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Do Lithium Battery Exports from China Need a DG Certificate?

No — not every lithium battery shipment leaving China needs one. Two situations exempt it: a battery installed inside the vehicle it powers, and a battery small enough to sit inside Special Provision 188. Everything outside those two lines needs the certificate, and the exemption itself comes with packaging conditions most suppliers never read.

Which shipments need the certificate

The order is negotiated, the goods are boxed, and then the forwarder asks for the certificate. Or the supplier says the battery is exempt and you want to know whether that is true. The table below settles the common cases before the detail.

Certificate requirement by shipment type
Your shipmentCertificate needed?
Battery bolted inside an e-bike, scooter or wheelchairNo
Lithium-ion cell 20 Wh or less, battery 100 Wh or lessNo
Lithium-metal cell 1 g or less, battery 2 g or lessNo
Any rating above those limitsYes
Battery taken out of the vehicle and boxed on its ownYes

What the certificate appraises

The full name is the Export Dangerous Goods Transport Packaging Use Appraisal Certificate. Chinese suppliers shorten it to weibao zheng and quote it in English as “dangerous packaging certificate” or “DG package certificate.”

It appraises the packaging, not the battery inside it. A customs officer inspects the cartons, drums or crates to confirm they can carry a Class 9 product through a sea voyage, then issues the certificate against that specific packaging design. Change the carton and the certificate no longer covers what is in the container.

That ordering matters when you are buying. The packaging supplier first obtains a performance test result for the carton. Your battery supplier packs against that result, a laboratory issues a transport conditions appraisal for the product, and only then does the local customs district issue the use appraisal. Skip a link and the chain does not close.

Exemption one: battery installed in the vehicle

A battery fitted inside an electric bicycle, scooter, wheelchair or similar lithium-powered vehicle ships under UN3171. There is no separate export package to appraise, because the vehicle is the packaging. Customs does not ask for the certificate.

This is the exemption that causes the most expensive misunderstandings. Order the same e-bike with the battery unbolted and boxed as a separate item and the battery returns to UN3480. The certificate becomes mandatory, and the shipment now carries two classifications instead of one. Splitting a shipment to save volume is common, and it quietly turns an exempt order into a regulated one.

Energy storage cabinets land in the same practical place for a different reason. A cabinet shipped as a finished unit with no outer packaging falls outside the scope of packaging appraisal, so there is nothing for customs to certify against.

Exemption two: Special Provision 188

The UN Model Regulations carve out small batteries in Special Provision 188, and the IMDG Code applies the same rule at sea. Both the cell and the battery have to fit under the limit. Passing on one and failing on the other does not work.

Lithium-ion20 Whper cell, or less
Lithium-ion100 Whper battery, or less
Lithium-metal1 glithium per cell, or less
Lithium-metal2 glithium per battery, or less
Special Provision 188 thresholds
ChemistryCell limitBattery limit
Lithium-ion20 Wh or less100 Wh or less
Lithium-metal or lithium alloy1 g lithium or less2 g lithium or less

Above either row the shipment is fully regulated Class 9 — UN3480 for lithium-ion shipped on its own, UN3090 for lithium metal — and the packaging certificate is mandatory.

Falling under both limits is necessary but not sufficient. Special Provision 188 attaches other conditions, and a supplier who quotes only the watt-hour number has usually stopped reading halfway:

Packaging rules that still apply

Exemption does not mean the outer packaging can be whatever is cheapest. Two requirements survive it.

The first is the lithium battery mark. Every package carries the compliant mark, sized and applied as the regulations specify, not a printed sticker the factory designed itself.

The second is physical protection. The packaging has to be strong enough to prevent short circuit, prevent damage, and prevent the equipment from activating accidentally in transit. A battery loose in a thin carton with no terminal protection fails that test even though its watt-hour rating passes.

Both requirements are checked at the port, not at the factory. A shipment held for a missing or undersized mark is a shipment that misses its vessel.

