This guide is designed to provide comprehensive but hopefully an easily understood summary of the complex requirements for transporting Lithium Batteries for recycling or disposal in Australia.
Due to their potential to cause fires and explode Lithium Batteries are classified as a Dangerous Good. Their transport by road or rail within Australia is regulated by the Australian Code for Transportation of Dangerous Goods by Road & Rail (ADGC). This guide is based of edition 2.9 of the ADGC which comes into effect as of October 2024 and has a 12 month grace period before they become mandatory.
My aim with this guide is to try to simplify this complexity while retaining critical information.
This Guide Does NOT include the requirements for
- Transport by Sea or Air
- Transport by Road or Rail of new lithium batteries or equipment containing batteries
- State based Hazardous / Controlled Waste Transport requirements
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About Lithium Batteries and How to Identify Them
There has been an explosion in the use of batteries to power our modern lives, with Lithium batteries being the most common new chemistries used. Unfortunately, with more power packed into smaller and smaller batteries comes an increase in fire risks with Fire Department’s worldwide dealing with an increase in battery related fires that are causing significant property damage, injuries and even loss of human life. Australia reported its first fatalities in 2023 and in the UK 13 people have reportedly died in 2023 due to battery fires.
Yes, many fires are a result of poor-quality batteries, overcharging, battery damage or poor storage conditions however there are also fires being reported of Lithium batteries without these causes. Take a look at this home owner’s CCTV footage of a relatively new power tool battery that self-combusted in Perth, Western Australia. Pretty scary stuff and as the homeowner said he was lucky it was only his alfresco area that was damaged, and he didn’t lose his house.
Lithium batteries are being used to power an increasing range of products and devices from vapes, cameras, mobile phones, laptops, drones, electric bikes and scooters, toys, power tools, security systems, power backup systems, electric vehicles and many other applications.
They come in all shapes and sizes and sometimes are not readily distinguished from other battery chemistries. You may find that you must closely inspect the label or failing this conduct an internet search for the battery’s specifications based on the its make & model.
When examining the battery label look for the word “Lithium” or the chemical symbol “Li” and if you are unable to find this then do an internet search based on the battery’s make & model.
Australian Lithium Battery Shipping Regulation by Road or Rail
The Australian Code for the Transportation of Dangerous Goods by road or rail (ADGC), forms the framework of each State’s Dangerous Goods Transport Regulations. The transport requirements for lithium batteries destined for recycling or disposal are detailed and complex as they must cover many different scenarios such as the battery’s power & chemistry, whether the battery is damaged or defective, the size of the battery and whether it is contained in equipment or not.
ADGC Definitions
Let’s start with a few definitions from the ADGC will help your understanding of the shipping requirements.
Cell vs a Battery: Single, small batteries (button, AA, AAA, D size) are usually defined as a Cell, while larger batteries, which are comprised of more than one cell, such as those used in power tools, laptop electric bikes, scooter etc are defined as a Battery.
Damaged or Defective: A Lithium Battery should be classified as damaged or defective if any of the following apply, but are not limited to:
- Cells or batteries identified as being defective for safety reasons;
- Cells or batteries that have leaked or vented;
- Cells or batteries that cannot be diagnosed prior to transport; or
- Cells or batteries that have sustained physical or mechanical damage.
Dangerously Damaged or Defective: These are cells or batteries that are liable to rapidly disassemble, dangerous react, produce a flame or a dangerous evolution of heat or a dangerous emission of toxic, corrosive or flammable gases or vapours under normal conditions of transport. Please refer to the Special Provision 376 for greater detail on determining if a battery is dangerously damaged or defective.
Lithium-Ion vs Lithium Metal: Lithium Ion batteries are generally rechargeable while Lithium Metal are designed for single use.
UN Numbers & Their Proper Shipping Name: The following Dangerous Goods UN Numbers apply to Lithium Cells / Batteries,
- 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)
- UN3091 – Lithium Metal Batteries Contained in Equipment or Packed with Equipment
And for Sodium Ion Batteries
- UN3551 – Sodium Ion Batteries with organics electrolyte
- UN3552 – Sodium Ion Batteries Contained in Equipment or Sodium Ion Batteries Packed with Equipment, with organics electrolyte
Packaging Instructions: The ADGC provides specific Packaging Instructions for different types of Dangerous Goods. For Lithium batteries destined for disposal or recycling, the follow 3 Packaging Instructions apply,
P909 – For transporting non damaged Lithium cells or batteries for the purpose of disposal or recycling.
