Understanding the Transport Requirements for Used Lithium Batteries

Non damaged cells or batteries for disposal or recycling

*Based on the ADGC edition 7.8 (this will be discontinued in October 2025, when edition 7.9 becomes mandatory)

The use of Lithium batteries to power our way of life is expanding exponentially and with it the need to safely recycle them when they have reached their end of life. Due to the large amount of energy stored in even small batteries they can cause fires and / or explode. Consequently, they are classified as a Dangerous Good in the Australian code for the Transportation of Dangerous Goods (ADGC).

The road and rail transport requirements laid out in the ADGC for Lithium Batteries are complex and not easily understood. I have written this article in an attempted to help explain them in layman terms. The ADGC code is updated from the UN model dangerous good regulations, so both are usually identical.

This article doesn’t cover the requirements for air and sea transport of Lithium batteries. For this you will need to refer to the Civil Aviation Safety Authority and Australian Maritime Safety Authority regulations.

Battery Rescue currently offers a Used Lithium Battery recycling service to its Western Australian customers only. You can find full details of our Lithium Battery Recycling Service here.

See Uniseg Product’s website if you are looking for a suitable box for storing and transporting used lithium batteries.

If you are wanting to find out about the ADGC regulations for transporting used lead acid batteries, then read here.

I should at this point mention a disclaimer, that what follows is my best endeavours to interpret the ADGC requirements after extensive reading and re-reading of the code. That said there is always some ambiguity or possibility of misinterpretation of the regulations. Given the dangerous nature of Lithium batteries and the potential for catastrophic outcomes, it would be advisable to seek alternative opinions.

Identifying Lithium Batteries

Lithium batteries are used to power many modern electronic devices, from mobile phone. Laptops, cameras, power tools, toys and many other industrial devices. They come in all shapes and sizes and often form part of the equipment they are installed in where the battery should only be removed by a professional (think some jump starter packs, UPS backup systems).

The photo below depicts 3 batteries with different chemistries. The only way to distinguish which of these batteries is a Lithium battery is by inspecting the description on the battery.

Larger Lithium batteries (1 kg or more) can also be distinguished from the more common lead acid batteries by their weight. Lithium batteries are much lighter than the equivalent sized lead acid batteries.

Some examples of different Lithium batteries are show below, however the best method to identify them from other battery chemistries, is to look for the word “Lithium” or the chemical symbol “Li”.

Packaging Used Lithium Batteries for Transport – the ADGC Requirements

What follows is an explanation of the packing instructions for transporting non-damaged Lithium batteries for the purpose of disposal or recycling. To not overwhelm the reader, I have excluded the requirements for:

• transporting damaged or defective Lithium batteries.
• transporting Lithium batteries by sea or air.

I will cover these requirements in future articles.

Below is the ADGC Packing Instruction P909 that applies to transporting non-damaged Lithium batteries for the purpose of disposal or recycling.

I suspect most people when they first read the instructions will be confused, so let’s see if I can help de-mystify the requirements for you. Let’s start with some useful definitions;

Definitions

The first thing we need to determine is what receptacle can the Lithium batteries be transported in – referred to as “Packagings” in the ADGC. This will depend upon the type of Lithium batteries you have and the quantity. The decision chart below should help you determine whether you need to use an authorised package or not.

Note: The decision chart does not apply to cells or batteries contained in equipment. See Used Lithium Batteries Contained in Equipment.

The Threshold Test & Authorised Packaging

Lithium Ion Cells / Batteries (rechargeable)

For Lithium Ion cells if the Watt-hour rating doesn’t exceed 20Wh and for Lithium Ion Batteries doesn’t exceed 100Wh, then the cells / batteries can be transported in a strong but non-authorised package. This includes all small hand-held batteries and most power tools. If you’re unsure check the battery labels or safety data sheet.

If the cell / battery exceeds these thresholds, generally larger batteries, then an authorised packaging must be used, as stipulated in the P909 Packaging Instruction Clause 1 (a). Again, if you’re unsure check the battery labels or safety data sheet.

