Small batteries: Never without rules

Anyone shipping lithium batteries with low power limits by land and sea can dispense with UN-approved packaging and – in land transport – without having to draw up a transport document. However, letters a) to h) of Special Provision (SV) 188 ensure that a lot of details have to be observed.
Documentation can only be dispensed with once the requirements have been fully implemented. As the requirements of Chapter 1.3 of the ADR dangerous goods regulations no longer apply with the exemption, there is no need for training in accordance with them. Nevertheless, it is necessary to instruct employees in the application of SV 188. Incidentally, the situation is different in air transport, as the packaging instructions explicitly refer to the training requirements in accordance with 1.6 IATA-DGR.
Note: A transitional rule for articles containing dangerous goods ended in 2023. The assignment to one of the new UN numbers is based on the predominant hazard (2.1.3.10. ADR).
Articles containing goods of Class 9 and goods of other classes must always be classified in classes other than Class 9. This also applies to articles in which, among other things, lithium batteries are installed, such as disposable e-cigarettes.

Daniela Schulte-Brader

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