Transporting Lithium Batteries
Lithium cells and batteries power countless items that support everyday life from portable computers, cordless tools, mobile telephones, watches, to wheelchairs and motor vehicles. Our society has come to depend on lithium cells and batteries for an increasingly mobile lifestyle. Today's lithium cells and batteries are more energy dense than ever, bringing a steadily growing number of higher-powered devices to market. With the increased energy density comes greater risk and the need to manage it. Shippers play an important role in reducing this risk and preventing incidents—including fires aboard aircraft or other transport vehicles.
Lithium batteries are regulated as a hazardous material under the U.S. Department of Transportation's (DOT) Hazardous Materials Regulations (HMR; 49 C.F.R., Parts 171-180). The HMR apply to any material DOT determines can pose an unreasonable risk to health, safety, and property when transported in commerce. Lithium batteries must conform to all applicable HMR requirements when offered for transportation or transported by air, highway, rail, or water.
Why are Lithium Batteries Regulated in Transportation?
The risks posed by lithium cells and batteries are generally a function of type, size, and chemistry. Lithium cells and batteries can present both chemical (e.g., corrosive or flammable electrolytes) and electrical hazards. Unlike standard alkaline batteries, most lithium batteries manufactured today contain a flammable electrolyte and have an incredibly high energy density. They can overheat and ignite under certain conditions, such as a short circuit, physical damage, improper design, or assembly. Once ignited, lithium cell and battery fires can be difficult to extinguish. Additional, although infrequent, events can result in lithium cells and batteries experiencing thermal runaway, a chain reaction leading to a violent release of stored energy and flammable gas. This thermal runaway can propagate to other batteries or combustible materials nearby, potentially resulting in large scale thermal events with severe consequences.
Lithium batteries pose a fire hazard, even when they are no longer useful in consumer equipment/products. Damaged, defective, or recalled batteries have greater potential than undamaged lithium batteries to short circuit, to release heat, or even to cause a fire. Anyone who offers a used lithium battery for disposal or recycling must, in addition to ensuring the terminals are protected to prevent short circuiting, fully assess the potential for fire hazards in shipping.
The Safety Advisory Notice discusses the essential requirements for preparing packages of used batteries for disposal or recycling and highlights additional resources for further information.
The Safety Advisory Notice can be viewed in its entirety at: https://www.phmsa.dot.gov/training/hazmat/safety-advisory-notice-transportation-lithium-batteries-disposal-or-recycling.
Additional DOT Resources for Recyclers/Collection Operators/Transporters:
The Occupational Safety and Health Administration (OSHA) maintains a website dedicated to battery disposal resources: https://www.osha.gov/green-jobs/recycling/batteries
Environmental Protection Agency (EPA) regulations apply to end-of-life lithium ion batteries under the Resource Conservation and Recovery Act (RCRA). In May 2023, EPA issued a memo to clarify how the hazardous waste regulations for universal waste and recycling apply to lithium ion batteries: https://rcrapublic.epa.gov/rcraonline/details.xhtml?rcra=14957. In addition, EPA maintains a website dedicated to battery disposal resources: https://www.epa.gov/recycle/used-lithium-ion-batteries, as well as a list of frequently asked questions for household batteries: https://www.epa.gov/recycle/used-household-batteries.
Private Individuals and Households
Private individuals should dispose of household lithium batteries via appropriate recycling channels and should never place lithium batteries in the trash or general recycling due to safety concerns. Electronics recyclers or scrap/collection centers in your area can be found online. Certain grocery, home improvement, big box retail, and consumer electronics stores offer lithium battery recycling services. In addition, your local solid waste district may offer a lithium battery collection program or host regular collection events. The manufacturer of your electronic may also offer a mail-in program. Should you utilize a mail-in program, you must comply with all USPS (for USPS mail shipments) or DOT (for shipments with other carriers) requirements. The organizer of your mail-in program should provide you with the guidelines to ship in compliance with USPS and/or DOT requirements.
