Shipping lithium batteries from an EU warehouse

Lithium batteries are class 9 dangerous goods under ADR, the agreement that governs the carriage of dangerous goods by road in Europe. Small cells and batteries that meet special provision 188 are released from most of ADR, but not from its packing, marking and drop-test conditions. Separately, the EU Batteries Regulation (EU) 2023/1542 has applied since 18 February 2024, with further obligations phasing in to 2027.

Two sets of rules therefore meet in the same warehouse. ADR decides how a parcel or pallet containing batteries may travel. The Batteries Regulation decides what the battery itself, its label and its producer must satisfy before it is sold.

Which UN number applies to lithium batteries?

ADR sorts lithium batteries into four entries. The choice depends on the chemistry and on whether the battery travels alone or with the device it powers.

UN number	What it covers
UN 3090	Lithium metal cells or batteries, shipped on their own
UN 3091	Lithium metal cells or batteries contained in equipment, or packed with equipment
UN 3480	Lithium ion cells or batteries, shipped on their own
UN 3481	Lithium ion cells or batteries contained in equipment, or packed with equipment

A power bank sold by itself is UN 3480. A pair of wireless headphones with a built-in battery is UN 3481, contained in equipment. A camera sold with a spare battery in the same box is UN 3481, packed with equipment.

Every entry rests on one precondition. Each cell and battery type must have passed the tests in the UN Manual of Tests and Criteria, Part III, sub-section 38.3. Manufacturers and later distributors of cells or batteries made after 30 June 2003 must make the test summary available, so that the consignor and others in the supply chain can confirm compliance. A warehouse asked to ship batteries will ask for that document first.

Do small lithium batteries fall under ADR?

Mostly not, provided they meet special provision 188. Under that provision, lithium ion cells up to 20 Wh and batteries up to 100 Wh are not subject to the other provisions of ADR. For lithium metal, the limits are 1 g of lithium per cell and 2 g per battery. Lithium ion batteries under this provision must show the watt-hour rating on the outside case, except those made before 1 January 2009.

The relief comes with conditions. Loose cells and batteries go in inner packagings that enclose them completely, protected against short circuits, inside strong outer packagings. Each package carries the lithium battery mark. Unless the batteries are installed in equipment, each package must survive a 1.2 m drop test in any orientation without damage to the contents. And unless they are installed in or packed with equipment, a package may not exceed 30 kg gross weight, packaging included.

The mark has two exceptions that matter for fulfilment. It is not needed for packages containing only button cells installed in equipment. Nor is it needed for packages with no more than four cells or two batteries installed in equipment, where the consignment has no more than two packages.

Suppose, as an example, a maker of wireless headphones holds stock in Portugal. Each headset has one small built-in lithium ion battery, well under 100 Wh. A consumer order of one headset ships in one parcel: the battery is installed in equipment, the package holds one battery, and no mark is required. A retailer order of forty headsets in one carton is a different package. That carton needs the lithium battery mark.

What changes above those limits?

Above the special provision 188 limits, the battery is fully regulated. Packing instruction P903 applies: drums, boxes or jerricans that conform to the packing group II performance level, with cells and batteries protected against movement and short circuit. The package carries the class 9A hazard label, and the consignment travels with the documentation and trained staff ADR requires.

Damaged or defective batteries follow their own route. Special provision 376 covers cells or batteries that are defective for safety reasons, have leaked or vented, cannot be diagnosed before carriage, or have physical damage. They are packed under P908, or P911 where they could react dangerously, and the packages are marked “DAMAGED/DEFECTIVE LITHIUM-ION BATTERIES” or the lithium metal equivalent.

This is where returns meet dangerous goods. A returned power bank that arrives swollen cannot simply go back on the shelf or into the next outbound parcel. It needs to be assessed, segregated and shipped under the defective-battery rules.

Does the warehouse need a safety adviser and trained staff?

ADR Chapter 1.3 requires training for every person whose duties concern the carriage of dangerous goods, appropriate to their responsibilities. Sweden’s civil defence agency, MCF, lists who that includes: people who classify dangerous goods, prepare transport documents, pack, load and unload. Training covers general awareness, the specific function, and safety.

The safety adviser is a separate obligation. In Portugal, the Instituto da Mobilidade e dos Transportes states that companies whose activity includes carriage of dangerous goods by road, or packing, loading, filling or unloading linked to that carriage, must appoint a conselheiro de segurança. The adviser’s certificate is issued by IMT after an exam and is valid for five years.