Lithium Metal Cells / Batteries (non-rechargeable)

For Lithium metal cells if the lithium content doesn’t exceed 1g and for Lithium Metal Batteries doesn’t exceed 2g, then the cells / batteries can be transported in a strong but non-authorised package. This includes all small hand-held batteries. If you’re unsure check the battery labels or safety data sheet.

If the cell / battery exceeds these thresholds, then an authorised packaging must be used, as stipulated in the P909 Packaging Instruction Clause 1 (a) – see P909 above. Again, if you’re unsure check the battery labels or safety data sheet.

Note: Lithium Batteries can be packed with other battery chemistries, however there presence dictates that all the batteries must be transported as per the requirements for Lithium batteries. Due to the difficulty of easily identifying the presence of lithium batteries in a mixture of portable, handheld batteries, my rule of thumb is “if in doubt assume the presence of some Lithium batteries”.

The “P909 Additional Requirements”

Now that you have determined what packagings are allowed for transporting your Lithium Cells / Batteries, you will now need to ensure they are packaged correctly.

The P909 Packing Instructions, include some “Additional Requirements”, which outline these requirements. The “Additional Requirements” are,

1.  Cells and batteries must be designed or packed to prevent short circuits and the dangerous evolution of heat.

2.  Protection against short circuits and the dangerous evolution of heat includes, but is not limited to,

• individual protection of the battery terminals,
• inner packaging to prevent contact between cells and batteries,
• batteries with recessed terminals designed to protect against short circuits, or
• the use of an electrically non-conductive and non-combustible cushioning material to fill empty space between the cells or batteries in the packaging.

3.  Cells and batteries must be secured within the outer packaging to prevent excessive movement during transport (e.g. by using a non-combustible and electrically non-conductive cushioning material or through the use of a tightly closed plastics bag).

So, let’s look at what this might mean for different types of Lithium Cells & Batteries

Handheld Lithium Batteries

This includes batteries, such as AA, AAA, AAAA, D, C, 9V batteries, button, mobile, laptop batteries etc

The most common method deployed to individually protect battery terminals is to tape each terminal. I think the requirement to individually tape the terminals of every AA, AAA, C, D & button battery is unrealistic and doesn’t match industry current practices. Similarly, to expect every battery to be placed in an “inner packaging” is also unlikely and again does not match industry current practices.

Furthermore the chances of a short circuit being formed from touching terminals is incredible unlikely in a box or container of small batteries and even in this unlikely event these batteries have insufficient power to generate a fire.

I would be concerned that these requirements would result in very low recycling rates for these batteries while not adding any material safety benefit.

Common solutions available in Australia involve the placement of these batteries in a fire-retardant bag that is then placed inside a sturdy cardboard box. The batteries are often mixed with non-lithium batteries which is allowed under the P909 requirements.

Non-Handheld Lithium Batteries

My definition for this is the larger Lithium batteries typically weighing more than 1kg.

For these larger batteries it is more practical to protect the battery terminals and provide inner packaging to prevent the batteries from contacting each other. This could be achieved using individual, non-conductive, non-combustible bags or foam.

Used Lithium Batteries Contained in Equipment

Clause 3 of the P909 Packing instructions details the requirements when transporting used lithium cells / batteries contained in equipment, for the purpose of disposal or recycling. The exemption from meeting the requirements in 4.1.1.3 means that any packaging used does not need to be UN Certified.

Cells or batteries contained in equipment can be shipped in a strong outer packaging provided the packaging provides adequate protection and strength for the intended use. Batteries contained in equipment can also be transported unpackaged or on pallets if the equipment provides adequate protection.