P908 / LP904 – For transporting damaged or defective Lithium cells or batteries (see above definition for damaged or defective)
P911 / LP906 – For transporting dangerously damaged or defective Lithium cells or batteries (see above definition for dangerously damaged or defective)
Packaging: Refers to one or more receptacles and any other components or materials necessary for the receptacles to perform their containment and other safety functions.
For some Lithium cells / batteries only authorised packagings (UN Certified) can be used for the transportation of Lithium Batteries for disposal or recycling.
For scenarios requiring an authorised packaging, a mark commencing with the letter UN and followed by the packaging type (e.g UN4H2/… for plastic boxes) must be displayed. However, beware as a UN mark doesn’t mean the packaging is suitable for Lithium Batteries. You will need to check the UN Certification test report from the supplier to ensure that the packaging’s testings are appropriate for Lithium Battery shipping.
Power Threshold Test – Low vs High Power
While not an ADGC term I have introduced it here to simplify my explanation of the ADGC shipping requirements. Clause (2) of the P909 Packing Instruction (non-damaged Lithium batteries for disposal or recycling) allows for different packaging requirements based on the Lithium content or power of a battery.
For this guide, I am going to define Lithium Metal Cells with less than 1g of Lithium content and Lithium Metal Batteries with an aggregate Lithium content of less than 2g as Low Power
or
Lithium Ion cells with a Watt-hour rating of not more than 20Wh and Lithium Ion Batteries with a Watt-hour rating of not more than 100Wh as Low Power
Cells or Batteries that exceed these thresholds I will refer to as High Power.
Note: You can calculate the power rating of a battery by multiplying the current by the voltage. So, for example a 5 Ah 18V battery will have a power rating of 90Wh and would be classified as low power.
Lithium Battery Packaging Requirements
There are 3 ADGC Packaging Instructions that can apply to the shipment of used or waste Lithium batteries. They are:
P909 – For transporting non damaged Lithium cells or batteries for the purpose of disposal or recycling.
P908 – For transporting damaged or defective Lithium cells or batteries (see above definition for damaged or defective)
P911 – For transporting dangerously damaged or defective Lithium cells or batteries (see above definition for dangerously damaged or defective)
Let’s take a closer look at each one.
P909 – For transporting non damaged Lithium cells or batteries for the purpose of disposal or recycling.
Download P909 Packaging Instruction here
I suspect when you first try to read the P909 you will find it a bit overwhelming, so let’s see if we can simplify it for you.
Clause 1 of the P909 specifies the types of Authorised Packagings (UN Certification) you are permitted to ship your Lithium batteries in. Before using a particular receptacle / packaging ask the manufacturer / supplier whether it has been certified for the transport of used lithium batteries and for them to provide a copy of the UN certification test. Note metal packagings must be fitted with an electrically non-conductive lining material.
There are 3 instances when you do not need to use Authorised Packaging. They are
- You can use a strong out packaging if the batteries being transported are Low Power and the gross weight of the packaging doesn’t exceed 30kg. The outer packaging must be strong enough to withstand the shocks and loadings normally encountered during transport and be able to prevent any loss of contents under normal transport conditions. This allows a strong well-constructed cardboard box to be used for the transport of Low Power Lithium batteries.
- Batteries greater than 12kg with a strong, impact resistant out casing can be transported in a strong outer packaging constructed of suitable material and adequate strength for the intended use.
- Cells or batteries contained in equipment can be shipped in a strong outer packaging constructed of suitable material and adequate strength for the intended use. Note also that equipment can be transported unpackaged or on pallets when the cells or batteries are afforded equivalent protection by the equipment.
Your lithium batteries can be packed together with or without non-lithium batteries. This is usually done when transporting small handheld batteries such as AA, AAA, D, C etc.
The Additional Requirements of the P909 outline further requirements when packaging the Lithium batteries and are designed to reduce the fire risks. Some are not very practical in my opinion such as “individual protections of the battery terminals” when you are transporting thousands of small handheld batteries.
