Why three proper shipping names — and why it matters
Lithium ion batteries appear in the IMDG Code Dangerous Goods List under two UN numbers and three distinct proper shipping names. Each entry is a separate regulatory category with its own packaging obligations, marking requirements, and documentation rules. Using the wrong name is not a minor labelling issue — it is a mis-declaration.
The three entries are:
- UN 3480 — LITHIUM ION BATTERIES (including lithium ion polymer batteries)
- UN 3481 — LITHIUM ION BATTERIES CONTAINED IN EQUIPMENT (including lithium ion polymer batteries)
- UN 3481 — LITHIUM ION BATTERIES PACKED WITH EQUIPMENT (including lithium ion polymer batteries)
Every classification decision turns on a single question: what is the physical relationship between the battery and the equipment at the time of transport? That relationship — and nothing else — determines which of the three proper shipping names applies.
The three entries at a glance
| Proper Shipping Name | UN Number | Battery–Equipment Relationship | Risk Level |
| LITHIUM ION BATTERIES | UN 3480 | Batteries shipped alone — no equipment in the same outer packaging | Highest |
| LITHIUM ION BATTERIES CONTAINED IN EQUIPMENT | UN 3481 | Battery physically installed inside the apparatus — equipment casing provides protection | Lower |
| LITHIUM ION BATTERIES PACKED WITH EQUIPMENT | UN 3481 | Battery separate but co-packed alongside equipment in the same outer packaging | Medium |
Frequently Asked Questions
| # | Question | Answer |
| 1 | What is the difference between a cell and a battery for transport purposes? | A cell is the basic electrochemical unit — anode, cathode, and electrolyte — that converts chemical energy to electrical energy. A battery is two or more cells electrically connected together with devices necessary for use (case, terminals, protective devices). A single-cell battery is treated as a cell for transport purposes. [Manual of Test and Criteria Part III, 38.3.2.3; SP 188, IMDG Code 42-24] |
| 2 | How do I determine whether my shipment should be UN 3480 or UN 3481? | Apply one test: what is the physical relationship between the battery and the equipment at the time of transport? Batteries shipped alone with no equipment in the same outer packaging = UN 3480. Batteries installed inside equipment, or separately co-packed alongside equipment in the same outer packaging = UN 3481. [2.9.4, IMDG Code 42-24] |
| 3 | What is the difference between “Contained in Equipment” and “Packed with Equipment” under UN 3481? | Contained in Equipment: the battery is physically installed inside the apparatus — an integral component; the equipment casing provides protection during transport. Packed with Equipment: the battery is separate from the equipment but both are in the same outer packaging as a commercial unit; the battery has not been installed into the device. Both are UN 3481 but require different proper shipping names on the DGD and package marks. [PI P903, 4.1.4.1, IMDG Code 42-24] |
| 4 | Can I use the same proper shipping name for both “Contained in Equipment” and “Packed with Equipment”? | No. Each is a distinct proper shipping name and must appear exactly on the package mark and DGD. Using the wrong name — or a generic “UN 3481 lithium ion batteries” description — is a mis-declaration. [DGL, Chapter 3.2, IMDG Code 42-24] |
| 5 | Are battery-powered electric bicycles and scooters classified under UN 3481? | No. SP 360 expressly routes all vehicles solely powered by lithium ion batteries — including e-bikes, e-scooters, electric wheelchairs, and electric cars — to UN 3556 VEHICLE, LITHIUM ION BATTERY POWERED. UN 3481 must not be used for these goods. [SP 360, IMDG Code 42-24] |
| 6 | What are the watt-hour thresholds for Special Provision 188? | Lithium ion cell: not more than 20 Wh. Lithium ion battery: not more than 100 Wh. Cells or batteries exceeding these thresholds must be transported as full Class 9 DG under the applicable packing instruction. [SP 188, IMDG Code 42-24] |
| 7 | If my shipment qualifies under Special Provision 188, do I still need a dangerous goods declaration? | No DGD is required for SP 188 shipments. However, the UN number must still appear on each package as the lithium battery mark (UN 3480 or UN 3481 as applicable), and all SP 188 packaging and marking conditions must be met. [SP 188 .6, 5.2.1.10.2, IMDG Code 42-24] |
| 8 | Does the 30 kg gross mass limit under SP 188 apply to UN 3481 shipments? | No. SP 188 sub-clause .8 states that the 30 kg gross mass limit does not apply when cells or batteries are installed in or packed with equipment. The 30 kg limit applies only to UN 3480 — standalone batteries shipped without equipment. [SP 188 .8, IMDG Code 42-24] |
