Lithium Battery Changes and Sodium-Ion Batteries in IMDG 43-26
Battery transport has become one of the fastest developing areas of dangerous goods regulation. For many years, lithium-ion and lithium metal batteries dominated the discussion, but the increasing commercial use of sodium-ion technology means that dangerous goods professionals must now deal with a broader range of battery chemistries. IMDG Code Amendment 43-26 continues this development and contains important changes affecting batteries, battery systems and battery-powered equipment transported by sea.
For manufacturers, shippers, freight forwarders, packers and shipping lines, the practical consequence is that existing procedures should be reviewed before Amendment 43-26 becomes mandatory. Companies that already handle lithium batteries will recognise many of the principles, but they should not assume that every battery shipment can continue to be prepared in exactly the same way.
Understanding the differences between lithium-ion, lithium metal and sodium-ion batteries, selecting the correct UN number and applying the relevant special provisions and packing instructions will become increasingly important as new battery technologies enter international supply chains.
Battery regulation continues to expand under IMDG 43-26
Lithium batteries have been regulated as dangerous goods for many years because of the hazards they can present during transport. A damaged, defective, poorly manufactured or incorrectly packed lithium battery can generate significant heat and, under certain circumstances, develop into thermal runaway. Fire involving lithium-ion batteries can be difficult to control, particularly when large numbers of batteries are packed together or transported in enclosed cargo transport units.
The IMDG Code therefore regulates lithium batteries through a combination of classification requirements, UN numbers, special provisions, packing instructions, marks, labels and documentation requirements.
Sodium-ion batteries have increasingly joined this regulatory framework.
The development is important because sodium-ion batteries are becoming commercially relevant as an alternative to lithium-ion technology. Their chemical composition is different, but this does not mean that they are automatically free from dangerous goods transport requirements. Battery chemistry, construction, energy storage and the condition in which the battery is transported all influence the applicable requirements.
Amendment 43-26 reflects this changing battery market by continuing the development of provisions for different battery types and configurations.
Lithium-ion batteries remain a major IMDG concern
For lithium-ion batteries, the familiar UN numbers remain central to classification.
UN 3480 applies to lithium-ion batteries transported by themselves, while UN 3481 covers lithium-ion batteries contained in equipment or packed with equipment. Lithium metal batteries are normally assigned to UN 3090 when transported separately and UN 3091 when contained in or packed with equipment.
Selecting the correct entry is fundamental because it determines which provisions of the IMDG Code must subsequently be considered.
A shipper cannot simply describe a consignment as “lithium batteries”. The shipper must understand what type of battery is being offered, whether it is transported separately, packed with equipment or contained in equipment and whether any special conditions apply.
Amendment 43-26 does not remove this basic principle. Instead, the regulatory environment surrounding batteries continues to become more detailed as battery technology develops.
This makes accurate product information increasingly important. Dangerous goods personnel may need information about battery chemistry, configuration, rated capacity, testing and whether the battery forms part of equipment or a larger battery system before they can determine the correct transport requirements.
Sodium-ion batteries are now firmly part of dangerous goods transport
One of the most important developments for companies following successive IMDG amendments is the emergence of dedicated provisions for sodium-ion batteries.
Sodium-ion batteries are rechargeable batteries that use sodium ions rather than lithium ions as part of their electrochemical system. They are attracting interest for applications such as stationary energy storage, industrial equipment and certain mobility applications because sodium is widely available and the technology may offer advantages for particular uses.
From a dangerous goods perspective, however, the absence of lithium does not mean the batteries can simply be treated as non-dangerous cargo.
Dedicated UN entries have already been established for sodium-ion batteries. UN 3551 covers sodium-ion batteries with organic electrolyte, while UN 3552 applies to sodium-ion batteries contained in equipment or packed with equipment, with organic electrolyte.
This distinction follows a concept familiar from lithium battery transport. The transport requirements can differ depending on whether batteries are shipped independently or in association with equipment.
For companies that manufacture or distribute both lithium-ion and sodium-ion products, product master data therefore becomes increasingly important. A warehouse employee or freight forwarder should not determine the applicable battery entry merely from the external appearance of a battery.
New battery system entries require attention
An important direction of development under Amendment 43-26 is the treatment of battery systems.
Modern energy storage increasingly involves more than individual cells or conventional battery packs. Large systems may incorporate batteries into containers, cabinets, modules or other integrated installations. These developments require dangerous goods regulations to keep pace with products that do not always fit neatly into traditional descriptions of a battery transported alone or a battery contained in conventional equipment.
For shippers, this means that a battery-related product that was classified under a particular entry in the past should not automatically be assumed to retain exactly the same classification under a new IMDG amendment.
Companies preparing for 43-26 should therefore review their battery portfolio rather than only updating their copy of the IMDG Code.
This review should include stand-alone lithium batteries, sodium-ion batteries, batteries packed with equipment, batteries contained in equipment and larger energy storage or battery systems.
Where a new or more specific UN entry applies, classification procedures, dangerous goods declarations, software and shipping instructions may all need to be updated.
Testing remains essential
Battery safety regulation begins long before a package reaches a port.
