Earlier this month, some of the Peter East team spent a couple of days in Chicago at the Labelmaster Dangerous Goods Symposium. It was a fantastic event – and great to meet other DG professionals from around the world.

One of the talks was delivered by Steven Webb, International Transportation Specialist at the U.S. Department of Transport. Steven also sits on the UN Sub-Committee of Experts on the Transport of Dangerous Goods. In the session, Steven floated a series of U.S. proposals and perspectives on the future of lithium battery transport regulation. The U.S. view, and one shared by several other countries is that class 9 is too broad and should be subdivided.

The US proposal is that there is a minimum of three divisions to include:

Energy Storage Devices (i.e. batteries)
Low Hazard Energetics
Environmentally Hazardous Substances

The talk mirrored a talk given a week later at the British Association of Dangerous Goods Professionals Lithium Battery Seminar, for which Peter East was a sponsor. Keith White, formerly of the VCA and current dangerous goods panel member explained that the long term goal of regulators is to reclassify lithium batteries based on the propagation of dangerous gases.

Currently there exists two core UN numbers for lithium ion batteries, and two for lithium metal batteries. Each UN number is then accompanied by several special provisions in the regulations.

It has been argued that the status quo makes things complicated and doesn’t consider the specific risks of an individual battery type. When batteries go into thermal runaway, some will give off more toxic gases and others more heat, therefore posing different dangers.

The suggestion is batteries be graded from A to D with A being the most dangerous, and D the least. Batteries may also be able to move between classification based on things that make them safer such as their state of charge. For example, an A battery with a 30% state of charge may be able to be classed as a B.

60+ New UN numbers?

Each type of battery classification would have its own unique set of UN numbers for lithium metal and lithium ion batteries, with unique corresponding packaging instructions. The same would be replicated for sodium ion batteries.

This would mean rather than the existing four generic UN numbers for lithium batteries (UN3480, UN3481, UN3090, UN3091), two for sodium ion batteries (UN3551, UN3552), and the small number of others for vehicles (UN3171, UN3556, UN3557, UN3558) there may be up to 60 different UN numbers, each with their own unique packing instruction.

Will it make any difference?

The goal with these proposals is to make transport safer, and it is reasonable to state that at the very least it will make some regulations easier to follow. This is, however, reliant on regulators introducing minimal new special provisions following the roll out of a ‘simplified’ system.

The current range of special provisions for shipping lithium batteries have evolved over time and adjusted in response to threats and incidents. Whilst the intention is to cut the number of special provisions, new battery technology and incidents that require new regulation, may in turn require more provisions to be added in the future, creating more complexity than we have currently.

Complicated Transition

Long term, changes may seem a good idea, but the move to a new system won’t be easy. Current suggestions from the U.S regulators are that the world may need a 10 year transition period where two parallel types of regulation for battery transport are viewed as compliant.

If you’re checking dangerous goods for a carrier – this will make your job much harder than before as you’ll essentially have two competing regulations to check shipments against. This may in turn then lead to carriers accepting just one form of battery classification. With aircraft manufactures continually making clear their planes are not designed to carry lithium batteries in cargo, air carriers or IATA may embrace what they see as the most stringent measures. In contrast, road and sea carriers may follow simpler classification leading to confusion and supply chain disruption for multimodal journeys.

Timeline

These proposals have been in discussion amongst the UN Sub-Committee of Experts on the Transport of Dangerous Goods for some time, and their introduction is by no means imminent. The United Nations Recommendations on the Transport of Dangerous Goods – Model Regulations (otherwise known as the Orange Book) is already being finalised, due to be published in early 2026 and will form the basis for new regulations for 2027. That means the very earliest we see any significant changes will be January 2029.

Conclusion

Lithium batteries will continue to be critical technology for humans and by nature they can be dangerous and unstable when not handled correctly. It is therefore unlikely the regulation for their transport ever becomes simple or easy, but any attempt to improve compliance by keeping things simple should be welcomed.

There are considerable numbers of batteries continuing to move undeclared, and that should concern all involved in any element of supply chains. Awareness of their risks and training could not be more important – particularly given the complexity of understanding the regulations.

If you need help with your lithium battery shipments or want more information on our training, please take a look at our Civil Aviation Authority approved training course or get in touch.