How to Ship Lithium Battery Products from China in 2026 Under IMDG Code Amendment 42-24
The year 2026 marks a fundamental shift in how lithium batteries are shipped internationally by sea. If you've been importing lithium battery products from China using the same procedures for years, you need to know this: the rules have changed, and the consequences of non-compliance are no longer theoretical.
Starting January 1, 2026, the International Maritime Dangerous Goods Code Amendment 42-24 becomes mandatory, bringing the most comprehensive updates to battery shipping regulations in recent history. For the first time, the International Maritime Organization has systematically separated batteries, battery-equipped devices, and battery-powered vehicles into distinct regulatory categories, each with specific UN numbers and compliance requirements.
This is not a minor technical update. It represents a structural change in how dangerous goods compliance works for battery shipments. Where problems previously surfaced during transit or at destination ports, they now emerge during the booking stage.
Understanding these changes is no longer optional for importers who source products from China, the world's largest exporter of lithium batteries, energy storage systems, and electric devices.
This guide walks you through everything you need to know to ship lithium batteries from China compliantly in 2026 and beyond.
Understanding IMDG Code Amendment 42-24: What Changed and Why It Matters
The Context Behind the Update
The IMDG Code, developed by the International Maritime Organization, serves as the global standard for transporting dangerous goods by sea. Every two years, the code undergoes revision based on operational data, incident reports, and technological developments. Amendment 42-24 reflects lessons learned from actual shipping incidents and the rapid growth of new energy technologies.
The amendment introduces significant changes to maritime compliance requirements, impacting industries such as chemicals, lithium and sodium-ion batteries, carbon materials, vehicles, and logistics. For battery importers specifically, three core changes stand out.
Core Change 1: New UN Number System for Batteries and Vehicles
The most visible change is the introduction of dedicated UN numbers for battery-powered vehicles and sodium-ion batteries. Previously, many electric devices and vehicles were shipped under the generic UN 3171 classification. The generic classification UN 3171, Class 9 for battery-powered vehicle is no longer permitted for lithium or sodium-ion powered vehicles.
New UN Numbers You Need to Know:
UN 3551: Sodium-ion batteries (standalone)
UN 3552: Sodium-ion batteries contained in equipment or packed with equipment
UN 3556: Lithium-ion battery-powered vehicles
UN 3557: Lithium metal battery-powered vehicles
UN 3558: Sodium-ion battery-powered vehicles
This separation exists for a critical safety reason. Battery-powered vehicles like e-bikes and e-scooters get their own dedicated UN numbers, separating them from loose batteries. When fire incidents occur at sea, response teams need to know immediately whether they're dealing with loose batteries, equipment containing batteries, or entire vehicles. The old system's ambiguity created response delays that endangered crews and cargo.
Core Change 2: Enhanced Documentation Requirements
Section 5.4.4.2 mandates that goods granted exemptions must include corresponding certificates. This represents a fundamental shift from experience-based compliance to evidence-based compliance.
Under the previous system, freight forwarders and factories often relied on verbal confirmations and historical precedent to determine if a shipment qualified for exemptions. That approach no longer works. If you claim a packaging exemption, reduced classification, or special provision, you must now provide written certification proving eligibility.
This change directly affects how you work with Chinese suppliers. They can no longer simply declare a shipment compliant. They must produce documentation demonstrating compliance according to current standards.
Core Change 3: Expanded Battery Marking and Labeling
Sodium-ion batteries are now subject to the Lithium Battery Mark and Class 9 label requirements, necessitating updates to packaging designs. The battery mark that originally applied only to lithium batteries now extends to sodium-ion technology, reflecting the commercial growth of this alternative chemistry.
If your Chinese suppliers still use old packaging designs without updated marks, customers are encouraged to verify placarding prior to gate-in to avoid potential disruption. Shipping lines will reject bookings at the documentation review stage, before cargo even reaches the port.
How This Affects You as an Importer: Three Critical Responsibility Shifts
Shift 1: Importers Now Part of the Compliance Chain
Previously, importers could remain relatively passive in the dangerous goods compliance process. You placed orders, your factory arranged export documentation, and your freight forwarder handled the hazmat procedures. That linear model is becoming obsolete.
Under the new framework, importers bear responsibility for verifying that the correct classification, packaging, and documentation exist before booking shipment. Shipping lines increasingly request confirmation that importers understand what they're shipping and can provide compliance evidence if questioned by authorities or insurance companies.
This doesn't mean you personally need to become a dangerous goods expert, but it does mean you need reliable partners who are experts and systems to verify compliance before committing to shipments.
