In an age dominated by the use of portable electronic devices, the demand for lithium-ion batteries has soared, but so has the need to responsibly manage their end-of-lifecycle. Technology lifecycle services companies, such as Greentec, provide a crucial role in ensuring the safe pick-up of these electronic devices which contain lithium-ion batteries. There are intricate regulations surrounding the transportation of lithium-ion batteries contained in devices that many are unaware of. In this article, we will look at the key regulations that you must comply with when shipping any electronic devices containing these batteries. These devices include most PCs, laptops, Chrome books, tablets, smartphones, headphones and more.
In Canada, the shipping of lithium batteries is subject to the Transportation of Dangerous Goods Act, (TDG Act) and its regulations. They are considered dangerous goods much like gasoline, propane, and sulfuric acid.
Shippers and transporters must meet the classification, documentation, labelling, packaging, and training requirements set out in the TDG Regulations for the handling, offering for transport, transporting, and importing of lithium batteries in Canada. The requirements vary by mode of transport.
Individual Canadian provinces can also regulate the handling and recycling of lithium batteries. For example, Ontario Resource Recovery and Circular Economy Act, 2016 designates electronics and batteries as the individual producer responsibility regulatory framework.
To ship and transport electronic equipment containing lithium-ion batteries, you must:
- Declare the batteries to the transporter as part of the contents
- Meet all other shipping requirements in the TDG Regulations
- Ensure the device is switched off and properly packed to protect the device
- Separate packaged batteries or cells to prevent short circuits and damage to terminals
Batteries contained in electronic equipment are as classified as UN 3481 (lithium ion batteries) and are subject to the TDG Regulations Schedule 2 – Special Provision 138. Contained in equipment means the battery is installed in the device and connected to it. The TDG regulation for contained in equipment depends on the type, size, and quantity of batteries. Some general rules are:
- The maximum net quantity per package is 10 kg.
- Packages must be marked with the words “Lithium-ion batteries”, and with the words “in compliance with Section II of PI 967”
- Packages must also have a lithium battery handling label affixed to them
Section 2 of PI 967 is the packing instruction for lithium-ion batteries contained in the equipment. It provides the requirements for packaging, labelling, documentation, and quantity limits for these types of batteries. There are two sections in PI 967:
- Section I applies to equipment that contains lithium ion cells with a Watt-hour rating in excess of 20 Wh or lithium ion batteries with a Watt-hour rating in excess of 100 Wh. These packages must be assigned to Class 9 and are subject to all the applicable requirements of the TDG regulations.
- Section II applies to equipment that contains lithium-ion cells with a Watt-hour rating not exceeding 20 Wh or lithium-ion batteries with a Watt-hour rating not exceeding 100 Wh. Most portable consumer electronics like laptops, chrome books, MacBooks, headphones, and cell phones fall into this classification. These packages are exempted from the lithium battery handling label, but they still need to be marked with the words “Lithium-ion batteries” and “in compliance with Section II of PI 967
Transporting lithium-ion batteries requires UN38.3 testing due to these batteries being classified as a Class 9 dangerous good during transport, as they are a potential fire hazard. According to Transport Canada, used equipment containing lithium batteries may be exempt from UN testing if they meet the following criteria:
- The equipment is not subject to a recall for safety reasons
- The equipment is protected from short circuits
- The equipment is secured to prevent movement that could damage the battery
- The equipment is packaged in strong outer packaging
- The equipment is marked with the words “Used electronic equipment containing lithium batteries”
However, if the used electronic equipment contains damaged or defective lithium batteries, they are considered as dangerous goods and must comply with the UN testing and packaging requirements. Shipping damaged or faulty batteries can be extremely dangerous, with the risk of fire, smoke, and fumes. For this reason, any battery that is suspected or known to be defective (swelling, corroding, or leaking, for example) is not permitted for standard shipping.
- Packaging and Labelling
Proper packaging and labelling is required for safe transportation of devices containing lithium-ion batteries. You must use packaging that meets the required safety standards to prevent physical damage or short-circuits during transportation. This includes using a strong, fiberboard box that meets a 1.2-meter drop test. Each box must be labelled with a lithium battery handling mark, a lithium-ion battery statement or an aircraft-only label. Once these boxes are packed onto a skid, they must be remarked on two sides with all marks used, as well as an “Overpack” and “Lithium Batteries for Disposal” label.
- Mode of Transportation
The mode of transportation needed to transport lithium-ion batteries contained in electronic devices, significantly impacts regulations. It is important that you are always informed about the specific requirements for each mode and adjust their process accordingly. For example, regulations would be different for sea shipments based on the International Maritime Dangerous Goods (IMDG) code versus air shipments based on the IATA regulations.
- International Air Transport Association (IATA) Regulations
When shipping lithium-ion batteries by air, you must adhere to the IATA Dangerous Goods Regulations. These regulations classify lithium-ion batteries based on their energy content and outline packaging, labelling, and documentation requirements. You need to ensure that staff are properly trained to package and label these batteries correctly to avoid violations. The IATA has produced a document to help individuals comply with these regulations. This document can be found on IATA’s website here: https://www.iata.org/contentassets/05e6d8742b0047259bf3a700bc9d42b9/lithium-battery-guidance-document.pdf
- National and International Regulations
If you are shipping lithium-ion batteries internationally should be well versed in the varying regulations of their origin and destination countries. Compliance with international regulations is crucial to avoid delays or fines.
At Greentec, we ensure proper handling of ITAD, and e-waste services for electronics that contain lithium-ion batteries. UN38.3 testing, proper packaging, and labelling, selecting the appropriate mode of transportation, and understating the national and international regulations are all critical aspects of navigating the complex process of transporting lithium-ion batteries.