Battery Hazard Label Requirements for Shipping

Battery hazard label requirements for shipping split into two tiers under Title 49 of the Code of Federal Regulations. Small lithium cells and batteries below set energy or lithium-content thresholds need the red-bordered lithium battery handling mark with the correct UN number. Larger batteries must ship as fully regulated Class 9 hazardous materials, which means the diamond-shaped Class 9 label, proper shipping name, UN identification number, shipping papers, and a 24-hour emergency response phone number. Getting the tier wrong, using the wrong UN number, or omitting the mark can lead to rejected shipments, civil penalties up to $75,000 per violation, and criminal exposure of up to five years in prison.

The Size Threshold That Decides Which Label You Need

Everything about labeling flows from one question: does the battery exceed the small-battery limits, or not?

For lithium-ion, the cutoff is 20 watt-hours per cell and 100 watt-hours per battery. For lithium metal, the threshold is weight-based: 1 gram of lithium per cell and 2 grams per battery.¹ At or below those limits, the package qualifies for the lithium battery handling mark and the reduced requirements that come with it. Above them, the shipment is fully regulated and needs the Class 9 label along with proper shipping name marking, shipping papers, an emergency response phone number, and a Cargo Aircraft Only label when moving by air.

The Lithium Battery Handling Mark

The handling mark is the rectangular label with red hatched borders that most shippers recognize. It must be at least 100 mm wide by 100 mm high. Packages too small for that size can use a reduced 100 mm by 70 mm version.¹

The mark itself has to display the correct UN number for the batteries inside. Symbols and lettering are black on a white or contrasting background; the hatched border is red. A telephone number for additional information is currently part of the mark, though a recent rulemaking is phasing that requirement out with a deadline of December 31, 2026.²

There is one narrow exemption from the mark itself: packages containing only button cells installed in equipment, or shipments of two packages or fewer where each package holds no more than four cells or two batteries contained in equipment.¹

The Class 9 Label for Larger Batteries

Batteries over the thresholds carry the Class 9 hazardous materials label. The standard Class 9 diamond is a square on point with seven black vertical stripes across the top half and the number “9” underlined at the bottom, all on white.³ A specific Class 9 lithium battery label described in 49 CFR 172.447 applies to certain battery shipments.

Each diamond must measure at least 100 mm (about 3.9 inches) on each side, with a solid inner border running 5 to 6.3 mm from the edge.⁴ Fully regulated shipments also need the proper shipping name and UN identification number marked on the outside of the package, shipping papers prepared under 49 CFR Part 172 Subpart C, and emergency response information.

UN Numbers by Battery Chemistry

Whether the shipment gets the handling mark or the Class 9 label, it has to display the correct United Nations identification number. Using the wrong number is one of the fastest ways to have a shipment rejected, and it misleads emergency responders who rely on those numbers to identify what they are dealing with.

UN 3480: Lithium-ion batteries shipped alone
UN 3481: Lithium-ion batteries packed with or contained in equipment
UN 3090: Lithium metal batteries shipped alone
UN 3091: Lithium metal batteries packed with or contained in equipment

When a package contains lithium batteries assigned to different UN numbers, all applicable numbers must appear on the mark.¹

Watt-Hour Marking on the Battery Itself

Separate from the package label, each lithium-ion battery must be marked with its watt-hour rating on the outside case. This has been required for batteries up to 100 Wh since 2016, and a 2024 rulemaking extended the marking requirement to batteries larger than 100 Wh as well.⁵

Ground-Only Exception for Mid-Range Batteries

A middle tier exists for batteries too big for the small-battery exception but moving only by highway or rail. Lithium-ion cells up to 60 Wh (or batteries up to 300 Wh) and lithium metal cells up to 5 grams (or batteries up to 25 grams) can ship without full Class 9 labeling, but only if the package carries the marking “LITHIUM BATTERIES—FORBIDDEN FOR TRANSPORT ABOARD AIRCRAFT AND VESSEL.”¹ Miss that marking and the shipment loses the exception.

Air Shipments Have Stricter Rules

Air rules are where labeling mistakes carry the highest stakes. All standalone lithium-ion batteries (UN 3480) and all standalone lithium metal batteries (UN 3090) are forbidden on passenger aircraft as cargo. They must carry a Cargo Aircraft Only label.⁶

Batteries packed with or contained in equipment (UN 3481 and UN 3091) have slightly more flexibility and can sometimes travel on passenger aircraft within quantity limits. Fully regulated versions still require the Class 9 label, proper shipping name, and shipping papers. Partially excepted versions need the lithium battery handling mark plus a statement that the shipment is forbidden on passenger aircraft, unless the shipper uses a Cargo Aircraft Only label instead.

