This article originally appeared in the Fall 2021 issue of E-Scrap News. Subscribe today for access to all print content.


Shipping lithium batteries has become a complex and highly regulated endeavor. These batteries, which power everything from cell phones to laptops to cars and more, pose such a fire risk that stringent restrictions – from commercial aircraft bans to state-of-charge rules – have been imposed regarding both their initial and return shipping.

This extends to the transport, recycling and disposal of end-of-life batteries and the devices that contain them.

The issue of proper management of lithium-ion batteries is constantly evolving and is only becoming more critical for recycling stakeholders to thoroughly understand. This article will lay out the basics on shipping the items correctly.

Loads of challenges and complications

Lithium batteries fall into two different categories: those that ship fully regulated and those that do not.

Batteries that are not damaged, defective, or recalled and have a watt hour rating of less than 100Wh (for example, laptop batteries) can ship as a non-fully regulated shipment by ocean or ground. Batteries with a watt hour rating of less than 300Wh (power tools or drone batteries fall into this category) can ship non-fully regulated by ground, but only if the proper labeling requirements are met according to the U.S. Code for Federal Regulations (CFR), title 49, part 173.185.

Title 49 regulations under CFR (49 CFR) deal with transportation and are thus under the purview of the U.S. Department of Transportation.

Batteries with a watt hour rating greater than 300Wh (such as batteries used in e-bikes or cars) – or any damaged, defective or recalled battery regardless of watt hours – are considered “fully regulated class 9 shipments” and must ship as such. This means complying with all CFR regulations under title 49, which include proper packaging, training, labeling, documentation and specified shipping methods.

It can be confusing, given that anyone with any part in shipping dangerous goods from a commercial establishment is considered a “hazmat employee” employee under the regulations and must be 49 CFR-trained and certified on every aspect of shipping, including seemingly remedial tasks such as filling out the bill of lading or physically loading the freight. Attending an interactive online training course can quickly and efficiently accomplish this training requirement.

But proper training isn’t all there is to it. You must also comply with all packaging regulations. Below are some examples of the rules pertaining to shipping a damaged, defective or recalled lithium battery:

  • Each cell or battery must be placed in individual, non-metallic inner packaging that completely encloses the cell or battery.
  • The inner packaging must be surrounded by cushioning material that is non-combustible, electrically non-conductive, and absorbent.
  • Each inner packaging must be individually placed in outer packaging, which needs to be metal, plastic or wooden, depending on the specifics of the situation.

Keep in mind this is just a small sample of regulations. Other factors that determine how to ship include whether you are shipping a stand-alone battery or one contained in (or with) equipment, the battery state of charge, weight, and destination.

Besides the CFR rules, material shippers need to also follow U.S. EPA regulations, which may include environmental waste labeling (when shipping directly to a physical recycler) or, in some cases, hazardous material labeling and proper documentation.

Finally, there are the carriers to consider. Even if you are 100% in compliance – with training, paperwork, and packaging all perfect – it is still ultimately up to individual carriers to decide whether to take your shipment or class of dangerous goods. That’s why before moving forward with any shipments, it’s best to first check with your carrier of choice to ensure they will accept it.

A rundown of best practices

Although shipping batteries to a recycler, or to be recycled, is a complicated endeavor, there are steps you can take to simplify the process.

First, pay attention to training. For fully regulated shipping, in particular, training does matter. Invest in quality and effective training to keep you and your staff engaged. Interactive and 3D training tops this list. Online training isn’t new, but it can be especially useful in helping employees digest complicated compliance and shipping regulations in a more convenient and memorable manner.

When it comes to setting up the process used by your team, make sure there is a point where the battery itself is inspected and you are realistic about what is being shipped. If you have a small damaged lithium battery and do everything according to the rules and have a thermal event in transit, you’re still responsible. Shipping by just meeting the rules doesn’t guarantee that it’s 100% safe. Sometimes you must exceed requirements and be extra cautious to go above and beyond.

When shipping damaged or defective batteries it’s strongly encouraged to use special permit packaging. It’s simple to use, does not require 49 CFR training, and has a much more user-friendly packaging experience (for instance, you’re able to use corrugation).

At the same time, however, special permit packaging should be scrutinized. Whenever you get special permit packaging, you need to ask: What was tested? How many watt hours? What was the state of charge at time of testing? Can I see the video of the testing? Not all special permit packaging is created equal. You need to know how the packaging has been tested, because a 20W flashlight or a 50W laptop or 100W battery won’t react the same way.

You would also be wise to consider next-generation packaging. Some modern packaging solutions are engineered specifically for transporting lithium batteries and can provide a thermal barrier that mitigates the risk of fires by containing pressure, fire, gasses and projectiles, yet require no use of gel packs, heavy liners or fillers. This makes transporting lithium-related items safer, easier and more cost-effective. Additionally, there are packaging options that let you ship mixed loads of used lithium-ion, lithium metals, and non-spillable batteries by ground or vessel for recycling or disposal.

Finally, never use the same box a new battery or device came in when it comes to return shipping. Packaging for shipment of new batteries has none of the protections needed to address used or damaged batteries. Avoid this issue and do the right thing by using proper return packaging in the first place.

Looking ahead

The battery recycling market will only continue to grow, with one recent market research report projecting battery recycling to go from a $17.2 billion business in 2020 to $23.2 billion by 2025. The North American lithium-ion battery recycling market alone is expected to reach $139.6 million by 2027 (up from $35.9 million in 2019), with the consumer electronics segment to dominate that market.

Reasons for growth include concerns around supply of precious and rare earth metals, growing demand for recycled batteries and other materials, and stringent government regulations.

With this expected growth in battery recycling, it’s more important than ever to stay up to date on the latest industry shipping regulations. Regulations change, especially when it comes to shipping and handling lithium batteries, so don’t just assume that what was correct a year or two ago is correct today. For example, if you’re using the lithium battery handling mark from two years ago, you’re using the wrong label.

When it comes to fully understanding all the regulations, it’s best to partner with an industry expert who can navigate the changes and new rules for you, and help keep the supply chain safe and compliant.


Thaddeus Puccini is the global development manager for Labelmaster, where his focus is on the safe and compliant shipping and handling of dangerous goods the world over. He specializes in custom packaging designs for damaged, defective, and potentially recalled lithium batteries. He can be contacted at [email protected].

This article originally appeared in the Fall 2021 issue of E-Scrap News. Subscribe today for access to all print content.