LiFePO4 Battery SDS: When You Need One, What It Should Contain, and How It Differs From UN38.3

“Please send the SDS” is one of the first requests in almost every battery RFQ. Forwarders ask for it at booking, warehouses ask for it before they accept the pallets, and installers’ customers ask for it for their site files. Yet batteries are manufactured articles, and the transport rules don’t require an SDS at all. This guide explains what the rules actually say, how an SDS differs from the UN38.3 test summary, and what to check on the SDS a supplier sends you.

This guide is general information as of 30 October 2026, not legal advice. Your forwarder, broker and the authority having jurisdiction (AHJ) decide what applies to your shipment and site.

Short answer

• Transport: the IATA guidance says neither the IATA Dangerous Goods Regulations nor the rules for other transport modes require an SDS when offering batteries for transport. The UN38.3 test summary is the document the transport rules require.
• Workplace (US): OSHA’s 2022 interpretation says batteries are not automatically outside the Hazard Communication Standard. Workers who store, handle, maintain or recycle them, or deal with them in emergencies, can still be exposed to hazards.
• Installation (Australia): AS/NZS 5139 as amended in 2025 requires a physical copy of the SDS at a home battery installation.
• In practice: expect to be asked for an SDS, and make sure the one you hold is current and matches the exact battery you ship.

SDS, MSDS and the UN38.3 test summary: what each document is

An SDS (safety data sheet) is a hazard communication document. OSHA explains that SDSs were formerly called MSDSs (material safety data sheets) and that the content is largely the same, but SDSs now follow a consistent 16-section format. The UN38.3 test summary is something else: a short record that the cell or battery type passed the UN transport tests. Certificates and test reports for product safety are a third category.

Document	What it is	Who usually asks	Required?
SDS (formerly MSDS)	Hazard and handling information in 16 sections	Forwarders, warehouses, installers, customers	Not a transport requirement for batteries; workplace and installation rules vary by country (see below)
UN38.3 test summary	Proof that the cell or battery type passed the UN 38.3 transport tests	Carriers, forwarders, regulators, customers	Yes. Manufacturers and later distributors must make it available
Product safety test reports (e.g. IEC 62619, UL 1973)	Product safety testing for a market or application	Customers, AHJs, insurers	Depends on the market and application. Arranged per project, with fees borne by the buyer

For how to check certificates and reports, see our battery certification verification guide and the LiFePO4 safety certifications guide.

What the rules say

Air and other transport: the SDS is not a transport document

IATA’s lithium battery guidance for the 2026 regulations answers the question directly. Asked whether the DGR requires an MSDS or SDS containing the UN 38.3 test data, it says: “No. Neither the IATA DGR, nor the regulatory requirements applicable to other modes of transport, requires a safety data sheet (SDS) when offering batteries for transport.” It adds that an SDS “is not a transport document” and that the GHS, the system behind SDSs, “does not include provisions for manufactured articles, such as batteries.”

What transport does require is the UN38.3 test summary. Manufacturers and subsequent distributors must make it available, and IATA notes that this can be done by placing it on a website and giving a QR code or URL with the battery, its packaging or the transport documents. The summary must include ten items, among them the manufacturer’s name and contact details, the test laboratory, a unique test report number and date, a description of the battery (lithium ion, mass, watt-hour rating, model numbers), the list of tests and results, and the name and title of the responsible person.

So when a forwarder insists on an SDS, it is usually their own booking or warehouse policy, not the dangerous-goods rule. It’s easier to provide a good SDS than to argue, but the UN38.3 test summary is the document that has to be right.

US workplaces: OSHA’s 2022 interpretation

OSHA’s Hazard Communication Standard exempts “articles”. In a letter of interpretation dated 1 December 2022, OSHA said it generally agrees that most workers are not exposed to battery hazards during normal use of many end-use products, but that “exposure to potential hazard(s) remains to some workers with exposure to batteries during storage, handling, maintenance, failure/exposure detection, and during emergencies.” It also said that manufacturers and importers must classify the hazards of what they produce or import, and “bear the burden of demonstrating that a claimed exemption, such as the exemption for articles, is applicable.”

For importers, the practical point is simple: you are the importer of record, so you should hold a current SDS from the manufacturer and be ready to pass it downstream to warehouses, installers and customers.

