
Lithium-ion and metal batteries are classified as hazardous goods for transport.
Products containing these batteries are also considered hazardous goods.
There are three options for transport. It can be carried out as an ADR exemption (transport under provision 188), as transport of small quantities of hazardous goods (up to 1000 points), or as a "full" ADR transport.
Let's first look at what transport under special provision 188 means.
Transport under provision 188 requires that the package (the box containing the batteries) is marked with the following label:

This applies if the lithium content does not exceed 2 g in metal batteries or 100 Wh in ion batteries. In this case, the orange plates on the vehicle must be closed, as it is an ADR exemption. A transport document is NOT required. And the driver does not need an ADR certificate.
What is important to know in the second case, which is transport of small quantities of hazardous goods (up to 1000 points)?
In this case, the lithium content exceeds 2 g (metal batteries) or 100 Wh (ion batteries). In this case, the package must be labeled with ADR label no. 9A:

Information on the transport document can include:
- UN 3480, LITHIUM ION BATTERIES, 9, (E)
- UN 3481, LITHIUM ION BATTERIES, CONTAINED IN EQUIPMENT, 9, (E)
- UN 3481, LITHIUM ION BATTERIES, PACKED WITH EQUIPMENT, 9, (E)
- UN 3090, LITHIUM METAL BATTERIES, 9, (E)
- UN 3091, LITHIUM METAL BATTERIES IN EQUIPMENT, 9, (E)
- UN 3091, LITHIUM METAL BATTERIES, PACKED WITH EQUIPMENT, 9, (E)
In all cases, it falls under transport category 2. This means that under exemption 1.1.3.6, up to 333 kg of batteries can be transported (to calculate points, multiply the quantity by 3).
Therefore, if batteries are transported in quantities up to 333 kg, the driver does not need an ADR certificate. The orange plates on the vehicle must be closed.
Here are the names in English:
- UN 3480: LITHIUM ION BATTERIES
- UN 3481: LITHIUM ION BATTERIES CONTAINED IN EQUIPMENT
- UN 3481: LITHIUM ION BATTERIES PACKED WITH EQUIPMENT
- UN 3090: LITHIUM METAL BATTERIES
- UN 3091: LITHIUM METAL BATTERIES CONTAINED IN EQUIPMENT
- UN 3091: LITHIUM METAL BATTERIES PACKED WITH EQUIPMENT
Now let's see when we talk about "full" ADR transport. "Full" ADR transport applies if the following conditions are met:
- All ADR details are listed in the transport documents (UN number, ADR name, label number, etc.)
- Over 1000 points are exceeded (total battery weight over 333 kg). In this case, the orange plates on the vehicle must be open. The driver needs an ADR certificate.
If you're unsure how to transport batteries or other hazardous goods in compliance with ADR regulations, write to me at: simona.miklavcic@bens-consulting.eu.
Avtor originalne fotografije Freepik
bojan.dimic@bens-consulting.eu





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