Sea Freight of LiFePO4: UN3480 vs UN3481 and the IMDG Document Pack

Share This Article

Importers booking a first container or LCL of LiFePO4 cells or packs usually hit the same three questions: is this shipment UN3480 or UN3481, what does Class 9 / P903 actually require, and which documents does the forwarder need before the vessel books? This guide deepens the sea-freight side of our China LiFePO4 export guide so you can RFQ a complete DG document pack instead of discovering gaps at the pier.

General information as of 30 October 2026. Classification and packing rules cite the U.S. PHMSA Lithium Battery Guide for Shippers (Rev. Oct 2024) and related PHMSA interpretations. Vessel carriage often uses the IMDG Code subject to applicable conditions — your forwarder and the competent authority decide the current amendment wording and any line-specific rules. LJY Energy is a Shenzhen supplier and OEM/ODM coordinator, not a manufacturer.

Short answer

TopicPractical takeaway
UN3480Stand-alone lithium ion batteries (package contains only cells/batteries).
UN3481Lithium ion batteries packed with equipment, or contained in equipment.
Hazard classClass 9. The shipper classifies the consignment.
Sea packing familyIMDG packing instruction P903 (confirm the current IMDG amendment with your forwarder). PHMSA §173.185(b) describes U.S. HMR packaging for fully regulated lithium ion batteries.
30% SoCAn air restriction for UN3480 cargo aircraft (SP A100 / IATA context) — not a universal IMDG sea mandate. Do not invent a sea SoC %.

UN3480 vs UN3481 in one table

UN numberProper shipping name (PSN)When it usually applies
UN3480Lithium ion batteries (including lithium ion polymer batteries)Cells or packs shipped alone — the package contains only batteries.
UN3481Lithium ion batteries packed with equipment or contained in equipmentBatteries in the same outer packaging as the equipment they power, or installed in the equipment.

PHMSA also lists related entries such as UN3171 (battery-powered vehicle) and UN3536 (lithium batteries installed in a cargo transport unit). Those are different consignments — do not force every ESS cabinet or cart into UN3480 by habit.

When the line between “battery” and “equipment” is unclear, PHMSA LOI 23-0001 stresses that the shipper classifies under §173.22, using the primary purpose of the device: a standalone power source for another device is often UN3480; a device whose primary purpose is something other than powering another device is often UN3481 contained-in. Put the intended UN number in the RFQ so supplier and forwarder argue from the same assumption.

Class 9 and shipper responsibility

Fully regulated lithium ion batteries travel as Class 9 dangerous goods under the U.S. Hazardous Materials Regulations (HMR) and, for many vessel movements, under the IMDG Code subject to HMR 171.22–26 conditions. PHMSA’s shipper guide says vessel transport may use the IMDG Code under those conditions and tells readers to consult the current IMDG Code (IMO).

That means:

  • The shipper owns classification, packaging selection, marks/labels and the shipping paper / DG declaration as required.
  • Line operators and ports may add their own document cut-offs. Book DG space early.
  • LJY can help assemble the model list, Wh figures and test-summary availability for the RFQ — we do not replace your forwarder’s classification decision.

P903 and packaging performance (sea)

For U.S. HMR fully regulated UN3480, PHMSA Guide 01 / §173.185(b) describes (among other points):

  • Protection against short circuits; cells/batteries in non-metallic inner packagings.
  • Outer packaging meeting UN specification Packing Group II performance.
  • An alternative path for batteries ≥12 kg with a strong, impact-resistant outer casing: strong outer packaging or protective enclosures / pallets (air movements need Associate Administrator approval for that alternative — another reason not to copy air rules onto sea blindly).
  • Hazard communication: Class 9 lithium battery label, UN number, PSN, shipping paper, emergency response information as required for fully regulated consignments.

On the vessel side, manufacturer/forwarder guides (for example Currie Associates Guide #21 covering IMDG Amendment 42-24, and older Tadiran IMDG overviews) state that IMDG P903 applies to UN 3090 / 3091 / 3480 / 3481. Treat those PDFs as secondary: prefer the current IMDG text and your forwarder’s checklist on the booking day. Do not quote 2017-era wording as current law.

