The current regulatory basis for international road transport is ADR 2025. It became applicable on 1 January 2025, while ADR 2023 could continue to be used during the transitional period ending on 30 June 2025. Within the European Union, ADR is implemented through Directive 2008/68/EC, updated for ADR 2025 by Commission Delegated Directive (EU) 2025/149.
Classification Comes Before Booking a Vehicle
The first task is not finding a truck. It is determining exactly what is being transported.
UN 3480 applies to lithium-ion batteries transported on their own, such as a pallet of replacement batteries for power tools, bicycles or industrial equipment. UN 3481 applies when lithium-ion batteries are contained in equipment or packed with equipment. A battery installed inside a medical device is contained in equipment, while a spare battery placed in the same package as the device is packed with equipment.
UN 3090 and UN 3091 cover the corresponding arrangements for lithium-metal batteries. UN 3536 applies to lithium batteries installed in a cargo transport unit, including certain containerised energy-storage systems. ADR 2025 also introduced separate vehicle entries: UN 3556 for vehicles powered by lithium-ion batteries, UN 3557 for vehicles powered by lithium-metal batteries and UN 3558 for vehicles powered by sodium-ion batteries. A complete electric vehicle, a machine with an installed battery and a standalone battery module therefore cannot automatically be classified in the same way.
Six Questions to Answer Before Requesting a Price
A useful transport enquiry should provide the following information:
- What is the battery chemistry: lithium-ion, lithium-metal, sodium-ion or another type?
- Is the battery transported alone, contained in equipment or packed with equipment?
- What is the watt-hour rating of every lithium-ion cell and battery, or the lithium content of every lithium-metal cell and battery?
- Is the battery new, used, a prototype, waste, or intended for recycling?
- Is there swelling, leakage, deformation, overheating, impact damage or another suspected defect?
- Is a valid UN 38.3 test summary available for the exact cell or battery type?
Descriptions such as electronics, machine parts or batteries included are not sufficient for an ADR assessment. The carrier must be able to identify the substance entry, condition, quantity, packaging method and applicable exemption before confirming acceptance.
UN 38.3: The Document That Is Often Missing
Before transport, lithium cells and batteries must normally belong to a type that has passed the tests in subsection 38.3 of the UN Manual of Tests and Criteria. The test programme covers simulated altitude, thermal cycling, vibration, mechanical shock, external short circuit, impact or crush, overcharge and forced discharge, depending on the type of cell or battery.
A buyer should request the test summary for the exact manufacturer and model, not merely a generic certificate stating that the product is compliant. The summary should identify the cell or battery manufacturer, the product, the test laboratory, the relevant test report and confirmation that the required tests were passed. Manufacturers and subsequent distributors must make the applicable test summary available.
This document is particularly important when batteries are bought from an unfamiliar manufacturer, imported under a private label or incorporated into equipment by a third party. A test report for a similar battery does not automatically cover a different model, chemistry, construction or energy rating.
SP 188, the 1000-Point Exemption and Full ADR
Three regulatory situations are commonly encountered in European road transport. They must not be confused.
Under Special Provision 188, lithium-ion cells may have a maximum rating of 20 Wh and lithium-ion batteries a maximum rating of 100 Wh. For lithium-metal products, the limits are 1 gram of lithium per cell and 2 grams per battery. Meeting the energy threshold alone is not enough. The batteries must also meet the applicable UN 38.3 requirements, be protected against short circuit, be secured against movement and be packed in compliant inner and outer packaging. Packages of standalone cells or batteries are generally limited to 30 kg gross mass.
SP 188 is a special exemption, not the Limited Quantities regime. For the principal lithium battery entries, the ADR Limited Quantities value is zero. A package cannot therefore be declared as Limited Quantities simply because each battery is below 100 Wh.
Batteries that do not qualify for SP 188 may still be transported under the small-load exemption in ADR 1.1.3.6. Standard lithium batteries are normally assigned to transport category 2, with a maximum of 333 kg per transport unit. For calculation purposes, the net mass of the batteries is multiplied by three. A load of 250 kg therefore represents 750 points.
The 1000-point exemption does not mean that the load is no longer dangerous goods. Classification, compliant packaging, marks, labels, Chapter 1.3 training, load securing and the required transport information remain relevant. The vehicle must normally carry at least one fire extinguisher with a minimum capacity of 2 kg. Orange plates, full ADR vehicle equipment and an ADR driver training certificate are generally not required when all conditions of the exemption are met.
Above the applicable threshold, full ADR requirements apply. These normally include an ADR-qualified driver, orange plates, instructions in writing, the required emergency equipment, a complete dangerous-goods transport document and a vehicle accepted for the specific load and route.
Which Packing Instruction Applies
P903 is the principal packing instruction for standard, tested and undamaged lithium cells and batteries.
P908 applies to damaged or defective batteries that can be transported without an expectation of rapid disassembly, dangerous reaction, flame production, dangerous heat generation or dangerous gas release under normal transport conditions.
