A Guide to Exporting Lithium Batteries from China
Introduction:
In recent years, lithium batteries have found widespread use in consumer products, industrial production, vehicle manufacturing, and various other industries. China is a major producer and exporter of lithium battery products. However, lithium batteries are classified as hazardous goods due to the potential risks of fire and explosions during transportation. Therefore, it is crucial to prioritize the safety of lithium battery exports.
Export Regulatory Requirements for Lithium Batteries:
International Regulations:
According to international cargo transportation regulations such as the United Nations Recommendations on the Transport of Dangerous Goods (TDG), the International Maritime Dangerous Goods (IMDG) Code, and the International Civil Aviation Organization Technical Instructions (ICAO-TI), lithium batteries are classified as Class 9 dangerous goods. Unless exempted from using dangerous goods packaging, lithium batteries must be transported using packaging that complies with international regulatory requirements.
Chinese Legal Regulations:
As per the relevant provisions of the People’s Republic of China Import and Export Commodity Inspection Law, manufacturers of lithium battery packaging must apply for a performance inspection of hazardous goods packaging from the local customs. Upon passing the inspection, customs will issue an “Export Inspection Result Certificate for Dangerous Goods Packaging.” Lithium battery companies intending to export must procure the appropriate hazardous goods packaging from manufacturers that can provide this certificate. After packaging lithium batteries, companies should apply for a usage appraisal of hazardous goods packaging from local customs, and upon approval, customs will issue an “Export Inspection Result Certificate for Dangerous Goods Packaging Usage Appraisal,” commonly referred to as the “Dangerous Goods Packaging Certificate.” Lithium battery packaging with this certificate complies with customs regulations and international requirements for hazardous goods packaging.
Common Violations in the Export of Lithium Batteries:
Customs Inspection Focus:
Customs at the export ports inspect the “Dangerous Goods Packaging Certificate” issued by the local customs. The main focus of this inspection is to verify whether the information on the export lithium battery “Dangerous Goods Packaging Certificate” matches the actual cargo. This includes checking packaging types, UN markings, lithium battery markings, actual export quantities, and other related information.
Common Violations:
Based on common violations, the primary issues include:
- Failure to apply for the “Dangerous Goods Packaging Certificate” as required, except in cases exempted from the condition, leading to an inability to provide the necessary certificate during customs inspections at the port.
- Some lithium battery outer packaging has obscured lithium battery markings or fails to display them as required.
Exemptions for Some Lithium Batteries:
UN3171 Lithium Batteries:
Lithium batteries used in vehicles such as electric cars and electric bicycles are exempt from hazardous goods packaging requirements.
Lithium Batteries with Small Rated Capacity or Lithium Content:
Specifically, for lithium metal batteries or lithium alloy batteries, the lithium content does not exceed 1 gram. For lithium metal or lithium alloy battery packs, the total lithium content does not exceed 2 grams. For lithium-ion batteries, the watt-hour rating does not exceed 20W·h, and for lithium-ion battery packs, the watt-hour rating does not exceed 100W·h. These batteries, when meeting the specific provisions of Article 188 of the IMDG Code, are exempt from hazardous goods packaging requirements. It’s important to note that this exemption only applies to the “Dangerous Goods Packaging Certificate” requirement; lithium battery outer packaging should still indicate the watt-hour rating and carry appropriate lithium battery markings.
Typical Cases:
Case 1: Export of Lithium Battery Packs Without Proper Declaration
In December 2021, a customs inspection at a port found that a batch of lithium battery packs was exported without the proper declaration and transportation as hazardous goods. The shipment was subsequently sampled and tested, revealing it to be hazardous goods. The responsible party, as the manufacturer of the hazardous goods, did not apply for the usage appraisal of hazardous goods packaging containers from the customs at the production location. According to Article 50, Paragraph 1 of the Regulations for the Implementation of the People’s Republic of China Import and Export Commodity Inspection Law, an administrative penalty was imposed on the party.
Case 2: Lithium-Ion Battery Pack Export Without Capacity Marking
In March 2021, a customs inspection found that a batch of lithium-ion battery packs (listed as Energy Storage System 230P) declared for export lacked capacity markings in watt-hours (W∙h). This omission did not comply with Rule 348 of Chapter 3.3 in the IMDG Code, leading to a requirement for technical correction.
Case 3: Inadequate Protection of Battery Pack Switch During Transportation
In January 2021, a customs inspection revealed that a batch of exported battery packs had a switch that could be easily triggered during transportation, posing a significant safety risk. This non-compliance with Packaging Specification P903 in the IMDG Code required technical correction.
Conclusion:
Exporting lithium batteries from China is subject to stringent international and domestic regulations. To ensure compliance and safety, it is essential to adhere to the requirements for hazardous goods packaging and declaration. Properly declaring and packaging lithium batteries will help prevent regulatory violations and contribute to the safe and efficient export of these products.