You can refer to the EPA's webpage dedicated to household batteries for more information and for tips on locating appropriate recycling channels in your area: https://www.epa.gov/recycle/used-household-batteries
Whether shipping a single battery, a palletized load of batteries, or a battery-powered device, the safety of the package, and those who handle it along its journey, depends on compliance with the HMR. Failure to comply with the applicable regulations may result in fines or even criminal prosecution. Refer to 49 CFR 173.185 and the resources below for detailed requirements related to shipments of lithium batteries, including those contained in electronic devices.
For shipments made via the United States Postal Service (USPS), refer to the USPS website for information on postal service shipping restrictions and access to Publication 52 and International Mail Manuals (IMM). Publication 52 describes the types and quantities of hazmat that can be sent using USPS. In addition, you can view the resource below for helpful information.
Lithium cells and batteries offered for transportation must have passed the design tests found in the United Nations (UN) Manual of Tests and Criteria, Section 38.3. Effective January 21, 2022, lithium cell and battery manufacturers must make test summary documents available upon request. The test summary includes a standardized set of elements that provide traceability and accountability to ensure that lithium cell and battery designs offered for transport meet UN 38.3 test requirements.
Check with the battery manufacturer, distributor, or product vendor to determine if a battery design has passed these tests or obtain the test summary document.
For additional information, view the resource below.
The Federal Aviation Administration (FAA) maintains a website devoted to lithium battery safety, with a focus on transportation by air: https://www.faa.gov/hazmat/resources/lithium_batteries
Under their SafeCargo initiative, the FAA provides a series of guides to properly shipping hazardous materials by air, including a chart for shipping lithium ion and lithium metal batteries.
For more information on lithium battery incidents by air, visit the FAA's interactive chart.
If you're taking a flight, you can bring your laptop computer, cell phone, camera, tablet, or other lithium battery-powered devices! These personal electronics pose lower risk if certain conditions and limitations are followed, such as preventing inadvertent activation. Spare batteries, including baggage equipped with lithium batteries, can be packed in carry-on baggage if steps are taken to protect against short circuits.
For information on the conditions and limitations for bringing lithium batteries or any other hazardous material on your next flight, refer to the FAA's PackSafe for Passengers website before you fly.
In addition, the Transportation Security Administration (TSA) publishes information on additional items that they restrict on flights. Refer to TSA resources below.
Lithium batteries may pose a risk to public safety, even when not in transportation. To learn more about safe use, maintenance, and disposal of lithium batteries, visit the following resources from federal and local agencies.
The US Consumer Product Safety Commission (CPSC) maintains a Batteries resource page which offers recommendations for safe battery use, and lists relevant standards, CPSC Safety Alerts, and CPSC reports. In addition, recalled lithium batteries pose a greater hazard. Visit CPSC's Recalls portal to determine if your battery has been recalled.
The New York City Fire Department's FDNYSmart program's Safety Tips for Devices with Lithium-Ion Batteries page provides educational resources and safety tips related to lithium batteries, with resources in nine languages.
Micro-mobility devices powered by lithium batteries, including e-bikes and scooters, pose a hazard due to the size of their batteries and conditions of use. The US Fire Administration (USFA) has provided Guidance on Responding to Lithium-Ion Battery Fires in Mobility Devices, with links to a variety of resources. Likewise, CPSC maintains an informational page on Micromobility: E-Bikes, E-Scooters and Hoverboards, with educational resources related to these devices.
Lithium batteries contain materials recoverable through recycling. Refer to the EPA's Used Household Batteries page for information recycling used lithium batteries, including links to locate a recycling center near you.
Have a question about transporting lithium batteries? Need clarification on the Hazardous Materials Regulations? PHMSA's Hazmat Information Center provides live, one-on-one assistance Monday through Friday from 9 a.m. - 5 p.m.