Changes to the Lithium Battery Mark for 2024
The introduction of the telephone number requirement for lithium battery labels initially left many shippers and carriers puzzled. There was uncertainty regarding its similarity to the 24-hour telephone number requirement in many countries, however, neither the UN nor national regulations explicitly stated that this number needed to be available around the clock. Furthermore, third-party providers of emergency numbers expressed concerns about receiving excessive non-emergency calls related to lithium batteries.
Questions arose about the accessibility of the number from outside the shipper’s home country for international shipments but the regulations remained silent on this matter.
The most pressing issue was determining what type of information should be provided on this number. While immediate emergency response information seemed logical, considering the main danger of lithium batteries is fire, it would be challenging to access fire-related emergency information if the package causing the problem were already on fire.
Ultimately, it became apparent that the telephone number requirement lacked clarity and practicality. It didn’t necessarily have to be a 24-hour number or provide comprehensive emergency information. It could simply be a regular business number operating during business hours, offering non-emergency information such as battery testing reports or specification sheets.
Recognising the confusion surrounding this requirement, the UN and national regulators decided to remove it in the 22nd edition of the UN Recommendations and so the lithium battery mark will no longer be required to display a ‘telephone number for additional information’.
The double asterisk has been removed from the IATA, ADR, and IMDG regulations and the note in relation to the telephone number has also been deleted.
A long transitional measure has been given to allow marks displaying the telephone number to continue to be used until 31st December 2026, after which, it must be removed.
So, to clarify, the telephone number is optional for now, but must be removed as of 1st January, 2027.
What does the lithium battery label look like and when is it required?
The lithium battery mark is required as specified in the additional requirements of Section II of Packing Instructions 966, 967, 969 and 970. It is also required as specified in the additional requirements of Section IB of Packing Instructions 965 and 968, in addition to the Class 9 lithium battery hazard label and Cargo Aircraft Only label.
The border of the mark must have red diagonal hatchings with a minimum width of 5mm. The symbol (group of batteries, one damaged and emitting flame, above the UN number for lithium ion or lithium metal batteries or cells) must be black on white, or suitable contrasting background.
The lithium battery mark may be printed directly on the outer packaging provided that there is sufficient contrast between the elements of the lithium battery mark and the colour of the packaging material.
The mark must be in the form of a rectangle, or a square, with minimum dimensions of 100 mm x 100 mm. The wording in the provisions for the application of the mark identifies that mark must be a square, or rectangle, – which permits the continued usage of the older mark at the 120mm x 110mm size.
Labelling Small Parcels
Where the packages dimensions are such that they cannot bear the full-size lithium battery mark, the mark dimensions may be reduced to 100 mm wide × 70 mm high. The design specifications must otherwise remain the same.
Where any face of a package is large enough to bear the full-size lithium battery mark, the full-size mark must be used.
When is a lithium battery label NOT required on the package?
A lithium battery mark must not be affixed to packages prepared in accordance with Section IA of Packing Instructions 965 and 968 and Section I of Packing Instructions 966, 967, 969 and 970.
A lithium battery mark is not required for packages prepared in accordance with Section II of PI 967 or PI 970 containing only button cell batteries installed in equipment (including circuit boards) or consignments of two packages or less where each package contains no more than four cells, or two batteries installed in equipment.
Class 9 Lithium Battery Hazard Label
The Class 9 lithium battery hazard label, specifically for lithium batteries, must also show the battery image and can only be used for packages containing lithium batteries.
For further information visit the IATA website and see the 2023 Lithium Battery Guidance Document.
This article should not be used in substitute for checking the exact requirements in the applicable modal regulations.