The following UN Numbers and Proper Shipping Names apply for Lithium cells / batteries contained within equipment,

• UN3481 – Lithium Ion Batteries Contained in Equipment or Packed with Equipment
• UN3091 – Lithium Metal Batteries Contained in Equipment or Packed with Equipment

Other ADGC Requirements for Transporting Lithium Batteries

In addition to the Packing Instruction for Lithium Batteries being shipped for recycling or disposal, the ADGC includes the following requirements:

• Markings & labelling
• Load Restraint & Segregation
• Placarding
• DG Documentation
• Emergency Information

These are outlined below:

Markings & Labeling

• 2 DG Diamonds Class 9a, minimum size of 100 x 100mm with minimum lettering size of 7mm, applied to opposite side of the package.
• All packages must be labeled with the appropriate UN Number and proper shipping name – 12 mm minimum lettering ,(may include combinations)
  • UN3480 – Lithium Ion Batteries (including lithium polymer batteries)
  • UN3481 – Lithium Ion Batteries Contained in Equipment or Packed with Equipment
  • UN3090 – Lithium Metal Batteries (including lithium polymer batteries)
  • UN3481 – Lithium Metal Batteries Contained in Equipment or Packed with Equipment
• All packages must display the Name, address and contact number of the consignor – minimum 12mm lettering.
• Special Provision 377 requires that cells or batteries being transported for the purpose of disposal or recycling must be marked “LITHIUM BATTERIES FOR DISPOSAL” or “LITHIUM BATTERIES FOR RECYCLING”

Note: It is an offence under the ADGC to transport an empty packaging while displaying DG labels.

Load Restraint & Segregation

• Packages must be stowed & restrained in the vehicle in accordance with the National Transport Commission’s Load Restraint Guide 2018.
• In addition Chapter 9.2 of the ADGC requires that batteries being transported with incompatible dangerous goods or other goods, must be segregated. Note that when batteries are transported with other goods all goods must be restrained to prevent damage to the batteries and release of their electrolyte.

Placarding

Placarding is the display on an Emergency Information Label (EIP), that may be required on the Packaging and teh Vehicle being used to transport the waste Lithium batteries. The requirements outlined in Chapter 5.3 of the ADGC are quite complex however below is an outline as to how they apply for lithium batteries.

A Placard is required on the Outer Package if the Package has a capacity greater than 500kg.

Placarding of the vehicle is also required if the vehicle is transporting an aggregate quantity of dangerous goods greater than 1000 kg/L.

An example Emergency Information Panel for Lithium Ion batteries is shown below.

Dangerous Good Transport Documentation

• The Consignor who provides the used Lithium cells / batteries for transport shall provide the transport contractor information applicable to those dangerous goods.
• The documentation must be carried in the vehicle in hard copy form
• The documentation must include the name and address of the consignor, consignee, including the consignor’s contact telephone number
• The documentation should include the following information
  • UN Number – UN3480, 3481, 3090, 3091 or combination of.
  • Proper Shipping Name – either or combination of Lithium Ion Batteries (including lithium polymer batteries), Lithium Ion Batteries Contained in Equipment or Packed with Equipment, Lithium Metal Batteries (including lithium polymer batteries), Lithium Metal Batteries Contained in Equipment or Packed with Equipment
  • DG Class – 9
  • Description of Packages – i.e. Drum, Box etc
  • The number of each type of package
  • The aggregate quantity of batteries (kg)

Emergency Information

The vehicle used to transport the dangerous goods, must carry the DG documentation, described above, and emergency information, as follows ,

• Emergency documentation should include an Initial Emergency Response Guide, an Emergency Procedure Guide for the dangerous good, an Emergency Procedure Guide in relation to a vehicle fire.
• Documentation can be kept in a prominent location in the the cabin.
• See Chapter 11.2 – Emergency Information in ADGC for further details.

Conclusion

The ADGC’s regulations for transporting Used Lithium Batteries are complex and understanding the requirements can be difficult. I hope this article has helped you decipher the complexities of transporting used Lithium Batteries for disposal or recycling. If you have any questions, please feel free to email me at davidbush@batteryrescue.com.au

Future articles on the requirements for transporting used lithium batteries contained in equipment and for transporting damaged or defective Lithium batteries will follow shortly.