Cell or battery?
A cell is a single electrochemical unit. A battery is generally an assembly of cells, such as a power-tool, laptop, e-bike or scooter battery.
Lithium battery transport regulations
Used Lithium Battery Transport Regulations
A practical Australian guide to waste lithium battery transport, packing instructions and used lithium battery shipping regulations for recycling or disposal.
What regulations apply when transporting used lithium-ion batteries by road?
Used lithium battery transport regulations depend on chemistry, battery condition, destination and transport mode. Waste lithium battery transport for recycling or disposal require different packing instructions depending whether the batteries are damaged or defective batteries or not.
This guide focuses on Australian road and rail requirements under the ADG Code. When transporting lithium ion batteries by road, check the relevant classification, packing instruction, short-circuit protection and documentation. Used lithium battery shipping regulations for the US, UK, Europe, air or sea must be checked separately with the relevant authority and carrier.
Start here
What this guide covers
Lithium batteries are dangerous goods because damage, internal failure or heat can lead to fire, explosion or a dangerous release of toxic gases. Their road and rail transport in Australia is governed by the Australian Dangerous Goods Code (ADG Code).
Scope of this summary
This page focuses on used or waste lithium batteries being moved by road or rail for recycling or disposal. It summarises common decisions operators need to make: battery type, condition, power rating, packaging instruction, marks and transport paperwork.
The National Transport Commission lists ADG Code edition 7.9 as the latest edition, mandatory from 1 October 2025. Some states may set a later commencement date. Check the current Code and state commencement details.
Not covered here
- Transport by sea or air.
- New lithium batteries or equipment containing new batteries.
- State or territory hazardous-waste and controlled-waste permits.
- Every packaging, placarding or emergency scenario in the ADG Code.
Identify the shipment
Battery chemistry, condition and UN number all matter
Before choosing packaging, identify the battery chemistry, whether it is a cell or a battery, whether it is in equipment, and whether it is damaged.
Lithium-ion or lithium metal?
Lithium-ion batteries are generally rechargeable. Lithium metal batteries are usually primary, single-use batteries. The chemistry affects the UN number and applicable provisions.
Damaged or defective?
Treat a battery as potentially damaged or defective if it is identified as unsafe, leaking or venting, cannot be diagnosed before transport, or has physical or mechanical damage.
Packaging or receptacle?
A receptacle is the containment vessel, including its closure. Packaging includes the receptacle and the other components needed to perform its containment and safety functions.
Finding the chemistry
Look for “Lithium” or the chemical symbol “Li” on the battery label. If the label is missing or unclear, identify the make and model and confirm its specifications before classifying the shipment.
Dangerously damaged is a higher-risk category
This can include batteries liable to disassemble rapidly, react dangerously, produce flame or dangerous heat, or release toxic, corrosive or flammable gases in normal transport conditions. This category uses more stringent packaging and emergency controls.
Special Provision 376 calls for assessment against the manufacturer’s safety criteria or by a technical expert familiar with the battery’s safety features.
Common UN numbers and shipping names
Confirm the exact proper shipping name and description against the current ADG Code.
| UN number | Battery type |
|---|---|
| UN 3480 | Lithium-ion batteries, including lithium polymer batteries |
| UN 3481 | Lithium-ion batteries contained in or packed with equipment |
| UN 3090 | Lithium metal batteries, including lithium alloy batteries |
| UN 3091 | Lithium metal batteries contained in or packed with equipment |
| UN 3551 | Sodium-ion batteries with organic electrolyte |
| UN 3552 | Sodium-ion batteries contained in or packed with equipment, with organic electrolyte |
Power threshold test
Low power vs high power
For non-damaged batteries going for recycling or disposal, P909 uses power or lithium-content thresholds to determine whether certain simpler packaging options may be available.
Low power thresholds
- Lithium-ion cell: up to 20 Wh.
- Lithium-ion battery: up to 100 Wh.
- Lithium metal cell: up to 1 g lithium content.
- Lithium metal battery: up to 2 g aggregate lithium content.
P909 also includes sodium-ion cells and batteries in its 20 Wh / 100 Wh thresholds. “Low power” and “high power” are explanatory terms used in this guide, not formal ADG Code classifications.