Special Provisions that can apply to the P909
The ADGC has several Special Provisions that apply for Lithium batteries. Below is a summary of the ones that are relevant when transporting Lithium Batteries for disposal or recycling.
You can download the exact wording of the relevant Special Provisions here.
Special Provision 377
When shipping non damaged lithium batteries, either packed with or without non-lithium batteries the Packages must be marked “LITHIUM BATTERIES FOR DISPOSAL” or “LITHIUM BATTERIES FOR RECYCLING, as appropriate.
Special Provision 188 and my confusion
Initially I though Special Provision 188 offered a convenient way to transport Low Powered, non-damaged Lithium batteries for disposal or recycling, but I have now formed the opinion that it was primarily written for new lithium batteries and attempting to apply it for used or waste lithium batteries is problematic.
Clause (d), of Special Provision 188, is the source of my confusion and concern.
My interpretation is that cells or batteries must be packed, individually, in inner packagings. The clause uses the singular reference to cell or battery and not plural and hence it does not appear to allow for multiple cells or batteries to be packed in an inner package.
This would make it impractical when it comes to transporting used or waste lithium batteries. Not many of us would be inclined to place a single AA or AAA battery into its own package and even for larger Lithium batteries, such as many power tool batteries, that are still classified as Low Power batteries, it would be difficult to find suitable packaging that accommodates the many different shapes and sizes these batteries come in.
The Special Provision also allows for the use of the Lithium-Ion Battery Mark, to be displayed on the Packagings as an alternative to the DG Class diamond 9A and the full UN proper shipping name. This is shown below:
However, if my interpretation of the SP188 is correct then this won’t apply for the lithium batteries being shipped for disposal or recycling. It also means that many businesses and organisations are using the wrong DG Label when transporting Lithium batteries for disposal or recycling.
P908 & LP904 – For transporting damaged or defective Lithium cells or batteries (see above definition for damaged or defective)
Download P908 Packaging Instruction here
Download LP904 Packaging Instruction here
When should a Lithium Cell or Battery be classified as Damaged or Defective for the purposes of transporting the battery for disposal or recycling? The Special Provision 376 states the following may be considered damaged or defective, but are not limited to:
- Cells or batteries identified as being defective for safety reasons;
- Cells or batteries that have leaked or vented;
- Cells or batteries that cannot be diagnosed prior to transport; or
- Cells or batteries that have sustained physical or mechanical damage.
The packaging instructions for P908 and LP904 are very similar except for the Packaging types that are permissible. LP904, specifies larger Packaging types, designed for large single batteries or single items of equipment containing damaged or defective batteries. The P908 permits multiple cells or batteries to be packaged together.
The following Packaging Requirements apply to both the Packing Instructions P908 and LP904.
Individual cells or batteries or equipment must be packed individually in an inner packaging. The inner packages are to be placed inside an outside packaging. Both the inner & outer packaging must be an Authorised Packaging (UN Certified for Lithium batteries) and if sealed be fitted with a venting device.
Measures must be taken to minimise the effects of vibrations, shocks and to prevent the movement of cells or batteries that could lead to further damage during transport. Cells or batteries must also be protected against short circuit.
Each inner packaging must be surrounded by sufficient non-combustible and non-conductive thermal insulation material (non-combustibility should be determined by the appropriate Australian Standard – tip there isn’t one).
P908 also requires that If the cell or battery is greater than 30kg it must be limited to one cell or battery per outer packaging.
Special Provision 376 and how it applies to P908 & LP904
Packages must be marked “DAMAGES/DEFECTIVE” in addition with the UN Proper shipping name (see ADGC definitions for these). The Dangerous Good Transport Document should include the following statement “Transport in accordance with special provision 376”
P911 & LP906 – For transporting dangerously damaged or defective Lithium cells or batteries (see above definition for dangerously damaged or defective)
Download P911 Packaging Instruction here
Download LP906 Packaging Instruction here
The Special Provision 376 provides greater detail on how to determine if a cell or battery dangerously damaged or defective where the Packing Instruction P911 or LP906 would apply.
