"In recent years, lithium batteries have been widely used both in personal consumer products and in industrial production, vehicle manufacturing and other industries. China is the production and export of lithium battery products in large countries, lithium batteries belong to the dangerous goods, in the process of transport may occur fire and explosion and other accidents, its transport safety must be paid attention to.
Definition and classification
I. Lithium-ion battery
Definition: Lithium-ion batteries generally use lithium metal oxide or lithium alloy oxide as the anode material, graphite as the anode material, the use of non-aqueous electrolyte batteries.
Characteristics: rechargeable battery
Lithium metal batteries
Definition: Lithium metal batteries generally use manganese dioxide as the positive material, lithium metal or its alloy as the negative material, the use of non-aqueous electrolyte batteries.
Characteristics: disposable battery
In TDG's Dangerous Goods List, there are 6 UN numbers involving lithium batteries, all of which are classified as Class 9 dangerous goods.
Keywords you want to know
Regulatory conditions
At present, the HS code of lithium battery related products do not have inspection and supervision conditions, and do not need to implement import and export commodity inspection.
Use of identification
Although lithium batteries do not need to implement import and export commodity inspection, but lithium batteries are dangerous goods, according to "Import and Export Commodity Inspection Law of the People's Republic of China" Article 17, "Import and Export Commodity Inspection Law of the People's Republic of China Implementing Regulations," Article 29, the export of lithium batteries (UN No. 3090,3091,3480,3481) of the manufacturer, should apply for Customs Dangerous Goods Identification of the use of packaging containers, the use of unidentified or unqualified packaging containers of dangerous goods are not allowed to export.
Special Goods
For lithium battery electric vehicles (UN No. 3171), containerised lithium-ion battery systems (UN No. 3536), although there is no specific requirement for packaging specification in the international hazardous regulations, and there is no need to apply for the identification of the use of dangerous packages, they should be exported according to the actual mode of transport, to meet the corresponding safety transport requirements.
International Dangerous Goods Regulations
Relevant international hazardous regulations are IMDG, RID, ADR, IATA-DGR and UN Manual of Tests and Criteria for the Recommendations on the Transport of Dangerous Goods.
Declaration points
I. Key Points of Declaration for Identification of Packaging Use of Export Lithium Battery
Required materials
1 "Application for Packaging Inspection of Entry-Exit Goods".
2. "Entry and Exit Cargo Packaging Performance Inspection Result Sheet".
3. "Factory Inspection Pass Sheet
4. "Classification and Identification Report of Dangerous Characteristics of Exported Dangerous Goods" or "Identification Report on Conditions of Carriage of Goods".
Second, the export of lithium battery products customs declaration declaration points
▲ In "Cargo Properties", select 19 normal and 33 non-dangerous chemicals, "Dangerous Goods Information": non-dangerous goods, without ticking. Fill in the correct UN number, hazardous category, packing category and packing UN mark.
▲Export of dangerous goods in the accompanying documents to upload the "use of identification results sheet".
▲ Export lithium battery products do not need electronic bottom account number.
General Requirements
About Packaging
1. The general requirements for the use identification of dangerous packages shall be met.
2. To meet the requirements of the packaging guidelines of the corresponding mode of transport in the international hazardous regulations.
3. Lithium battery products are not applicable to limited packaging, nor applicable to exempted amount of packaging.
4. Lithium battery products are not applicable to medium-sized bulk packagings.
5. If it meets TDG special regulation 188, it can not apply for identification.
About labelling
1. The package must be affixed with the exclusive Dangerous Goods Label No. 9A for lithium batteries.
2. If the label is attached to the outside of the cargo transport unit, then the Dangerous Goods Label No. 9 shall be used.
3. Packages of lithium batteries or lithium battery packs complying with TDG Special Provision 188 shall use the "Lithium Battery Exclusive Marking".
4. Lithium-ion batteries shall be marked on the outside of the product with the rated capacity value in W?h unit.
Size requirements:
Minimum 100mm x 100mm, the minimum width of the inner line of the outer edge of the rhombus is 2mm, the inner edge of the line is a parallel line, the distance between the outer edge of the line and the edge of the rhombus is 5mm. in the absence of specific dimensions, all the elements should be roughly proportional to the scale of the illustration. If the size of the package requires it, the dimensions may be reduced accordingly, but the symbol and other elements of the label shall be clearly visible.
Label Elements:
Symbol (the upper part is seven black vertical stripes; the lower part is a group of batteries, one of which is damaged and on fire): black; background colour: white; the number "9": underlined, written in the bottom corner, black.
Application Scenario:
For lithium battery products complying with TDG Special Provision 188, apply the labels as shown above, and indicate the United Nations number starting with the letters "UN"; if the package contains lithium batteries or cells with different United Nations numbers, one or more labels shall indicate all applicable United Nations numbers.
Size requirements:
The marking shall be rectangular or square. The width of the shadow line at the edge shall not be less than 5mm. In the 21st revised edition of the UN TDG regulations, the minimum size has been revised from the original 120mm x 110mm to 100mm x 100mm; if the size of the package requires it, the size can be reduced accordingly, but it shall not be less than 100mm x 70mm.
Label elements:
? The symbol is black (a group of batteries, one of which is damaged and caught fire), and the edge shadow line is red.
? * here is the UN number; ** here is the telephone number.
? The requirement to display the telephone number on the label will be removed as of 1 January 2023 for air shipment methods.
Application Scenario:
Only packages containing lithium batteries or cells inside are transported individually by air freight on cargo aircraft.
Dimensional requirements:
120mm x 110mm
Positioning requirements:
On the same side as the Class 9 Dangerous Goods marking, cross-side and corner folding are prohibited.