P909 is intended for cells and batteries transported for disposal or recycling. Its use does not remove the need to determine whether a battery is damaged or presents a more serious hazard.
P910 covers production runs and prototypes that have not completed the normal UN 38.3 testing process, subject to its detailed conditions.
P911 applies to critically damaged or defective batteries presenting a more severe reaction risk. Large industrial and electric-vehicle batteries may require corresponding large-packaging instructions LP903, LP904, LP905 or LP906.
A box carrying a UN packaging mark is not automatically suitable for every lithium battery. The complete packaging configuration must satisfy the applicable instruction, battery mass, dimensions, energy content and physical condition. This may include tested cushioning, thermal protection, non-combustible insulation, gas management and measures to contain dangerous effects.
How to Pack a Sound Lithium Battery
A practical packing process should include:
- Inspect every battery for impact damage, cracks, swelling, leakage, corrosion and unusual heat.
- Protect exposed terminals with terminal caps, insulating tape or individual non-conductive inner packaging.
- Separate batteries from one another with non-conductive material.
- Secure each battery so that it cannot move, overturn, become crushed or contact conductive objects.
- Prevent equipment from switching on accidentally during handling and transport.
- Use strong outer packaging appropriate to the battery’s mass, shape and transport conditions.
- Secure packages to the pallet without applying pressure to battery housings or allowing metal straps to contact terminals.
The completed pallet must remain stable during braking, cornering, terminal handling and repeated forklift movements. Stretch film alone is not a substitute for internal securing, and a pallet that appears stable externally may still allow individual batteries to move inside their boxes.
Damaged, Defective or Critically Dangerous
A torn retail carton does not necessarily mean that the battery itself is damaged. The product may remain technically sound if inspection confirms that the casing, terminals, cells and safety systems are unaffected.
A damaged or defective battery may be eligible for transport under Special Provision 376 and P908 when it is not liable to react dangerously during the journey. A critically defective battery presenting a risk of rapid failure, dangerous heat, flames or gas requires the more demanding P911 or LP906 regime.
Warning signs include swelling, puncture, leakage, smoke, unusual smell, increasing temperature, fire exposure, severe crushing, water immersion or impact during an accident. A battery showing these signs should not be placed into a normal groupage network before specialist assessment.
Placing a damaged electric-vehicle module in an ordinary box with absorbent material does not make it compliant. P911 and LP906 packaging must control the dangerous effects of a potential reaction and may be tested or approved for defined battery types, energy levels and surrounding conditions.
Battery Mark, Class 9A Label and Transport Documents
Packages transported under SP 188 normally carry the lithium battery mark showing the applicable UN number. Its standard minimum dimensions are 100 × 100 mm. Where the package is too small, the dimensions may be reduced to 100 × 70 mm. Obsolete label templates should not be copied without checking that they reflect the current mark format and correct UN number.
Fully regulated packages normally require the UN number, the appropriate proper shipping name and the Class 9A lithium battery label. When an overpack hides package marks or labels, they must be reproduced on the outside, together with the word OVERPACK where required.
A transport document entry for standalone lithium-ion batteries may be written as:
UN 3480 LITHIUM ION BATTERIES, 9, (E)
For batteries installed in equipment, the entry may be:
UN 3481 LITHIUM ION BATTERIES CONTAINED IN EQUIPMENT, 9, (E)
The document must also contain the required package information and quantity. A shipment moving under ADR 1.1.3.6 should contain sufficient information to demonstrate the applicable quantity and exemption calculation.
The UN 38.3 test summary does not normally travel as the transport document, but it must be available when requested. Full ADR transport also requires instructions in writing in the vehicle. Special P911 or LP906 solutions may require evidence of testing or approval.
Waste batteries may additionally fall under European waste-shipment rules. Depending on their classification and destination, cross-border movement can require prior notification, consent, waste documentation and electronic submission through the EU’s digital waste-shipment system. Most provisions of Regulation (EU) 2024/1157 became applicable on 21 May 2026.
Who Is Responsible and When a DGSA Is Needed
The logistics provider does not automatically inherit every legal duty. The consignor is responsible for providing correct classification and shipment information. The packer is responsible for packaging, marking and labelling. The loader must check that the cargo can be accepted and loaded safely. The carrier is responsible for the vehicle, crew, required documents and operational compliance. The consignee also has defined obligations when receiving and completing the transport operation.
Businesses that regularly consign, pack, load, transport or unload dangerous goods should determine whether they must appoint a Dangerous Goods Safety Adviser. The adviser helps monitor compliance, prepares the required reports, investigates incidents and supports safe operating procedures. Some limited exemptions exist, but they should be assessed against the company’s actual activities rather than assumed from shipment size alone.
European road-check rules have also been updated to connect infringements more clearly with the responsible participants in the transport chain. Incorrect information supplied by the shipper cannot always be treated merely as a carrier problem.