Australian installations: a paper SDS at the battery

Amendment 1 to AS/NZS 5139:2019 was published on 19 December 2025. In its advisory on the changes, the NSW Government says the amendment clarifies SDS requirements: “A physical copy of the SDS must be provided,” protected from damage, for example in a sealed, durable clear pouch. The Clean Energy Regulator’s solar battery inspection checklist also asks whether there is a hard-copy SDS, “not digital”, in a document holder at the main switchboard or meter box. Installers in Australia therefore need a printed, current SDS for every battery model they install.

UN3480 vs UN3481 on the SDS transport section

Section 14 of an SDS covers transport information. For lithium-ion batteries, IATA lists the classifications as:

• UN 3480: lithium ion batteries shipped on their own
• UN 3481: lithium ion batteries contained in equipment, or packed with equipment

A standalone LiFePO4 battery shipped to a distributor is normally UN 3480. The same battery installed in a product, or packed in the same box as the product it powers, is UN 3481. The correct entry depends on how you ship, so check it with your forwarder rather than copying the SDS of another product. Our guide to importing lithium batteries from China covers the rest of the shipping document pack.

What to check on a supplier’s SDS

OSHA’s SDS brief describes the 16 sections. Sections 1 to 8 cover identification, hazards, composition, first aid, fire-fighting, accidental release, handling and storage, and exposure controls. Sections 9 to 11 and 16 cover technical information, including “the date of preparation or last revision”. OSHA also notes that the SDS must be in English (other languages may be added). When a supplier sends an SDS, check:

1. All 16 sections are present, in the standard order.
2. The product identifier matches your battery: model name, chemistry (lithium iron phosphate, LiFePO4), nominal voltage, capacity and watt-hour rating as on the label and the UN38.3 test summary.
3. The responsible party is named: Section 1 should give the name, address and phone number of the manufacturer, importer or other responsible party, and an emergency phone number.
4. The transport section matches how you ship: UN 3480 or UN 3481, Class 9.
5. The date and revision are current. An old SDS for a different model with the name changed is a red flag.
6. The same company appears on the SDS, the UN38.3 test summary and the label, or the relationship between them is explained.

Our LiFePO4 import checklist puts these checks alongside the other pre-shipment documents.

Who asks for an SDS, and why

• Forwarders and carriers: often as a booking policy, even though IATA says the SDS is not a transport document.
• Warehouses and fire officials: to plan storage and emergency response. See our lithium battery warehouse storage fire code guide and our storage guide for distributors.
• Installers and AHJs: for site files and inspections. Australia requires a paper copy at the installation; see our home battery permit pack guide for the rest of the installer document set.
• Customers and marketplaces: as part of supplier onboarding. For Amazon’s SDS and test summary requirements, see our guide to selling LiFePO4 batteries on Amazon.

Where LJY fits

LJY Energy is a Shenzhen supplier and OEM/ODM coordinator for LiFePO4 batteries, not a manufacturer. For each order we coordinate the SDS and the UN38.3 test summary for the exact model with the manufacturer, so the model, chemistry and company details match what you ship. Further certification and testing are arranged per project, with fees borne by the buyer. Importers and distributors can browse the product catalog or see our distributor page.

FAQ

Do lithium batteries need an SDS?

Not for transport: IATA says no transport mode requires one for batteries. Workplace and installation rules vary by country. OSHA says hazard communication can still apply in some situations, and Australia’s AS/NZS 5139 requires a paper SDS at home battery installations. Expect to be asked for one.

Is an MSDS the same as an SDS?

Yes, in practice. OSHA says SDSs were formerly called MSDSs, with largely the same information now in a consistent 16-section format.

Is an SDS the same as a UN38.3 test summary?

No. The SDS is about hazards and handling. The UN38.3 test summary shows that the battery type passed the UN transport tests, and it is the document the transport rules require.

What UN number goes on a LiFePO4 battery SDS?

UN 3480 for lithium-ion batteries shipped on their own, and UN 3481 for batteries contained in or packed with equipment.

How old can an SDS be?

Ask for the current revision and check the date of preparation or last revision in Section 16. Make sure the model and company match the label and the UN38.3 test summary.

Sources

• IATA Lithium Battery Guidance Document (2026 regulations): classification, test summary, FAQ G.01
• OSHA letter of interpretation, 1 December 2022: applicability of the HCS to lithium-ion batteries
• OSHA brief: Hazard Communication Standard, Safety Data Sheets
• NSW Government: changes to the battery standard (AS/NZS 5139:2019 Amd 1:2025)
• Clean Energy Regulator: solar battery inspection checklist