Not exempt from dangerous goods rules

This is the part that catches exporters. Every lithium battery, whatever its size, still has to be declared with its dangerous goods information. Filing a sub-100 Wh battery as general cargo is a misdeclaration, and it is the kind that gets a container pulled at Yantian or Shekou while the paperwork is rebuilt.

Air freight adds a layer rather than removing one. The ICAO technical instructions and each airline’s acceptance rules sit on top of the sea thresholds, and several carriers refuse UN3480 outright on passenger aircraft. A supplier who has confirmed a sea booking does not thereby hold an air booking.

The document pack

Documents behind a regulated lithium battery export
DocumentIssued byWhat it proves
UN38.3 test summaryAccredited testing laboratoryThe cell and battery passed the UN transport tests
Safety data sheetBattery manufacturerChemistry, hazards, handling
Transport conditions appraisalAuthorised inspection bodyWhich regulation the product falls under
Packaging performance certificatePackaging manufacturerThe carton design passed drop and stack tests
Packaging use appraisal certificateLocal customs districtThis shipment’s packaging is fit for Class 9
Dangerous goods declarationDeclarant or forwarderThe booking is filed as Class 9

Assembling this takes longer than the ocean transit on a first shipment. Buyers who request it while production is still running usually sail on the planned vessel. Buyers who ask once the container is at the gate usually do not.

Three ways shipments get stuck

The watt-hour figure does not match the paperwork. A battery sold as 100 Wh but printed 99 Wh, or a pack whose rating was calculated differently from the test summary. Customs reads the printed number against the certificate.

The packaging changed after certification. Same battery, new carton supplier, thinner foam. The certificate names a packaging design, so the shipment no longer matches the document.

The battery came out of the vehicle to save freight. A shipment that would have moved as UN3171 becomes UN3480, and the certificate that was never needed is suddenly required. The saving rarely covers the delay.

How we book battery cargo

We handle FCL and LCL port to port from Shenzhen, Shanghai and Ningbo, and air freight to destination airports. Battery bookings start with three questions before any rate is quoted:

Those answers fix the UN number, whether the certificate is in scope, and which carriers will accept the booking on your lane. Carriers differ: some take Class 9 in limited quantity only, some take full UN3480, some refuse it entirely. We route to the ones that accept your actual classification rather than the one your supplier hoped for.

FAQ

Is a power bank rated exactly 100 Wh exempt?

Yes. Special Provision 188 reads “not more than 100 Wh,” so 100 Wh sits inside the exemption. At 101 Wh the shipment becomes fully regulated Class 9.

How do I convert mAh to Wh?

Multiply amp-hours by voltage. A 20,000 mAh power bank at 3.7 V is 20 Ah × 3.7 V = 74 Wh, comfortably under the limit. A 27,000 mAh pack at the same voltage lands at 99.9 Wh, which is why that figure appears so often on power bank labels.

My battery is 101 Wh. What changes?

The shipment becomes UN3480 Class 9, the packaging certificate is mandatory, a dangerous goods declaration is required, and the freight rate rises because fewer carriers and slots accept it. There is no rounding down that survives a port inspection.

Does air freight avoid the certificate?

No. Air freight adds requirements rather than removing them, and the airline will ask for the UN38.3 summary plus its own acceptance conditions.

Is the exemption judged per battery or per package?

On the cell and battery rating. A carton holding forty 50 Wh batteries stays exempt on rating, though each package still needs the lithium battery mark and a declaration.

The battery ships separately from the e-bike. Does it need the certificate?

Yes. Once the battery leaves the vehicle frame it is UN3480, which is the case Chinese customs states explicitly in its guidance on e-bike exports.

We are exempt. Can the packaging be basic?

It has to meet the packaging conditions: the lithium battery mark on every package, and construction that prevents short circuit, damage and accidental activation. Cheap and thin fails that test.

What happens if the container is already at the port without a certificate?

It does not load. Customs verifies the certificate against the actual cargo at the port of export — packaging type, UN mark, battery marking, quantity. The document chain has to be rebuilt, and the vessel is gone.

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