About product safety
1. Unless the exemption conditions are met, the exported lithium batteries must pass the UN38.3 test and provide the test summary.
2. Each cell and battery pack should have a safety venting device, and it should have a design to prevent breakage by force in case of ordinary accidents.
3. Each cell and battery shall be equipped with an effective device to prevent external short circuit.
4. Each battery pack containing several cells or series of cells connected in parallel shall be fitted with effective devices (e.g. diodes, fuses, etc.) necessary to prevent reverse current from causing danger.
Typical cases
I. Export of lithium battery packs not declared as dangerous goods
In December 2021, a port customs in the implementation of a batch of export lithium battery pack inspection found that the batch of lithium battery pack in accordance with the declaration of non-dangerous goods and transport, on-site sampling for inspection, identified as dangerous goods, the parties as the export of dangerous goods production enterprises, did not apply to the customs of origin for identification of the use of packaging containers of dangerous goods, according to the "People's Republic of China Import and Export Commodity Inspection Law Enforcement Regulations". The first paragraph of Article 50 of the provisions of the parties to impose administrative penalties.
Second, the export of lithium-ion battery packs are not marked with the capacity of the unit W?h
In March 2021, a customs declaration of a batch of export lithium-ion battery packs (declared name for the energy storage system 230P) for the use of dangerous goods packaging identification found that the lithium-ion battery packs on the product is not W?h capacity marking, does not comply with the "International Maritime Dangerous Goods Code" in Chapter 3.3, Article 348 of the provisions of the Regulations, and ordered the enterprise to carry out technical rectification of the batch of goods.
Inadequate switch protection for exported battery packs
In January 2021, a customs in a batch of export battery packs for dangerous goods packaging use identification found that the battery packs in the transport process is easy to trigger the power switch so that the power supply in the power state, the goods in transit there are greater safety hazards, does not comply with the "International Maritime Dangerous Goods Code" in the packaging specification P903 "its packaging must be able to prevent the accidental start of the transport process". It does not meet the relevant requirements of the International Maritime Dangerous Goods Rules Packaging Specification P903 "The packaging must be in a manner that prevents accidental start-up during transport.
Non-compliance with the charge state of lithium battery cores exported by air.
In June 2021, a customs in a batch of air exports of dangerous goods packaging identification found that the goods for lithium-ion battery core, rated capacity of 37 W?h, according to the "Technical Rules for the Safe Transport of Dangerous Goods by Air," the goods should be 965 air transport packaging instructions, IA, is limited to the cargo aircraft transport. After on-site verification of the charge state of the goods, it shows that the charge state is more than 50%, which does not meet the requirement that the charge state of the product does not exceed 30% of the rated capacity when it is delivered for transport as stipulated in the "Technical Regulations for the Safe Transport of Dangerous Goods by Air".
Application Guideline for Dangerous Goods Certificate
Lithium battery is dangerous goods, according to the "Import and Export Commodity Inspection Law" Article 17, for the export of dangerous goods production of packaging containers for the enterprise, must apply for commodity inspection agencies to carry out the performance appraisal of packaging containers. Production of dangerous goods for export enterprises must apply for commodity inspection agencies to identify the use of packaging containers. Dangerous goods that use packaging containers that have not been qualified for appraisal are not allowed to be exported. Enterprises should fulfil their responsibilities in accordance with the law, the Customs and Excise Department will investigate and deal with the export of dangerous goods such as entrapped batteries and other illegal acts in accordance with the law.
Responsible Enterprises
Type of appraisal to be handled
Enterprises producing packaging containers for export of dangerous goods
Packaging performance test for export of dangerous goods
Enterprises producing dangerous goods for export
Identification of the use of packaging for export of dangerous goods
(Customs Xiao Er microblogging public number tab)
Take the application for identification of the use of packaging for export of dangerous goods as an example:
(a) Online application for inspection process
Holding an electronic port card media login China International Trade Single Window - "standard version of the application" - click on "goods declaration "-" Other inspection and quarantine declaration "-" outbound packaging ".
Information to fill in the instructions:
"Inspection category": fill in the "dangerous package use";
"Inspection authority": the name of the Customs where the enterprise;
Fill in the specific product inspection information, click on the "temporary storage", confirm that there is no error and click "declare", to be generated after the official inspection number, print the "entry-exit goods packaging inspection application form.
(B) Customs on-site process
Enterprises online inspection success, according to the following chart query method will be "entry-exit cargo packaging inspection application form" print out, and carry the following "for the material catalogue" in all the information to the local Customs to apply for "outbound transport of dangerous goods packaging use identification Result Sheet".
Handling materials catalogue
Material Name
Sample materials to fill in
Material Type
Source Channel
Number of copies
Material necessity
Packaging inspection of imported and exported goods application form
Download blank form
Original
Others
1 paper copy
Necessary
Packaging performance test results of imported and exported goods
Download blank form
Original
Issued by government department
1 paper copy
Necessary
Manufacturer's factory inspection record or product compliance statement
No
Original copy
Prepared by the applicant
1 paper copy
Necessary
Classification and identification report of hazardous characteristics of exported dangerous goods
No
Original copy
Others
1 paper copy
Necessary
Sales contract for export of dangerous goods
No
Photocopy
Prepared by the applicant
1 paper copy
Necessary
There are many policies, regulations and technical requirements for the packaging of goods involved in export, so enterprises can consult the relevant departments of the Customs and Excise Department in advance to understand the regulations, standards, declaration procedures and packaging requirements. Customs will guide enterprises to handle dangerous goods export business, improve customs clearance efficiency, and help more high-quality new energy products made in China to be exported.