Shift 2: Classification Verification Becomes the Checkpoint
The proliferation of new UN numbers means classification errors are now more likely and more consequential. Consider these common scenarios where importers face classification challenges:
Energy Storage Systems: Many importers treat battery cabinets and power stations as standalone batteries (UN 3480). However, if these units include integrated inverters, controllers, or other functional equipment, they may actually fall under "batteries contained in equipment" classifications, requiring different packaging instructions and documentation.
Electric Mobility Devices: Electric scooters, bikes, and hoverboards previously shipped under various classifications depending on how suppliers interpreted the rules. Now, if the device is self-propelled and uses lithium-ion batteries, it must use UN 3556. The classification depends on the product's actual function, not on what category seems most convenient.
Battery-Powered Tools: Professional power tools containing batteries face particular scrutiny. Is the tool shipped with the battery installed, or separately? The answer determines whether you use UN 3481 (batteries packed with equipment) or UN 3480 (standalone batteries), each with different packaging and documentation requirements.
Getting the classification wrong doesn't just delay shipment. It creates insurance complications, potential liability for incident costs, and regulatory investigations in both origin and destination countries.
Shift 3: Document Integrity Becomes Quality Control Gate
Enhanced documentation requirements include dates of production, dates of packaging, and temperature of material at packaging for carbon products. While this specific requirement applies to carbon, it exemplifies the broader trend toward granular documentation standards.
For battery shipments, document consistency matters more than ever. Your UN 38.3 test summary must match the exact battery model being shipped. The Safety Data Sheet must reference IMDG Code Amendment 42-24 in Section 14. The battery specifications in your commercial documents must align with the test report parameters.
Inconsistent documentation is now the leading cause of booking rejections. Shipping lines employ trained dangerous goods specialists who cross-reference multiple documents before accepting hazmat cargo. Any discrepancy triggers rejection, and re-booking extends your supply chain timeline by weeks.
Five High-Risk Scenarios That Will Cause Problems in 2026
Understanding where problems typically emerge helps you build preventive measures into your sourcing and shipping processes.
Scenario 1: Using Old UN Numbers for New Product Categories
What Happens: Your Chinese supplier continues declaring electric scooters under UN 3171, the old generic code for battery-powered vehicles.
Why It Fails: All applicable shipments must be declared using UN 3556, 3557, or 3558 as appropriate depending on battery chemistry.
Consequence: Shipping line rejects the booking during document review. Your supplier must repackage with correct labeling and resubmit documentation. You lose 2-3 weeks and may miss your sales window.
Prevention: Before placing orders, confirm with your supplier which specific UN number will be used and verify they have packaging materials with the correct labels already in stock.
Scenario 2: Mismatched Test Reports and Actual Battery Specifications
What Happens: Your supplier provides a UN 38.3 test summary for a 3,000mAh battery, but the actual product now uses a 5,000mAh battery because they upgraded the product without updating documentation.
Why It Fails: The UN 38.3 test summary must match the exact battery model, capacity, and configuration being shipped. Shipping lines verify this by cross-referencing the test summary with the product specifications in your commercial invoice and packing list.
Consequence: Booking rejection, plus potential safety liability if the shipment somehow proceeds and an incident occurs. Insurance companies use document mismatches as grounds to deny claims.
Prevention: Request updated UN 38.3 test summaries whenever your supplier makes any battery specification changes, no matter how minor they seem. Treat battery test reports as version-controlled documents that must match current production.
Scenario 3: Expired or Invalid UN 38.3 Reports
What Happens: Your supplier provides a UN 38.3 test summary from 2019, believing it remains valid because the battery model hasn't changed.
Why It Fails: Testing standards evolve, and many shipping lines now require test reports to be no more than three to five years old. Additionally, if your supplier changed battery cell suppliers or manufacturing locations, the old test may no longer apply.
Consequence: Shipping line rejects the booking and requests current testing. Obtaining new UN 38.3 testing typically requires four to six weeks, completely disrupting your supply schedule.
Prevention: As part of your annual supplier qualification process, verify that UN 38.3 test reports are current and will remain valid for at least six months after your planned shipment date.
Scenario 4: Inadequate State of Charge Documentation for High-Capacity Batteries
What Happens: You ship large-capacity lithium batteries (like those in energy storage systems) without clearly documenting the state of charge at the time of packaging.
Why It Fails: The rule states batteries should generally be shipped at a state of charge not exceeding 30% of their rated capacity. Shipping lines require written confirmation of SoC levels for high-capacity batteries due to thermal runaway risks.
Consequence: The shipping line may refuse the booking entirely, or require additional safety measures such as segregation from other cargo, significantly increasing freight costs.