How to estimate watt-hours
For a battery labelled in amp-hours, multiply amp-hours by voltage to estimate watt-hours. For example, 5 Ah × 18 V = 90 Wh. A battery’s rating, chemistry and condition must still be checked against the applicable Code requirements.
Anything above the relevant thresholds is treated as high power for this guide. “Low power” does not automatically mean every packaging exemption applies; the package weight, battery condition and other P909 conditions still matter.
Choose the packaging instruction
Three condition-based packaging pathways
Select the instruction based first on the battery’s condition. The correct packing method then depends on chemistry, size, power, equipment, packaging type and the detailed Code clauses.
P909
Undamaged batteries for recycling or disposal
P909 is the principal route for non-damaged lithium cells and batteries being sent for recycling or disposal.
- The general authorised-packaging route uses permitted drums, boxes or jerricans at packing group II performance level. Ask the supplier for the UN test report and confirm suitability for the battery shipment; a UN mark alone does not prove suitability.
- Metal packagings need an electrically non-conductive lining. Prevent short circuits and dangerous heat using suitable terminal protection, inner packaging, recessed terminals or non-combustible, non-conductive cushioning. Secure batteries against excessive movement.
- The Code lists limited situations where a strong outer packaging may be used instead: low-power batteries in packages up to 30 kg gross; cells or batteries of 12 kg or more with a strong, impact-resistant outer casing; and batteries contained in equipment.
- Equipment may be transported unpackaged or on a pallet only when the equipment itself provides equivalent protection. Check the exact conditions in P909 before using this exception.
- P909 can apply to batteries packed together with or without non-lithium batteries, but the protection and securing requirements still apply.
P908 / LP904
Damaged or defective batteries
P908 and LP904 apply when a battery is damaged or defective but does not meet the dangerously damaged or defective criteria.
- Examples include batteries identified as unsafe, leaking or venting, not able to be diagnosed before transport, or physically or mechanically damaged.
- Package each cell, battery or item of equipment individually in inner packaging, then place it in an authorised outer packaging. The inner or outer packaging must be leak-proof. P908 specifies packing group II performance; LP904 uses rigid large packaging at packing group I performance for a single battery or single item of equipment.
- Protect against short circuit, vibration, shock and movement. Surround each inner package with sufficient non-combustible, non-conductive thermal insulation. Sealed packagings may require a venting device.
- Under P908, a cell or battery with a net mass above 30 kg is limited to one cell or battery per outer packaging. Confirm whether P908 or LP904 applies to the item being moved.
- For leaking batteries, add enough inert absorbent material to contain any electrolyte release. The insulation and cushioning material’s non-combustibility must be assessed against a recognised standard.
P911 / LP906
Dangerously damaged or defective batteries
Use this route where a cell or battery could rapidly disassemble, react dangerously, produce flame or dangerous heat, or release toxic, corrosive or flammable gases under normal transport conditions.
- Special Provision 376 describes the assessment and documentation requirements. Do not treat a dangerously damaged battery as an ordinary damaged battery.
- The packaging must conform to packing group I performance and meet additional verified thermal and containment requirements. It must prevent flames and projectiles escaping, maintain structural integrity and manage gases appropriately.
- The outer surface must generally remain at or below 100 °C, with a momentary spike up to 200 °C allowed. The additional performance must be verified by testing specified by the competent authority, with a verification report available.
- Follow the package-specific instructions, including approved battery types, numbers, energy content, arrangement and protection. Protect cells and batteries against short circuit.
- Mark the package “DAMAGED/DEFECTIVE” in addition to the proper shipping name, and include “Transport in accordance with special provision 376” on the transport document.
- These cases need specialist assessment. Confirm the approved packaging design and emergency plan with a dangerous-goods professional before transport.
These downloadable instruction extracts are convenient references. Always check them against the complete current ADG Code and the conditions of the packaging approval.
Do not assume Special Provision 188 applies to waste batteries. Special Provision 188 provides an exemption only when all its conditions are met, including applicable inner-packaging, short-circuit protection, testing, marking and package-mass requirements. Those conditions can be difficult to establish for mixed waste-battery collections. Confirm the current Code interpretation with a competent dangerous-goods adviser before relying on an exemption or alternative battery mark. Review the lithium battery special provisions.
