Returned e-bike batteries with two scorched packs
A distributor of electric bicycles is returning 300 used battery packs to the manufacturer for refurbishment. Each pack is rated 48 V, 20 Ah (about 960 Wh) and contains lithium-ion cells. 280 packs look intact; 20 were pulled from bikes after a charging fault and show swollen casings, and two of those have scorch marks. The forwarder proposes to book the whole lot as "UN 3480, Lithium ion batteries, Class 9, Section II - no dangerous goods declaration needed, they are used and are not for sale". The forwarder also plans to ship them at whatever state of charge they were returned in, loose in one 40 ft container with no inner packaging and no separation between the damaged and undamaged units.
1. Is Section II of the lithium battery packing instruction available for these 960 Wh packs? State what applies instead.
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No. Section II reliefs exist only for small cells and batteries - the threshold for lithium ion batteries is 100 Wh per battery (20 Wh per cell) - and they also carry package mass limits. At roughly 960 Wh these packs are an order of magnitude above the threshold, so they are fully regulated Class 9 dangerous goods, UN 3480, packed under the Section I requirements of the applicable packing instruction, with a Class 9 label, the UN number marked on the package, inner packagings, and a dangerous goods declaration.
Being "used" changes nothing: the classification criteria apply to the article, not to its commercial status, and a returned pack is still a lithium ion battery. "Not for sale" is irrelevant to the Code.
Two further points follow from shipping them as UN 3480 alone rather than packed with or contained in equipment: the state-of-charge limit (batteries must be at no more than 30 % state of charge) applies, and the packs must be protected against short circuit and movement inside the package. The loose-in-a-container plan fails on both counts.
2. How must the 20 swollen and scorched packs be handled? Give the classification, packing and documentation consequences.
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They are damaged/defective lithium ion batteries and fall under the special provision for cells and batteries that are damaged or defective, or that are liable to rapidly disassemble, react dangerously or produce flame or a dangerous evolution of heat. They stay Class 9, UN 3480, but the packaging must be the one specified for damaged/defective cells and batteries (P908, or P911 where they are liable to rapidly disassemble), and the condition must be declared - the transport document has to identify them as damaged/defective.
Before anything is packed, someone competent must assess whether each pack can be transported at all. A pack that cannot be packed to the applicable instruction, or that is still evolving heat, must not be loaded; it needs to be made safe or dealt with as waste locally. The two scorched units should be treated as the highest-risk items and physically isolated from the rest.
Practically: the 280 sound packs and the 20 damaged packs go as two separate consignments with separate declarations, not one container of loose batteries. The forwarder's plan must be rejected before the container is stuffed, not corrected at the quay.
3. What should the declaration and the stowage plan show, and what would you tell the forwarder about the state of charge?
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The declaration needs, for each line: UN 3480, LITHIUM ION BATTERIES, Class 9, the packing instruction and section used, the number and kind of packages, net and gross mass, the 24-hour emergency telephone number, and the consignor's signature. The damaged/defective line must say so in the proper shipping name field. Stowage follows the Dangerous Goods List entry - check the stowage category and any segregation code - and, as a minimum, batteries go away from heat sources and ignition sources and are protected from short circuit and mechanical damage.
The state of charge point: UN 3480 batteries shipped on their own must be at no more than 30 % state of charge. "Whatever they were returned in" is not a plan; the consignor must measure and, where needed, discharge to the limit before packing, and record it. If the forwarder cannot show that this was done, the consignment is not ready to load.