UN 3480 Lithium Batteries on Europallets: ADR Test Rules

Question asked to Palen

Revised on Nov 6, 2026

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UN 3480, can i pack lithium batterys on a europallet and Cover them with wodden Boards and kartonage? Is there no testing of the packaging required?

Yes — but only under specific ADR conditions.

For UN 3480 lithium ion batteries, packing on a Europallet can be acceptable only if the battery has a gross mass of at least 12 kg and has a strong, impact-resistant outer casing. In that case, ADR P903 allows: strong outer packagings, protective enclosures such as fully enclosed crates or wooden crates, or pallets/other handling devices (ADR P903(2), Volume 2, page 131) .

If you use a pallet solution, the batteries must be secured so that they cannot move accidentally, and the terminals must not bear the weight of anything stacked above them (ADR P903(2), Volume 2, page 131) . They must also be protected against short circuits (ADR P910 additional provisions, Volume 2, page 138) .

For this specific P903(2) pallet/handling-device option, the packaging does not have to meet the ADR 4.1.1.3 packaging test requirements (ADR P903(2), Volume 2, page 131) .

So: wooden boards and cardboard are not automatically sufficient just because they cover the batteries. The arrangement must function as a robust protective enclosure or load-securing system: no shifting, no terminal loading, no short-circuit risk, and adequate protection against normal transport damage.

Important exceptions: if the batteries are damaged/defective, ADR special provision 376 leads to P908/LP904 or P911/LP906 depending on risk (ADR SP 376, Volume 1, page 612) . If they are transported for disposal or recycling, SP 377 may allow P909 (ADR SP 377, Volume 1, page 612; ADR P909, Volume 2, page 137) .

Sources

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