End-of-life and damaged battery shipping: Navigating state and federal regulations

Navigating the world of battery transportation can feel like trying to solve a puzzle with pieces that just don’t seem to fit.

We have energy transition under way, when many technologies and markets are switching to electric power – EVs, forklifts, construction equipment, residential storage, etc. All these various applications require a multitude of batteries in various chemistries and sizes.

Regulators are playing catch-up with the technologies and markets that are developing at high speed.

Understanding battery transportation regulatory framework

A truck transporting end-of-life lithium-ion batteries on I-15 in California overturned in September 2024, and the container caught fire. The road was closed for two days while the fire burn itself out. Following this incident U.S. Rep. Dina Titus is advocating for stricter regulations on the transportation of lithium-ion batteries: maximum charge of 30% and testing for impact power comparable to traffic incidents.

When it comes to shipping batteries, the Dept. of Transportation (DOT) lays down the law. Its regulations are designed to keep everyone safe and cover everything from how batteries are packaged to the labels that must be displayed. DOT recently published the report “Lithium Battery Guide for Shippers” to help shippers safely package lithium cells and batteries for transport by all modes, in accordance with the latest international harmonization regulatory requirements. Shipping internationally can be a different story, with crucial rules set by the International Civil Aviation Organization (ICAO) and the International Maritime Dangerous Goods Code (IMDG Code).

The U.S. hazardous materials regulations and international regulations can be complex, so it’s important to work with professionals knowledgeable in regulatory best practices. For example, even if batteries are classified correctly and have the required labels, the shipper must still be trained and certified for hazmat transportation. The complexity and high risks involved makes transportation companies with a hazmat focus important partners in ensuring battery shipments are safe and compliant.

Applying shipping conditions and requirements

When shipping lithium batteries, it’s important to understand why a regulation is written. There’s a significant difference between new batteries, end-of-life batteries and those determined to be damaged or defective. New batteries usually have fewer restrictions, while end-of-life batteries and damaged batteries require more stringent handling due to their potential hazards. Batteries headed for recycling may have different sets of requirements (limited state of charge, marking and labelling, packaging, etc.) compared to those batteries headed for their second-life applications, or for repair or refurbishing for their original application.

Defective batteries will need extra handling precautions. They can leak harmful electrolyte or catch fire following a thermal runaway event. It’s vital to have a clear understanding of how to package and label them to minimize risks and potential enforcement actions by regulatory agencies.

Packaging and labeling guidelines

Examples of battery labeling.

Proper packaging is not just a formality; it’s a necessity. Most battery shipments must meet specific UN-approved packaging requirements to ensure they survive the journey intact, without posing a health and safety risk. Packaging guidance specific to the weight, power output, condition and chemistry of the batteries is essential, especially for larger or heavier batteries.

Labeling is equally important. Every package must display the correct hazardous materials labels, along with the appropriate UN markings. This isn’t just about compliance; it’s about communicating the risks to people handling the shipment, including emergency responders. Accurate shipping papers are crucial too, detailing the contents, handling instructions and emergency contact information. This ensures that if something goes awry, everyone knows how to respond.

Conclusion

Understanding the regulations governing battery transportation is essential for the safety of your team, the public, your customers and the environment. By being informed and compliant, you can avoid costly fines, litigation, costly insurance rate increases.

The full set of shipping capabilities and legal expertise of your battery logistics partner needs to include the practical knowledge and expertise of applying the changing regulations in the rapidly developing battery manufacturing and logistics space.

Bluewater Battery Logistics is a battery lifecycle management company based out of Los Angeles, California, that works with partners and customers globally.