Document checklist for the forwarder

Ask for this pack before the carrier books the container or LCL:

  1. UN38.3 test summary for the exact model(s) being shipped (available / arranged per project; testing fees borne by the buyer — we do not invent report IDs).
  2. SDS when the line or destination requires it; model and chemistry must match the cargo.
  3. Commercial invoice with a clear description and Wh per unit.
  4. Packing list with piece counts and weights that match the physical load.
  5. DG declaration / shipping paper as required for fully regulated consignments, plus emergency response information.
  6. Marks and labels plan: Class 9 lithium battery label, UN number, PSN on the packages as required.
  7. Any China-export packaging appraisal / DG packaging certificate your lane still uses for export clearance — confirm with the broker for that sailing.

For the wider export document set (invoice, COO, customs declaration and so on), stay on the export guide. For destination duty and producer rules, use the country import guides linked from how to import lithium batteries from China and the LiFePO4 import checklist.

Request an import quotation with DG document review

Sea vs air SoC — keep the correction

The 30% state-of-charge limit that circulates in sales chats is an air rule for UN3480 on cargo aircraft (PHMSA Guide 01 air restrictions / SP A100 context; passenger aircraft is forbidden for that entry). It is not a universal IMDG sea mandate. Carriers or insurers may still set their own SoC preferences for a sailing — that is a commercial condition, not something this page invents as “the IMDG SoC %”.

If your RFQ mixes air samples and sea production, write the mode next to the SoC ask so nobody applies the air figure to the container by mistake.

Wh marking on the battery case

PHMSA’s Oct 2024 shipper guide notes that beginning 10 May 2024, the Wh rating must be marked on the outside case of lithium ion batteries (§173.185(a)(5) in that guide). Match the marked Wh to the invoice and the test summary model list — mismatches are a common booking delay.

What to ask the supplier before booking

  • Exact model list and configuration (cells vs packs; packed-with vs contained-in equipment).
  • Wh per unit and how it is marked on the case.
  • Intended UN number (3480 vs 3481) and why.
  • UN38.3 test summary availability for those models; who holds the report; whether a new test is needed after logo/BMS/enclosure changes (fees borne by the buyer).
  • Packaging type proposed (UN PG II outer vs ≥12 kg strong-casing / pallet path) and who issues any China DG packaging certificate for export.
  • HS / tariff line the supplier prints on export docs — useful input only; import classification is still the importer’s responsibility. See the LiFePO4 HS code classification guide.

Certification wording elsewhere on this site follows the same rule: documents are available / arranged per project; we do not publish a blanket claim that LJY holds the UN38.3 report for every model. Verify report scope with the certification verification guide.

Ask about a China export RFQ

Where LJY fits

LJY Energy is a Shenzhen supplier and OEM/ODM coordinator for LiFePO4 batteries, not a manufacturer. We help importers and distributors line up model lists, Wh data and document availability with manufacturing partners so your forwarder receives a coherent DG pack. Classification, packaging performance and carrier acceptance remain with the shipper and forwarder. Browse the product range when you are ready to map models to an RFQ.

FAQ

Is every LiFePO4 container UN3480?

No. Stand-alone cells/packs are typically UN3480; batteries packed with or contained in equipment are UN3481. Vehicles and CTU-installed batteries use other UN entries. The shipper classifies.

Does sea freight require 30% SoC?

Not as a universal IMDG rule. 30% SoC is the familiar air (cargo aircraft) restriction for UN3480. Ask your forwarder whether the line has its own SoC condition for that sailing.

What is P903?

The IMDG packing-instruction family commonly cited for UN 3090/3091/3480/3481 in secondary manufacturer/forwarder guides. Confirm the current IMDG amendment text with your forwarder before you treat any PDF checklist as final.

Can LJY assign the UN number for me?

We can state the intended packing configuration and share the documents we can obtain per project. Final classification and carrier paperwork stay with the shipper / forwarder / competent authority.

Sources

  • PHMSA Lithium Battery Guide for Shippers (Revised Oct 2024) — UN3480/UN3481 classification; §173.185(b) fully regulated packaging; vessel/IMDG note; air SoC contrast; Wh marking from 10 May 2024
  • PHMSA LOI 23-0001 — shipper classification; primary-purpose test for UN3480 vs UN3481 contained-in
  • Currie Associates Guide #21 (IMDG Amendment 42-24) and Tadiran sea-transport IMDG overview — secondary P903 references only; confirm current IMDG / forwarder text on publish day

Share This Article