battery quantities. |
| UN3558 | Sodium-ion batteries installed in a vehicle | Vehicles using sodium-ion technology | Sodium-ion batteries have inherently lower fire risk than lithium-ion. Classified as Class 9 but with different safety assessment criteria. |
For current Chinese EV exports, the majority of vehicles still ship under the existing provisions for UN3171 (battery-powered vehicle) when the battery is installed for propulsion. The new UN3556-3558 codes address specific niche cases. However, as sodium-ion battery technology matures and enters mass production in China, UN3558 is expected to become increasingly relevant. Exporters should have their battery system classified by a certified laboratory to determine the correct UN number before beginning the 危包证 process.
8. Common mistakes in lithium battery DG declaration
| # | Mistake | Why it is wrong | How to fix |
|---|---|---|---|
| 1 | Using UN3480 for batteries inside equipment | Batteries installed in equipment are UN3481. UN3480 applies to standalone batteries. | Check whether the battery is physically installed in or packed together with the equipment. If yes, it is UN3481. |
| 2 | Applying for Use Appraisal Certificate before UN38.3 is ready | The 危包证 application requires a valid UN38.3 test report as a supporting document. | Complete UN38.3 testing first. Obtain the test report. Only then start the 危包证 process. |
| 3 | SOC above carrier limit at time of loading | Carriers enforce SOC limits. Batteries at 100% SOC will be rejected even if all documents are in order. | Discharge batteries to the required SOC before packing. Verify SOC with a certificate or test report. |
| 4 | Mixed shipment: UN3480 and non-DG cargo in same container | Some carriers prohibit mixing UN3480 with general cargo. Others allow it but with segregation requirements. | Check carrier policy before loading. If mixing is prohibited, book a dedicated DG container. |
| 5 | Ignoring terminal-specific requirements | Different terminals within the same port may have different DG acceptance rules. | Confirm terminal-specific requirements during the booking process. Your freight forwarder should handle this. |
9. How Great Hensen manages lithium battery DG certification
Our DG logistics team processes lithium battery shipments daily through Qingdao Port. Here is how we handle the certification chain:
- UN number verification: we review your product specifications to confirm the correct UN number and packing group. If you do not yet have a DG Classification Report, we arrange one through an accredited laboratory like the Shanghai Chemical Institute.
- UN38.3 coordination: if your batteries have not been UN38.3 tested, we coordinate with the testing laboratory. We manage the sample submission, track test progress, and ensure you receive the report.
- Packaging specification: based on your UN number and product dimensions, we specify the correct UN packaging type. We source certified packaging from approved manufacturers who have active Performance Certificates.
- 危包证 application: we handle the full Single Window application for the Use Appraisal Certificate, including document preparation, submission, and Customs inspection scheduling. Our team in Qingdao has direct working relationships with Shandong Customs DG inspectors.
- Maritime DG Declaration: once the 危包证 is issued, we submit the Maritime DG Declaration to the MSA. We pre-clear DG bookings with carriers (MSK, HPL, MSC, COSCO, and others) to ensure confirmed space.
- Loading and shipment: we supervise container loading at Qingdao CFS, verify SOC levels, check UN markings one final time, and ensure the container is properly placarded before it moves to the terminal.
For exporters shipping lithium batteries from Shandong and surrounding provinces, Qingdao Port offers the fastest DG approval turnaround in China. According to the China Port and Harbor Association, Qingdao's DG terminal processes over 10,000 DG declarations annually, with an average approval time of 24-48 hours. (24-48 hours for DG declaration approval) and a DG handling facilities with lithium battery handling capability. See timeline and cost details.
10. Frequently asked questions
Can I ship a prototype lithium battery without UN38.3?
There is a provision for prototype lithium batteries that have not completed UN38.3 testing. Under Special Provision 310 of the IMDG Code, prototype batteries (maximum 100 cells/batteries per shipment) can be shipped as Class 9 if they are packed in a way that prevents short circuits and are transported under an approved arrangement with the competent authority. However, this requires advance coordination and carries higher risk. Most carriers are reluctant to accept prototype batteries. We recommend completing UN38.3 before shipment.
Do used or waste lithium batteries need a 危包证?
Yes. Used or waste lithium batteries for disposal or recycling are typically classified under UN3480 (if standalone) or UN3481 (if contained in equipment) and require the same DG Packaging Certificate as new batteries. However, used batteries with unknown condition may face additional scrutiny: some carriers refuse them outright, and some ports require a condition assessment report (e.g., proof of no swelling, no leakage) before acceptance. Check carrier policy before booking.
Is the 危包证 process the same for all lithium battery chemistries (LFP, NMC, LCO)?
From the DG Packaging Certificate perspective, the process is the same regardless of cathode chemistry. LFP (lithium iron phosphate), NMC (nickel manganese cobalt), and LCO (lithium cobalt oxide) all fall under the same UN numbers (UN3480 or UN3481 for Li-ion). The UN38.3 test requirements are the same. However, the DG Classification Report may note different hazard profiles, and some carriers have chemistry-specific policies (typically, LFP is viewed as lower risk than NMC due to higher thermal stability).
Shipping lithium batteries from China?
We manage the full certification chain: UN38.3 testing coordination, 危包证 application, Maritime DG Declaration, and carrier DG booking. Single point of contact from lab to vessel.
Get Lithium Battery Shipping Support → Pillar Guide →DG Packaging Certificate: Complete Guide Series
Explore all guides in this cluster:
Complete overview, two certificates, costs, 2025 rules.
Step-by-step, Single Window, rejection reasons.
Packaging types, UN marks for each class 2-9.
Also see: UN3536 Energy Storage Guide → | DG Freight Services →
Sources and references
- 《中华人民共和国进出口商品检验法》第17条: Legal basis for mandatory DG packaging inspection. 全国人民代表大会.
- SN/T 0370-2021: 出口危险货物包装检验规程 (China DG packaging inspection standards). Issued by GACC (海关总署).
- China International Trade Single Window (中国国际贸易单一窗口): Online application portal for DG packaging certificates. singlewindow.cn
- Differentiated Conformity Assessment (差异化合格评定): GACC announcement 2025年第8期, UN3077/UN3082 Class 9 streamlined procedure. 中国海关 2025年08期
- 危包证有效期: 空运3个月, 海运/陆运/铁路12个月: per CIQ inspection standards. ChemRadar Regulatory
- UN38.3 Test Report requirement: UN Manual of Tests and Criteria, Part III, Section 38.3. Mandatory for lithium battery DG shipments from Chinese ports.
- Ningbo Port mandatory UN38.3 effective October 2025: ONE Advisory Oct 2025
All procedural descriptions verified against GACC published guidelines and Great Hensen operational experience. Last verified: July 2026.