The packaging must be an Authorised Packaging (UN Certified) to a packing group 1 performance level, as defined in the ADGC.
The P911 & LP906 outlines several additional detailed and complex performance requirements for the packaging.
The Special Provision 376 also requires that Packages must be marked “DAMAGES/DEFECTIVE” in addition with the UN Proper shipping name (see ADGC definitions for these). The Dangerous Good Transport Document should include the following statement “Transport in accordance with special provision 376”
Shipment Markings & Labels when Transporting Lithium Batteries
The ADGC requires that each Packaging is marked with:
- The UN Number and Proper Shipping Name for each type of Lithium battery present (see ADGC Definitions earlier in this article).
- The Name and Address of the consignor of the batteries.
- The words “LITHIUM BATTERIES FOR DISPOSAL” or “LITHIUM BATTERIES FOR RECYCLING” or “DAMAGED/DEFECTIVE”, as appropriate (see Special Provision 377 & 376 for detail).
The markings should be a minimum of 12mm high, unless the package is 30kg or less and they can be 6mm high.
The Packages must display the Dangerous Good Class diamond Model No 9A, shown below. Generally, the label should be a minimum of 100mm x 100mm should be used, unless the size of the package doesn’t permit it. It can then be reduced proportionally provided the symbol and other elements are clearly visible.
Special Provision 384 requires Packaging used to transport lithium batteries, that the DG Class diamond Model No 9A should be used, while for placarding of transport units, the placard shall correspond to Model No 9. Each is depicted below.
Placarding Requirements
Placarding as defined in the ADGC is the display of an Emergency Information Pabel (EIP). Below is a simplified summary of the ADGC Placarding requirements for how they are likely to apply for transporting waste lithium batteries. You can find the full requirements in Chapter 5.3 of the ADGC, but beware they are not a light read.
Placarding 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.
Below is displayed an example of an Emergency Information Panel for a Lithium-Ion Batteries (UN 3480).
Dangerous Goods Transport Documentation
The transport of Lithium batteries requires a dangerous good transport document, that must be carried in the vehicle in hard copy form. The consignor must provide a copy of the document to the driver.
The documentation must include the name and address of the consignor, consignee, including the consignor’s contact telephone number.
A separate entry for each type of Lithium battery present (e.g. UN3480, 3481, 3090, 3091), with the following information:
- UN Number
- Proper Shipping Name
- DG Class – 9
- Packing Group – is not applicable as batteries are defined as Articles in the ADGC
- Description of Packages
- The number of each type of package
- The Gross Aggregate Quantity of Dangerous Good – Record the gross weight of batteries (including other chemistries)
You can download a dangerous good transportation document word template here.
Emergency Procedure Information
Emergency information needs to be carried on each road vehicle or train transporting Lithium batteries in a placard load. The Emergency information should include an Emergency Procedure Guide in relation to the Lithium batteries and a vehicle fire.
The Emergency Procedure Guide should be in the form of one of the following relevant guides,
- The Australian & New Zealand Emergency Response Guidebook
- Standards Australia
- In a form approved by the Competent Authority
I have summarised below, the relevant sections/pages of the Australian & New Zealand Emergency Response Guidebook, as they apply to both Lithium Ion and Lithium Metal Batteries:
- Pg 8 – Safety Precautions
- Pg 9 – Notifications & Request Technical Information
- Pg 156 – How To Use Guides
- Pg 232 – Guide 147 for Lithium-Ion Batteries
- Pg 214-215 – Guide 138 for Lithium Metal Batteries
You can download the Australian & New Zealand Emergency Response Guidebook from the National Transport Commissions website.
The Emergency Information should be placed in an Emergency Information Holder on the inside door of the cabin or immediately adjacent. For further detail regarding the ADGC’s Emergency Information requirements refer to Chapter 11.2 of the ADGC.
Conclusion
While a lot to digest, I hope this article has helped with your understanding the Australian shipping requirements for used or waste Lithium Batteries. If you have any questions, please feel free to email me at davidbush@batteryrescue.com.au
Please note that this article is based on my best endeavours to interpret the complexities of the ADGC and does not constitute legally binding advice. Readers should always seek alternative opinions if they are wanting clarification or certainty on the requirements.
