ADR Regulations for Shipping 800 kg of Lithium Batteries

Question asked to Palen

Revised on Sep 1, 2026

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I need to ship 800 kg of lithium batteries. What ADR regulations do i need to comply with?

Regulatory route for 800 kg of lithium batteries

The shipment is not determined by the 800 kg total alone. First establish the battery chemistry, whether batteries are shipped standalone, packed with equipment, or contained in equipment, and whether they are new, used for recycling, damaged, or defective. Lithium batteries are assigned, as appropriate, to UN 3090, UN 3091, UN 3480, or UN 3481. (ADR 2.2.9.1.7.1, Volume 1, page 239)

1. Check Special Provision 188 first — possible full ADR relief

The entire 800 kg consignment is not subject to other ADR provisions if every cell, battery, package, and shipment condition meets Special Provision 188. This relief is not expressed as a total consignment-mass cap; however, the package-level conditions remain decisive. (ADR 3.3, Special Provision 188, Volume 1, pages 591–592)

For SP 188, the relevant limits and conditions include:

Lithium-ion cells: maximum 20 Wh per cell; lithium-ion batteries: maximum 100 Wh per battery. (ADR 3.3, Special Provision 188(a)–(b), Volume 1, pages 591–592)
Lithium-metal/alloy cells: maximum 1 g lithium content per cell; lithium-metal/alloy batteries: maximum 2 g aggregate lithium content per battery. (ADR 3.3, Special Provision 188(a)–(b), Volume 1, pages 591–592)
Cells and batteries must meet the applicable lithium-battery requirements, including UN Manual of Tests and Criteria, Part III, subsection 38.3 testing. (ADR 2.2.9.1.7.1(a), Volume 1, page 239; ADR 3.3, Special Provision 188(c), Volume 1, page 592)
Standalone cells and batteries must be completely enclosed in inner packagings, protected from short circuit and contact with conductive materials, and placed in strong outer packagings. (ADR 3.3, Special Provision 188(d), Volume 1, page 592)
Each package must carry the lithium battery mark, except for the limited exceptions for certain button-cell/equipment packages and very small equipment consignments. (ADR 3.3, Special Provision 188(f), Volume 1, page 592; ADR 5.2.1.9, Volume 2, page 239)
Packages of standalone cells or batteries must pass the 1.2 m drop test and may not exceed 30 kg gross mass. (ADR 3.3, Special Provision 188(g)–(h), Volume 1, page 592)

For a compliant SP 188 consignment, show the appropriate UN number on the battery mark: UN 3480 for standalone lithium-ion batteries, UN 3481 for lithium-ion batteries packed with or contained in equipment, UN 3090 for standalone lithium-metal batteries, or UN 3091 for lithium-metal batteries packed with or contained in equipment. (ADR 5.2.1.9.2, Volume 2, page 239)

2. If SP 188 is not met: normal ADR carriage applies

For batteries exceeding the SP 188 energy/lithium-content limits, or where any SP 188 packaging, test, marking, or condition is not met, ship under the applicable UN entry and apply the full ADR requirements associated with that entry. The battery type must have passed UN 38.3 testing; batteries must include protection against external short circuits, and manufacturers/subsequent distributors must make the required test summary available, except for the specified button-cell exception. (ADR 2.2.9.1.7.1(a)–(g), Volume 1, pages 239–240)

For normal, non-damaged lithium battery shipments, use P903. It authorizes specified drums, boxes, and jerricans at packing group II performance level; batteries must be protected against damage caused by movement within the package. Large batteries of at least 12 kg with a strong, impact-resistant outer casing may alternatively use strong outer packagings, protective enclosures, pallets, or other handling devices, provided they are secured against movement and their terminals do not bear superimposed loads. (ADR 4.1.4.1, P903, Volume 2, page 128)

Accordingly, the normal ADR shipment must be prepared with the applicable:

UN number and proper shipping description for the actual battery configuration; (ADR 2.2.9.1.7.1, Volume 1, page 239)
compliant P903 packaging and short-circuit/damage protection; (ADR 4.1.4.1, P903, Volume 2, page 128)
package marking and Class 9 lithium-battery hazard communication required for the assigned UN entry;
ADR transport document, vehicle documentation, crew equipment, and driver training requirements applicable to the assigned entry and quantity;
transport-category calculation under ADR 1.1.3.6 before relying on any small-load relief; and
Table A controls for the specific UN entry, including tunnel restriction code, loading/handling provisions, and security provisions where triggered.

3. Damaged, defective, waste, or recycling batteries

Do not use the normal P903 route for batteries assessed as damaged or defective. Such batteries require P908 or LP904; batteries liable to rapidly disassemble, dangerously react, ignite, evolve dangerous heat, or emit toxic, corrosive, or flammable gas/vapour require P911 or LP906. Packages require the prescribed “DAMAGED/DEFECTIVE LITHIUM … BATTERIES” marking, and the transport document must state: “Transport in accordance with special provision 376”. (ADR 3.3, Special Provision 376, Volume 1, pages 612–613)

Batteries sent for disposal or recycling may use P909 and require the applicable “LITHIUM BATTERIES FOR DISPOSAL” or “LITHIUM BATTERIES FOR RECYCLING” package marking. Identified damaged or defective batteries remain subject to Special Provision 376. (ADR 3.3, Special Provision 377, Volume 1, page 613)

Conclusion: 800 kg may move under SP 188 only where every package independently meets all SP 188 limits and conditions, notably the 30 kg gross package maximum. Otherwise, treat it as a full ADR Class 9 lithium-battery shipment under the correct UN entry and P903, unless the batteries are damaged/defective or destined for disposal/recycling, for which the special packaging and documentation routes above apply. (ADR 3.3, Special Provisions 188, 376 and 377, Volume 1, pages 591–592 and 612–613; ADR 4.1.4.1, P903, Volume 2, page 128)

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