Damaged, Defective, or Recalled Batteries

Batteries that are damaged, defective, or subject to a recall have their own regime. Each battery must be individually enclosed in a non-metallic inner packaging surrounded by non-combustible, electrically non-conductive cushioning. One battery per inner packaging, one inner packaging per outer packaging, and the outer packaging must meet the highest performance standard (Packing Group I).⁷

The outer packaging must be marked “Damaged/defective lithium ion battery” or “Damaged/defective lithium metal battery” in lettering at least 12 mm high. Standard hazard communication still applies: shipping papers, the Class 9 lithium battery label, and an emergency response phone number. These batteries are categorically forbidden for air transport, with no exceptions.⁷

Where the Labels Go on the Package

Labels can go on any surface except the bottom. They must appear on the same surface as the proper shipping name marking when the package is large enough, and for air shipments all labels must appear on a single side of the package.⁸ Avoid seams, folds, and corners where sorting can tear or wrinkle the label.

When primary and subsidiary hazard labels are both required, they must sit within 150 mm (about 6 inches) of each other.⁸ Whether printed on the package or applied as a sticker, the label must survive 30 days of exposure to conditions reasonably encountered during transportation without deteriorating or substantially changing color.⁴ A label covered by tape, another sticker, or a shipping document does not satisfy the requirement.

Overpacks

When multiple battery packages get consolidated into a single larger box, that outer container is an “overpack” with its own marking rules. The overpack must show the proper shipping name, identification number, and required labels for each hazardous material inside, unless the markings on the inner packages are clearly visible through or on the outside of the overpack.⁹

If the inner packages require orientation arrows, those packages must be placed with filling holes up, and the overpack itself must display orientation arrows on two opposite vertical sides. When specification packaging is required and the inner specification markings are not visible, the overpack must be marked with the word “OVERPACK” in lettering at least 12 mm high.⁹

Who Has to Be Trained

Every employee who handles, packages, or prepares shipping papers for lithium batteries qualifies as a “hazmat employee” and must be trained. That covers general awareness of hazardous materials regulations, function-specific instruction tied to actual job duties, safety training on emergency response and exposure protection, and security awareness training.¹⁰

New employees can perform hazmat functions before completing training, but only under the direct supervision of a trained employee. Security awareness training must be finished within 90 days of hire. Recurrent training is required at least once every three years.¹⁰ Training violations carry a mandatory minimum civil penalty.

Penalties for Getting It Wrong

A person who knowingly violates the hazardous materials regulations faces a civil penalty of up to $75,000 per violation. If the violation results in death, serious illness, severe injury, or substantial property destruction, that cap rises to $175,000. Training-related violations carry a mandatory floor of at least $450.¹¹

Criminal exposure is steeper. A willful or reckless violation can bring a fine and up to five years in prison. If the violation involves an actual release of hazardous material that causes death or bodily injury, the maximum prison term doubles to ten years.¹²

These penalties reach beyond the shipper. Carriers that accept packages they know are improperly labeled, warehouses that ignore visible labeling deficiencies, and employees who falsify shipping papers all face individual liability. A single pallet touching multiple requirements can generate violations that stack into six-figure territory quickly.

1
eCFR. 49 CFR 173.185 – Lithium Cells and Batteries
2
Pipeline and Hazardous Materials Safety Administration. Lithium Battery Guide for Shippers
3
eCFR. 49 CFR 172.446 – Class 9 Label
4
eCFR. 49 CFR 172.407 – Label Specifications
5
Pipeline and Hazardous Materials Safety Administration. Lithium Battery Guide for Shippers
6
International Air Transport Association. IATA Guidance Document for Lithium Batteries and Sodium Ion Batteries
7
Pipeline and Hazardous Materials Safety Administration. Damaged, Defective, and Recalled Lithium Battery Shipping
8
eCFR. 49 CFR 172.406 – Placement of Labels
9
eCFR. 49 CFR 173.25 – Authorized Packagings and Overpacks
10
eCFR. 49 CFR 172.704 – Training Requirements
11
Office of the Law Revision Counsel. 49 USC 5123 – Civil Penalty
12
Office of the Law Revision Counsel. 49 USC 5124 – Criminal Penalty