Shipment markings
Marks and dangerous-goods labels on packages
Each package must identify what is inside and communicate the relevant recycling, disposal or damage status. Use the proper shipping name for the actual battery type.
Package marks to check
- The UN number and proper shipping name for each battery type.
- The consignor’s name and address.
- “LITHIUM BATTERIES FOR DISPOSAL” or “LITHIUM BATTERIES FOR RECYCLING”, as appropriate.
- “DAMAGED/DEFECTIVE” in addition to the proper shipping name when Special Provision 376 applies.
- Marking text generally at least 12 mm high; 6 mm may be permitted for packages of 30 kg or less.
Class 9A vs Class 9
Class 9A is the lithium-battery hazard label used on packages; Class 9 is the placard used on cargo transport units. Special Provision 384 sets out where those different marks apply.
A package hazard label is normally at least 100 mm × 100 mm. If the package is too small, a proportionally reduced label may be permitted, provided its symbol and other elements remain clearly visible.
Check the applicable special provisionsVehicle and load
Placarding depends on the unit and the total load
These common thresholds are an overview—not a substitute for checking all of Chapter 5.3, mixed dangerous-goods loads or jurisdiction rules.
Placardable unit
A receptacle or package with capacity above 500 kg may be a placardable unit. An Emergency Information Panel (EIP) is generally displayed on two opposite sides; where a relevant side or diameter is under 1 m, one EIP may be sufficient.
Placardable load
A road vehicle carrying more than 1,000 kg/L aggregate quantity of dangerous goods may meet the placardable-load threshold. For the lithium-battery-only scenario described here, Class 9 placards are displayed at the front and rear of the vehicle and on each side of each trailer.
If the vehicle carries placardable units, EIPs may also be required on the vehicle—at the rear and on the sides of each trailer or rigid vehicle in the described single-class scenario. Mixed loads and different vehicle layouts can change the outcome, so check the ADG Code before dispatch.
Emergency Information Panels
An EIP identifies the dangerous goods and provides emergency information for the relevant UN number. Standard panels are 800 mm × 600 mm; a 400 mm × 300 mm panel may be permitted for a placardable unit with capacity below 3 m³. Check the prescribed layout, content and any permitted reduction in the Code rather than making a custom sign.
Before the vehicle leaves
Transport documents and emergency information
Paperwork and emergency information need to travel with the load, not sit in an office or be left to the driver to assemble.
Dangerous-goods transport document
The consignor provides the required transport document to the driver, and a hard copy must be carried in the vehicle. Include the consignor and consignee names and addresses, the consignor’s contact number, and a separate entry for each battery type.
- UN number, proper shipping name and Class 9.
- Package description and number of packages.
- The required gross aggregate quantity of dangerous goods.
- Packing group is generally not applicable because batteries are treated as articles under the Code.
- For Special Provision 376 shipments: “Transport in accordance with special provision 376”.
Emergency procedure information
Placard loads need emergency information for the dangerous goods and vehicle fire. Keep the required emergency procedure guide in the prescribed holder in the cabin or immediately adjacent, where the driver can access it.
Use the Australian and New Zealand Emergency Response Guidebook, an applicable Standards Australia guide or another form approved by the competent authority. If carrying individual Emergency Procedure Guides rather than the full Guidebook, also carry the Vehicle Fire guide. Refer to ADG Code Chapter 11.2.
- Australian and New Zealand Emergency Response Guidebook: safety precautions and notifications.
- Guide 147 for lithium-ion batteries.
- Guide 138 for lithium-metal batteries.
Need a packaging option?
Match the packaging to the battery and its condition.
See Uniseg’s lithium battery containment options or contact the team to discuss your handling requirements.
This page is a plain-language summary, not legal or dangerous-goods advice. The ADG Code, state or territory commencement dates, waste permits and specific shipment circumstances can change what applies. Confirm every shipment against the latest Code and the relevant competent authority. This summary is not a substitute for the detailed Code requirements or specialist advice.