ADR also sets quantity thresholds, in section 1.1.3.6, below which some consignments are relieved of parts of the rules. Whether a flow falls under them is a question for the adviser, flow by flow, rather than a general assumption.

What does the EU Batteries Regulation require, and from when?

The Batteries Regulation governs the product and its producer, wherever the battery travels. Its main dates, as published by the European Commission and Germany’s Federal Environment Ministry, are these.

Milestone	Date
Entry into force	17 August 2023
General application	18 February 2024
Chapter VIII, waste batteries (collection and treatment)	18 August 2025
Supply-chain due diligence, after a 2025 postponement	18 August 2027
Battery passport for electric vehicle batteries, light means of transport batteries and industrial batteries above 2 kWh	18 February 2027

Collection targets for portable batteries rise to 63 percent by 2027 and 73 percent by 2030. Labelling and QR code requirements phase in under Article 13 on their own timetable, which the product’s compliance file should track.

Producer registration stays national. A seller placing batteries on the German market, for example, registers with stiftung ear before the first sale, and a foreign company needs an authorised representative to do so. The German route is set out in selling into Germany from stock in Portugal.

What should a seller send the warehouse before the first shipment?

A short file, prepared once per product, avoids most delays.

• The UN number, and whether the battery ships alone, inside the device or packed with it.
• The watt-hour rating for lithium ion, or the lithium content for lithium metal, per cell and per battery.
• The UN 38.3 test summary for each cell and battery type.
• The retail packaging specification, so the warehouse can check whether it meets the inner packaging and drop-test conditions.
• The plan for returned or damaged units, including who assesses them.
• The producer registration numbers held in each target market.

The same file serves the product side. GPSR asks for product identification and safety information, and the Batteries Regulation adds its own labelling. A seller who assembles all of it before stock moves rarely has to reopen a pallet.

This is general information, not legal advice. The classification of a specific battery is confirmed with the manufacturer’s documentation and a qualified dangerous goods adviser.

How this runs at EFC

Goods with lithium batteries inside are reviewed case by case before they reach EFC’s base in Portugal, which is run with its logistics partner. The UN number, the watt-hour rating, the test summary and the packing route decide how each unit is stored and dispatched to customers across Europe, consumer electronics included. Registration in national battery or WEEE schemes stays with the producer; EFC does not register producers there and does not give legal advice. For the onward journey, see parcel, pallet or groupage from Portugal.

Sources

Label	Value	Source
UN numbers and classification	UN 3090, 3091, 3480, 3481; class 9; hazard label 9A; packing instructions P903, P908, P911	Tadiran Batteries, ADR 2025 technical notice LTN-065-70, reproducing ADR text, opened 2026-08-27
Test summary	UN Manual of Tests and Criteria 38.3; test summary for cells and batteries made after 30 June 2003 (ADR 2.2.9.1.7)	Tadiran Batteries, ADR 2025 technical notice, opened 2026-08-27
Special provision 188	20 Wh cell, 100 Wh battery; 1 g and 2 g lithium; mark; 1.2 m drop test; 30 kg; mark exceptions	Tadiran Batteries, ADR 2025 technical notice, opened 2026-08-27
Damaged or defective batteries	special provision 376; P908 and P911; package marking	Tadiran Batteries, ADR 2025 technical notice, opened 2026-08-27
ADR training	staff who classify, prepare documents, pack, load and unload; general awareness, function-specific and safety training	MCF (Sweden), training required under ADR and RID, opened 2026-08-27
Safety adviser in Portugal	companies that carry, pack, load, fill or unload dangerous goods must appoint one	IMT, which companies must appoint a safety adviser, opened 2026-08-27
Safety adviser certificate	issued by IMT after exam; valid five years	gov.pt, certification of safety adviser, opened 2026-08-27
Batteries Regulation, entry and application	in force 17 August 2023; applies from 18 February 2024	European Commission, Batteries, opened 2026-08-27
Batteries Regulation, later dates	waste batteries 18 August 2025; passport 18 February 2027; due diligence 18 August 2027; collection 63 percent by 2027, 73 percent by 2030	German Federal Environment Ministry, European Batteries Regulation, opened 2026-08-27
Due diligence postponement	published 30 July 2025; moved from 18 August 2025 to 18 August 2027	Linklaters, EU regulation delaying due diligence rules for batteries, opened 2026-08-27
German battery registration	registration with stiftung ear before placing on the market; foreign companies need an authorised representative	stiftung ear, obligations of battery producers, opened 2026-08-27