Prevention: Work with your Chinese supplier to establish standard operating procedures for discharging batteries to acceptable SoC levels before packaging, and ensure they document this process with date, initial charge level, final charge level, and technician signature.
Scenario 5: Sodium-Ion Batteries Treated as Non-Hazardous
What Happens: Your supplier treats sodium-ion batteries as general cargo because they are a newer technology and mistakenly believes they are not yet regulated.
Why It Fails: Under IMDG 42-24, sodium-ion batteries are now strictly Class 9 Dangerous Goods with specific UN numbers (3551 and 3552) and testing requirements similar to lithium batteries.
Consequence: If shipped as general cargo, the shipment violates dangerous goods regulations. Discovery at the loading port results in refused loading. Discovery at destination can result in fines, cargo detention, and potential criminal liability in some jurisdictions.
Prevention: Explicitly confirm with your supplier whether any products use sodium-ion battery technology, and if so, ensure they are prepared to handle these batteries with the same dangerous goods procedures they use for lithium batteries.
Step-by-Step Guide: How to Ship Lithium Battery Products from China in 2026
Step 1: Determine Your Product's Correct Classification
The classification process starts with three fundamental questions:
What is the physical form? Standalone batteries, batteries installed in equipment, batteries packed with equipment, or battery-powered vehicles.
What battery chemistry? Lithium-ion, lithium metal, or sodium-ion.
What is the watt-hour rating or lithium content? For lithium-ion batteries, calculate watt-hours (Wh) = voltage (V) × amp-hours (Ah). These values determine whether your batteries qualify for exceptions or require full dangerous goods procedures.
Example: Electric skateboards with built-in 36V, 6Ah lithium-ion batteries (216 Wh) are classified as UN 3556 (Lithium-ion battery-powered vehicles), not UN 3481, because they are self-propelled.
Step 2: Verify Complete and Consistent Compliance Documentation
Your Chinese supplier must provide matching documentation:
UN 38.3 Test Summary showing the exact battery model passed all eight required safety tests (altitude simulation, thermal test, vibration, shock, external short circuit, impact, overcharge, forced discharge)
Safety Data Sheet with Section 14 referencing IMDG Code Amendment 42-24
Battery Specification Sheet with parameters matching the UN 38.3 test summary
Packaging Certification proving compliance with the correct Packing Instruction (P912 for vehicles UN 3556-3558)
Exemption Certificates if applicable, per Section 5.4.4.2
The critical requirement is consistency. Every document must align on battery specifications and safety characteristics.
Read full domumentation checklist for DG cargo and batteries.
Step 3: Confirm Packaging and Marking Compliance
Physical Packaging: Batteries must be packaged to prevent short circuits and movement during transport. Outer packaging must withstand normal transport conditions.
Marking and Labeling: Outer packaging must display the correct UN number, Proper Shipping Name, Class 9 hazard label, lithium battery handling label (now applicable to sodium-ion batteries too), and shipper/consignee information.
Step 4: Conduct Pre-Booking Dangerous Goods Review
Before booking, verify the UN number, proper shipping name, Packing Instruction, and whether your shipment qualifies for Limited Quantity provisions. Check route-specific restrictions and destination country requirements. Many shipping lines offer online screening tools for preliminary acceptance.
Step 5: Book with a Qualified Carrier and Maintain Records
Select carriers based on their experience with battery cargo from major Chinese ports (Shenzhen, Ningbo, Shanghai, Qingdao). Work with freight forwarders who have certified dangerous goods staff and established carrier relationships. Maintain all documentation for at least five years for insurance claims, regulatory investigations, and audits.
Working with a Chinese Freight Forwarder: What to Expect in 2026
Selecting a freight forwarder with genuine dangerous goods expertise provides significant operational advantages when shipping batteries from China.
What Distinguishes a Qualified Dangerous Goods Forwarder
Professional dangerous goods forwarders offer capabilities beyond general logistics providers:
Proactive Classification Review: Independent verification of product classifications rather than accepting factory declarations.
Documentation Audit Systems: Systematic audits ensuring UN 38.3 test summaries match product specifications and all certificates are current.
Direct Carrier Relationships: Established communication channels with dangerous goods acceptance staff at major carriers, enabling expedited approvals.
Regulatory Update Monitoring: Continuous tracking of IMO, flag state, and port authority updates, with proactive customer notification.
Factory Coordination Services: Direct work with Chinese manufacturers to correct packaging deficiencies and update documentation.
Gerudo Logistics: Supporting Compliant Battery Exports from China
At Gerudo Logistics, we specialize in dangerous goods exports from China, with particular expertise in lithium battery products. We serve as a risk filtration layer between you and potential compliance failures.
