Sourcing a LiFePO4 pack is the straightforward half of importing. The half that stops shipments is documentation. Batteries are regulated as dangerous goods, they carry market-access requirements that differ by destination, and the paperwork is tied to the exact cell and construction you bought — which means it has to be planned before the order, not after.
What follows is the working checklist, with the caveat that applies to all trade compliance: rules change and national implementations differ, so confirm the specifics with your freight forwarder or customs broker for your destination.
The document set that must exist before the goods move
- UN38.3 test summary and test reports. Section 38.3 of the UN Manual of Tests and Criteria sets out the eight transport tests every lithium cell and battery must pass. Carriers and customs ask for the summary; the full reports should exist behind it.
- Safety data sheet (MSDS/SDS). A standardised document, not a marketing one, in the language the destination requires.
- Dangerous goods transport declaration. Completed by the shipper, with the correct UN number, packing instruction and class.
- Commercial invoice and packing list, with the model and quantity matching the test documentation exactly.
- Bill of lading or air waybill, and a certificate of origin if you intend to claim preferential duty under a trade agreement.
Which UN number applies
Getting this wrong invalidates the transport declaration, and it is a common error when packs ship inside equipment.
- UN3480 — lithium-ion batteries shipped on their own. This is the case for a bare swap pack or a rack battery.
- UN3481 — lithium-ion batteries contained in equipment, or packed with equipment.
- UN3171 — battery-powered vehicles.
All three travel as Class 9 dangerous goods. For air freight, standalone lithium-ion batteries (UN3480) are subject to a state-of-charge limit — they must be shipped at or below 30% state of charge. If your supplier fills packs before shipping, that is a problem to fix at the factory, not at the airport.
HS classification
Lithium-ion accumulators fall under heading 8507.60 in the harmonised system. The six digits are internationally agreed; most countries extend the code to eight or ten digits for tariff purposes, and the duty rate — and any anti-dumping or licensing treatment — attaches to that national line, not to the six-digit heading.
Two complications are worth knowing in advance. First, a battery shipped inside or with a device is sometimes classified as part of that device rather than as a battery, which changes both the duty rate and the documentation. Second, classification disputes are expensive to resolve after the fact. If the volume justifies it, ask for a binding tariff ruling from the destination customs authority before you ship.
Market access differs by destination
Transport documentation gets the goods to the port. Market access lets you sell them once they arrive. Two examples that come up constantly with the markets we serve:
- European Union. Products need CE marking, and batteries are governed by Regulation (EU) 2023/1542, which replaced the earlier Battery Directive and introduces obligations — including carbon footprint declaration and recycled content — on a phased timetable. Confirm which obligations already apply to your product category.
- India. Lithium cells and batteries require registration with the Bureau of Indian Standards under the Compulsory Registration Scheme, with IS 16046 as the applicable safety standard. Registration is held by the manufacturer and is a market-access gate, not a formality.
Other destinations have their own regimes, and they change. Treat market access as a question you ask your supplier and your broker per shipment, not as a fact you establish once.
Product safety standards buyers ask for
- IEC 62619 — safety requirements for industrial lithium batteries, and the standard most often named by commercial and industrial buyers.
- IEC 62133-2 — portable sealed cells and batteries.
- UL 1973 — batteries for stationary applications, common in North American projects.
- UL 9540A — a test method for evaluating thermal runaway propagation in energy storage systems, increasingly requested for containerised and cabinet installations.
Treat these as target standards. A supplier claiming all four as held certifications should be able to produce the certificate numbers and the issuing laboratory; if they cannot, the claim is a target, not a certification.
Why the documentation is a design input
The most expensive mistake in this whole process is treating certification as paperwork that follows manufacturing. UN38.3 summaries and safety certificates are tied to a specific cell, a specific construction and a specific BMS. Change the cell supplier to save cost after certification, and the documentation no longer describes the product you are shipping. In practice that means the cell and the construction should be locked before the certification programme starts — which makes the cell decision a compliance decision, not only a commercial one.
Checklist
- UN38.3 test summary in hand, with the cell model matching the invoice.
- MSDS in the destination’s required language.
- Correct UN number, and state of charge at or below 30% for air freight of UN3480.
- HS code confirmed to national tariff line, with duty verified.
- Market-access registration identified for the destination, with lead time built into the schedule.
- Cell and construction frozen before certification begins.
How Origin Drive Future supports it
We supply the transport documentation package — UN38.3 test summary, MSDS and declaration support — with every shipment, and can discuss target standards and market-access requirements as part of the quotation. See the LiFePO4 cells and packs and container energy storage ranges, or send us your destination and volume and we will tell you what the documentation looks like for that market.