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Product compliance

Products with batteries from China: air freight rules, test papers and EU and UK duties

Quick answer

Lithium batteries are dangerous goods in air freight. Each battery needs a UN 38.3 test summary from its manufacturer. Loose batteries ship at no more than 30% charge, and damaged or recalled ones cannot fly. Separately, the EU and UK put duties on the importer, including labels and registration.

A power bank, a smartwatch, an e-bike light, a Bluetooth speaker. Lots of products from China carry a lithium battery, and a battery changes how the goods ship, what papers you need and what the law asks of you as importer.

This guide has two parts. The first covers transport, based on the 2026 IATA lithium battery guidance for air freight. The second covers what the EU and UK add for the importer. It does not replace advice from your forwarder, who has to accept the shipment.

How batteries are classified

IATA classifies lithium and sodium ion batteries as Class 9, miscellaneous dangerous goods. The common UN numbers are:

UN number What it is
UN 3480 Lithium ion batteries, shipped on their own
UN 3481 Lithium ion batteries packed with equipment or contained in equipment
UN 3090 Lithium metal batteries
UN 3551 / 3552 Sodium ion batteries

The packing instruction depends on the type. IATA lists PI 965 for loose lithium-ion batteries, PI 966 for batteries packed with equipment and PI 967 for batteries contained in equipment. Each has a Section I and a smaller-battery Section II.

Your forwarder or the supplier’s shipping team classifies the goods. You ask the right questions.

The papers to ask for

Before production, ask the supplier for:

  • The battery’s watt-hour (Wh) rating. Limits depend on it.
  • The UN 38.3 test summary. IATA says that manufacturers and later distributors of cells, batteries and equipment powered by them must make the test summary available. It applies to batteries shipped alone or inside equipment, except equipment that contains only button cells. It does not need to travel on paper with every consignment: IATA says the summary can sit on a website, with a QR code or URL on the battery, its packaging or the transport document.
  • Photos of the battery marking. Check the model and Wh rating on the label against the test summary.

If the supplier cannot produce a UN 38.3 test summary, stop. Without it, an airline or forwarder can refuse the goods.

What air freight allows

Points from the 2026 IATA guidance:

  • Charge level for loose batteries. Lithium-ion batteries shipped by themselves under PI 965 must be at no more than 30% of rated capacity. A higher charge needs approval from the State of Origin and the State of the Operator. Loose lithium-ion batteries cannot go on a passenger aircraft unless the authorities approve it.
  • Charge level for batteries with equipment. Under Section II, lithium-ion cells and batteries over 2.7 Wh must be offered at no more than 30% of rated capacity.
  • No damaged or recalled batteries. Batteries that the manufacturer has identified as defective for safety reasons, or that are damaged in a way that could cause heat, fire or a short circuit, are forbidden by air. This includes batteries inside equipment that is subject to a safety recall.
  • Training. IATA says that shippers of Section IB batteries need dangerous goods training. For Section II, the shipper needs “adequate instruction”. Your forwarder tells you which applies.
  • Chargers. A package with only a charger or cables and lithium-ion batteries counts as UN 3480 and follows PI 965.

Sea freight has its own dangerous goods rules, which this guide does not cover. Ask your forwarder before you pick a route. Our guides to shipping from China to the UK and to the EU cover routes and costs.

What the EU adds for the importer

Regulation (EU) 2023/1542 sets rules for batteries and waste batteries placed on the EU market. It puts duties on the economic operators who place batteries on the market, and that includes importers. Two points to know now:

  • Labels and QR code. The regulation requires batteries to carry a label. It also says: “From 18 February 2027, all batteries shall be marked with a QR code” as set out in Part C of Annex VI.
  • Other duties. The regulation covers producer responsibility, documentation, conformity and, for some batteries, due diligence and a battery passport. Some dates were moved by later amendments.

Read the regulation’s timetable or ask a compliance adviser which duties apply to your product and when. Products that contain a battery may also fall under other EU rules, such as the rules we cover in our GPSR guide.

What the UK adds for the importer

The Waste Batteries and Accumulators Regulations 2009 set producer responsibility for batteries in the UK. A business that places batteries on the UK market for the first time can count as a producer, and that includes batteries inside products it imports. Producers must register and meet collection and recycling duties. Ask the Environment Agency or a compliance scheme whether you are in scope and which threshold applies.

Before you order

Settle these with the supplier first
  1. Get the battery details

    Ask for the battery type, capacity in Wh and the manufacturer. Check these match the product listing and the label.

  2. Get the UN 38.3 test summary

    Check it names the same battery model. Keep a copy or the link in your files.

  3. Tell your forwarder early

    Share the details at the quote stage. Ask whether air, sea or rail suits your product and quantity.

  4. Check the label proof

    The battery marking, your importer details and any warnings should match your notes before printing.

  5. Inspect the finished goods

    Add the battery label, the model and the packaging marks to the inspection checklist.

  6. Ask a compliance adviser

    Confirm which EU or UK battery duties apply to you and what to register before the first sale.

How CFS helps

We arrange shipping from Shenzhen through our group business, ParcelFromChina. We tell you at the quote stage if a product’s battery limits the shipping routes. We also check labels and batteries at inspection. See our shipping and consolidation and quality control services. A compliance adviser in your market confirms the legal duties.

Bottom line

Batteries are the first thing a forwarder asks about. Collect the Wh rating and the UN 38.3 test summary before you order, tell your forwarder early and plan for the EU and UK importer duties.

Checked against the IATA 2026 guidance, EUR-Lex and legislation.gov.uk on 13 November 2026. This guide is general information, not legal or dangerous goods advice. Your forwarder and compliance adviser confirm the rules for your shipment.

Questions we get asked

Can I ship lithium batteries from China by air?

Yes, in most cases, but they are dangerous goods (Class 9). Loose lithium-ion batteries ship as UN 3480, and batteries packed with or inside equipment as UN 3481. The shipper must follow the IATA packing instruction for that type, and some uses need dangerous goods training.

What is a UN 38.3 test summary?

A summary of the safety tests a lithium cell or battery passed under the UN Manual of Tests and Criteria. IATA says manufacturers and later distributors must make it available. It can sit on a website with a QR code or link on the battery, packaging or transport document, so a paper copy is not needed for every shipment.

What charge level can batteries be shipped at?

IATA says loose lithium-ion batteries shipped under Packing Instruction 965 must not exceed 30% of rated capacity. Batteries over 2.7 Wh packed with or contained in equipment under Section II must also be offered at 30% or less. Higher charge needs approval from the authorities.

Can I ship damaged or recalled batteries by air?

No. IATA says lithium or sodium ion batteries that the manufacturer identifies as defective for safety reasons, or that are damaged in a way that could cause heat, fire or a short circuit, are forbidden for transport by air. The same applies to such batteries installed in equipment.

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