Our comprehensive services include classification and compliance consulting, documentation review and verification, factory compliance coordination, carrier coordination and booking management, and regulatory change monitoring. We help determine the correct UN number and Special Provisions, verify that UN 38.3 test summaries are current and match specifications, work directly with your Chinese suppliers to address compliance issues, and maintain relationships with major carriers serving routes from China to global destinations.
Every year, importers lose significant resources to rejected bookings, delayed shipments, and regulatory penalties. These losses are preventable with proper expertise applied at the right stages of the supply chain.
For more information about how we support lithium battery imports from China, contact our dangerous goods team directly.
Understanding Testing and Certification Requirements
UN 38.3 Test Summary Explained
The UN 38.3 test summary documents that a battery has successfully completed eight mandatory safety tests designed to simulate conditions the battery might encounter during transport. These tests identify batteries that could pose fire, explosion, or chemical release hazards.
The Eight Required Tests:
Altitude Simulation
Thermal Test
Vibration
Shock
External Short Circuit
Impact
Overcharge (for rechargeable batteries)
Forced Discharge
Critical Verification Points:
The battery model and specifications in the test summary must exactly match what you are shipping
If your supplier changed battery cell suppliers or modified the battery design, new testing is required
Test summaries should typically be no more than three to five years old
The test summary must be available to anyone in the transport chain who needs it
Safety Data Sheets for Battery Products
The Safety Data Sheet provides comprehensive safety information about the battery. Section 14 of the SDS must specifically reference IMDG Code Amendment 42-24 and provide critical transport classification information, including UN number, proper shipping name, transport hazard class, packing group, environmental hazards, and special precautions for transport.
Manufacturing and Quality Documentation
Beyond testing and safety documents, shipping lines increasingly request evidence of manufacturing quality control, including manufacturing location and date, quality control certifications, product specification sheets, and warranty information. While not formally required by IMDG Code in all cases, this supplementary documentation demonstrates proper manufacturing and reduces perceived risk.
Frequently Asked Questions to Ship Batteries from China
Q1: We have been shipping batteries the same way for three years. Why do we need to change our procedures now?
IMDG Code Amendment 42-24 introduces new UN numbers, documentation requirements, and classification systems. As of January 1, 2026, Amendment 42-24 is mandatory, and carriers will reject non-compliant bookings.
Q2: Is this a Chinese regulation or an international regulation?
These are international regulations established by the International Maritime Organization, implemented by flag states and shipping lines worldwide. The requirements apply to all ocean shipments regardless of origin or destination country.
Q3: Can we still use IMDG Code Amendment 41-22 procedures through the end of 2025?
During 2025, shippers can comply with either Amendment 41-22 or 42-24. However, many shipping lines have already transitioned to accepting only 42-24, so early adoption reduces booking difficulties.
Q4: What happens if we ship using incorrect classification or outdated documentation?
The most common consequence is booking rejection at the documentation review stage. If shipment proceeds despite non-compliance, you face potential fines, cargo detention, insurance policy invalidation, and regulatory investigations.
Q5: Do all lithium batteries require dangerous goods procedures, or are there exemptions?
Most lithium battery shipments require full dangerous goods procedures. Exemptions exist for certain small batteries (e.g., lithium-ion cells under 20 watt-hours or batteries under 100 watt-hours). These exemptions must be documented.
Q6: How do sodium-ion batteries differ from lithium batteries in shipping requirements?
Sodium-ion batteries have dedicated UN numbers (3551 and 3552) and similar requirements to lithium batteries, including Class 9 classification, dangerous goods packaging and labeling, and documentation needs.
Q7: How long does it take to obtain UN 38.3 testing if our current test report is outdated?
UN 38.3 testing typically takes four to six weeks depending on laboratory availability and battery complexity. Maintain awareness of test report status and initiate updates well in advance of planned shipments.
Conclusion
The implementation of IMDG Code Amendment 42-24 marks the beginning of a new compliance framework where documentation standards are stricter, classification requirements are more specific, and the margin for error is smaller.
For importers sourcing lithium battery products from China, success in 2026 and beyond depends on building compliance verification into your sourcing process, establishing partnerships with logistics providers who bring genuine dangerous goods expertise, and maintaining organized documentation systems that preserve compliance evidence.
The global transition to electric mobility and energy storage ensures that battery shipments will only grow in volume and importance. Understanding how to navigate the regulatory environment is a core competency for sustainable supply chain operations.
If you are currently importing lithium batteries, energy storage systems, or battery-powered products from China, now is the time to audit your compliance procedures and ensure your logistics partners have the expertise you need.