| 9 | What is the state of charge requirement for lithium ion batteries under IMDG Code 42-24? | The IMDG Code does not impose a state of charge condition on standard UN 3480 or UN 3481 shipments. State of charge is addressed specifically in Packing Instructions P906 and LP906, which govern damaged or defective lithium ion cells and batteries transported under SP 376. In that context, the consignor must assess and ascertain the state of charge as part of determining the hazard level of the damaged or defective goods before offering them for transport. For normal, undamaged lithium ion battery shipments under PI P903 or SP 188, no SoC limit is prescribed by the IMDG Code. [PI P906; LP906; SP 376, IMDG Code 42-24] |
| 10 | Does a laptop qualify as Class 9 dangerous goods when shipped by sea? | Only if the battery exceeds 100 Wh. Most laptops with batteries at or below 100 Wh qualify for SP 188 relief and are not subject to full Class 9 requirements. They remain assigned to UN 3481 LITHIUM ION BATTERIES CONTAINED IN EQUIPMENT and the lithium battery mark is still required on the package. [SP 188; 5.2.1.10.2, IMDG Code 42-24] |
| 11 | What packing instruction applies to UN 3480 and UN 3481? | Both entries use Packing Instruction P903 (and LP903 for large packagings). P903 has three operative paragraphs: (1) for cells/batteries only, (2) for batteries contained in equipment, and (3) for batteries packed with equipment. [PI P903, 4.1.4.1, IMDG Code 42-24] |
| 12 | What label is required on packages of Class 9 UN 3480 and UN 3481? | The Class 9 lithium battery label, model 9A, not the generic Class 9 label. The lithium battery label incorporates the battery graphic and is specified separately in 5.2.2.2.2. [5.2.2.2.2, IMDG Code 42-24] |
| 13 | Is a dangerous goods declaration required for UN 3480 and UN 3481 shipments that exceed SP 188 thresholds? | Yes. A DGD is required for all shipments of UN 3480 and UN 3481 that are subject to full Class 9 requirements (i.e., above SP 188 thresholds). The DGD must state the correct proper shipping name, UN number, class, packing instruction reference, and net quantity. [Chapter 5.4, IMDG Code 42-24] |
| 14 | What does the term “equipment” mean under the IMDG Code lithium battery provisions? | Equipment means apparatus for which the cells or batteries will provide electrical power for its operation. The definition appears identically in PI P903 (4.1.4.1) and SP 188 sub-clause .8. Vehicles solely powered by lithium ion batteries are not “equipment” for this purpose — SP 360 routes them to UN 3556. [PI P903; SP 188 .8; SP 360, IMDG Code 42-24] |
| 15 | What is the UN 38.3 test requirement and who must comply? | Each cell and battery must be of a type proved to meet the requirements of each test in the UN Manual of Tests and Criteria, Part III, Subsection 38.3 (T1–T8 tests). This applies to all three entries — UN 3480 and both configurations of UN 3481 — and cannot be waived by any special provision. [2.9.4.1, IMDG Code 42-24] |
| 16 | What are the stowage and segregation requirements for UN 3480 and UN 3481? | Both entries: stowage category A (on deck or under deck permitted), EmS F-A / S-I. SW19 applies for batteries transported under SP 376 or SP 377 (damaged/defective or for disposal), requiring category C stowage, except on short international voyages. No segregation from other classes is required under standard conditions. [Part 7, IMDG Code 42-24] |
| 17 | What should I do if a package contains batteries both installed in equipment and packed alongside equipment? | Apply SP 390. The package must be marked and documented as UN 3481 LITHIUM ION BATTERIES PACKED WITH EQUIPMENT. Button cell batteries installed in equipment (including circuit boards) need not be considered for this purpose. [SP 390, IMDG Code 42-24] |
| 18 | Can UN 3480 and UN 3481 be transported on passenger vessels? | Yes — there is no vessel-type restriction for sea transport under the IMDG Code. Both entries are permitted on cargo and passenger vessels. Carriers may impose their own acceptance conditions, particularly for high-energy batteries or large consignments. [DGL, Chapter 3.2; Part 7, IMDG Code 42-24] |
| 19 | What is SP 348 and when does it apply? | SP 348 requires that lithium ion batteries manufactured after 31 December 2011 be marked with the watt-hour rating on the outside casing. The Wh marking is essential because it is the primary basis for determining whether SP 188 relief applies. [SP 348, IMDG Code 42-24] |
| 20 | What is the correct emergency response procedure for a lithium ion battery fire at sea? | EmS F-A / S-I applies. The critical operational point is that lithium ion battery fires may re-ignite after apparent extinguishment, the fire must not be assumed to be out. Water flooding of the cargo hold is the recommended response for large-scale battery fires at sea. Crew must continue to monitor the space after initial suppression. [EmS Guide; F-A Fire Schedule, IMDG Code 42-24] |
For the full compliance guide covering definitions, packing instruction, SP 188 thresholds, SP 360 vehicle routing, and worked classification examples download Lithium Battery: A Practical Maritime Dangerous Goods Reference
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