Lithium batteries offered for transport generally have to meet the applicable testing requirements in the UN Manual of Tests and Criteria. These tests are intended to demonstrate that a battery design can withstand conditions associated with transport, including pressure differences, temperature extremes, vibration, shock and other stresses.
The test summary is therefore an important part of the compliance chain for lithium batteries.
Dangerous goods professionals should not treat battery documentation as a purely administrative matter. The classification and transport conditions depend on the characteristics of the actual battery being shipped.
This principle becomes even more important as the number of battery technologies and configurations increases.
A company receiving batteries from several manufacturers should have procedures to ensure that the required technical information is available. Simply relying on a commercial product description such as “rechargeable battery” or “energy storage unit” is not sufficient to establish the correct IMDG classification.
Damaged and defective batteries remain a higher-risk category
The condition of a battery can be just as important as its chemistry.
A battery that has been damaged in an accident, overheated, suffered mechanical deformation, developed internal defects or otherwise presents an increased risk cannot automatically be transported under the same conditions as a new battery in normal condition.
This is particularly important in reverse logistics.
Companies increasingly handle returned electronic equipment, used batteries, damaged electric vehicles, recycling streams and batteries removed from industrial equipment. These logistics operations can create circumstances in which the original packaging is no longer available and the condition of the battery is uncertain.
Personnel accepting such goods need to recognise that a damaged battery requires additional assessment.
The safest compliance procedure is therefore not merely to ask what type of battery is involved, but also to establish its condition and transport history.
Packing and protection against short circuits remain fundamental
Correct classification does not make a battery shipment safe by itself.
Batteries must also be packed in accordance with the applicable IMDG provisions. One of the fundamental objectives is preventing movement and accidental activation while also protecting terminals against short circuits.
A loose battery terminal contacting conductive material can create a short circuit and generate substantial heat. For this reason, protection of terminals, appropriate inner packaging, cushioning and securing can be essential elements of compliant battery transport.
The applicable packing instruction depends on the specific UN entry and circumstances of the shipment.
Companies moving from IMDG 42-24 to 43-26 should therefore review packing procedures together with classification. Updating a UN number in shipping software while leaving warehouse instructions unchanged can create a compliance gap.
Marks, labels and documentation must follow the classification
Once the correct classification and packing provisions have been established, the shipper must determine the appropriate marking, labelling and documentation requirements.
Battery consignments may require the Class 9 hazard label or battery-specific marking depending on the entry and provisions being used. Packages must also carry the required identification information.
Where a dangerous goods transport document is required, the description must correspond with the applicable IMDG classification.
This is another reason why battery classification should be controlled centrally. If the technical department, warehouse and shipping department use different product information, discrepancies can occur between the battery being transported, the package markings and the dangerous goods declaration.
Amendment 43-26 provides a good opportunity for companies to verify that these processes are connected.
What should companies do before IMDG 43-26?
The transition to Amendment 43-26 should begin with a review of all battery-related products being shipped by sea.
Companies should establish whether they handle lithium metal batteries, lithium-ion batteries, sodium-ion batteries, equipment containing batteries, batteries packed with equipment, battery systems, prototypes, production runs, used batteries or damaged and defective batteries.
The relevant UN entries and special provisions can then be checked against the new edition.
Particular attention should be given to newer sodium-ion products and energy storage systems. These products may have been introduced into a company’s inventory relatively recently and dangerous goods master data may not yet have received the same level of review as established lithium battery products.
Shipping software, standard operating procedures, packaging instructions, dangerous goods documentation and training material should subsequently be updated where necessary.
Train personnel handling battery shipments
Battery transport demonstrates why function-specific dangerous goods knowledge is essential. Employees need to understand not only that lithium and sodium-ion batteries can be regulated, but also how their own activities influence compliance.
IMDG-course.com provides online maritime dangerous goods training for employees involved in preparing, handling and transporting dangerous goods by sea.
For personnel requiring a general understanding of the IMDG Code, the IMDG Awareness Training provides a practical introduction to dangerous goods classification, marking, labelling, packaging, documentation and maritime transport requirements.
Companies preparing for IMDG 43-26 can use the transition period to review which employees handle lithium and sodium-ion batteries and whether their training reflects the functions they actually perform.
Prepare your personnel for IMDG 43-26 and view the IMDG Awareness Training available through IMDG-course.com.
Lithium and sodium-ion batteries will remain a regulatory priority
The changes surrounding batteries in IMDG 43-26 reflect a much larger development in global logistics. The number, size and variety of batteries transported internationally continue to increase as electrification expands across consumer electronics, vehicles, industrial equipment and energy storage.
Lithium batteries therefore remain a major dangerous goods issue, while sodium-ion batteries are becoming increasingly relevant.
For shippers, the practical response should be to improve the quality of battery information throughout the supply chain. Correct chemistry, UN number, configuration, test status, condition, packing method and documentation must all correspond with the battery actually being transported.
Amendment 43-26 should therefore not be approached simply as another regulatory update. It is an opportunity for organisations to review whether their battery transport procedures are keeping pace with rapidly changing technology.
Companies that identify their lithium and sodium-ion battery flows now, review the relevant entries under IMDG 43-26 and train personnel accordingly will be better prepared for the next phase of maritime battery transport.
