Short answer: E-bike batteries leave China as Class 9 dangerous goods under the IMDG Code — UN3481 when the pack is fitted to the bicycle or boxed with it, UN3480 when packs travel alone — both under packing instruction P903. Every cell and battery type must have passed UN 38.3 tests T1 to T8, and since 1 January 2020 a UN 38.3 Test Summary must be available for each type. Under IMDG amendment 41-22, mandatory from 1 January 2024, UN3480 batteries offered for sea transport must not exceed 30 percent of rated capacity. The booking needs a multimodal Dangerous Goods Declaration, a Safety Data Sheet, a 1.2 m drop-test report and the Class 9 lithium battery mark on every carton.
Is an e-bike battery really dangerous goods?
At bicycle sizes, always. E-bike packs are typically 300 to 1000 Wh, far above the 100 Wh threshold that separates small consumer cells from full dangerous goods, so they never qualify as excepted. Factory, forwarder, carrier, terminal and trucker all handle them as dangerous goods. The battery, not the bicycle, decides your schedule.
UN3480 or UN3481 — which UN number do you declare?
The UN number follows how the pack travels. UN3480 covers batteries shipped alone: spares, replacement stock, a pallet of packs for a service programme. UN3481 covers batteries packed with equipment or contained in equipment — boxed beside the e-bike, or installed in the frame. Both are Class 9 under P903, but the consequences differ sharply.
| Point | UN3480 (batteries alone) | UN3481 (with or in the e-bike) |
| Typical cargo | Spare and replacement packs | Complete e-bikes, pack fitted or boxed |
| Class and packing instruction | Class 9, P903 | Class 9, P903 |
| State of charge by sea | Maximum 30 percent of rated capacity | No IMDG cap; many carriers impose one |
| Passenger aircraft | Forbidden — cargo aircraft only | Permitted under IATA DGR conditions |
| HS code at export | 8507.60 lithium-ion accumulators | 8711.60 electric bicycles |
| Damaged or recalled units | Forbidden by air; special approval by sea | Forbidden by air; special approval by sea |
What is UN 38.3, and why does the Test Summary decide whether you ship?
UN 38.3 is the section of the UN Manual of Tests and Criteria that qualifies a lithium cell or battery for transport. It is mandatory and it is eight tests: T1 altitude simulation, T2 thermal test, T3 vibration, T4 shock, T5 external short circuit, T6 impact or crush, T7 overcharge, T8 forced discharge.
Since 1 January 2020 the manufacturer or distributor must make a UN 38.3 Test Summary available for every cell and battery type: manufacturer and contact, description, watt-hour rating, test report number and date, the revision of the Manual applied, and a signature. Note the trap — a redesign with a different cell supplier, BMS or capacity is a new type needing its own summary, and one missing summary strands a loaded container at the gate.
Why 30 percent state of charge, and what changed in 2024?
IMDG Code amendment 41-22, mandatory from 1 January 2024, requires UN3480 lithium-ion batteries offered for sea transport to be at a state of charge not exceeding 30 percent of rated capacity. The logic is stored energy: a pack at 30 percent has far less fuel to sustain a thermal runaway in a container stack at sea.
Make the state of charge a written instruction to the factory: on the packing list and the QC report, with a signed statement at booking if the carrier asks. Packs under UN3481 are not covered by the 30 percent rule, but several carriers apply their own limit, so confirm the service you are booking.
Which documents must exist before the container loads?
- Multimodal Dangerous Goods Declaration — shipping name, UN number, Class 9, P903, packages, net quantity, emergency contact.
- UN 38.3 Test Summary for every cell type and battery type in the container.
- Safety Data Sheet in the required language, matching the exact pack model.
- Package drop-test report showing a 1.2 m drop in shipping configuration with no damage, shifting of contents or release.
- Class 9 lithium battery mark with the UN number on each carton, the hazard label where required, and a container packing certificate.
How does a dangerous goods booking differ from ordinary bikes?
Carriers allocate limited DG slots per vessel and approve them case by case, so a Class 9 booking goes in earlier than general cargo — two to three weeks before cut-off rather than a few days, with the occasional vessel refused. Damaged, defective or recalled batteries are forbidden by air and need special approval by sea, so design the warranty flow in advance. E-bike programmes usually start at 25 to 50 units, and a mixed container is declared as dangerous goods in full.
What happens after discharge?
The mode changes, the seriousness does not. The European road leg is governed by ADR, so the receiving trucker, driver training and placarding must be arranged in advance. Some transhipment ports restrict Class 9 lithium transit altogether, so routing is confirmed at booking — a refused transhipment leaves your container in a third country at your cost.
Frequently asked questions
Can e-bikes with batteries installed be shipped by sea from China?
Yes. Batteries installed in the bicycle ship as UN3481, Class 9, packing instruction P903 under the IMDG Code. The consignment needs a dangerous goods declaration, UN 38.3 Test Summaries, a Safety Data Sheet and correct carton marking, booked as dangerous goods.
What is the maximum state of charge for lithium batteries shipped by sea?
Since IMDG amendment 41-22 became mandatory on 1 January 2024, UN3480 lithium-ion batteries offered for sea transport must not exceed 30 percent of rated capacity. UN3481 shipments have no such cap in the Code, but carriers frequently impose one. Confirm the limit on your service.
Who issues the UN 38.3 Test Summary?
The cell or battery manufacturer, or the distributor placing it on the market, must make the summary available for every cell and battery type, based on testing by a competent laboratory. If your supplier changes cells, BMS or capacity, the earlier summary no longer covers the pack.
Can e-bike batteries be shipped by air?
Only under strict conditions, and UN3480 alone is forbidden on passenger aircraft — cargo aircraft only. Packs of 300 to 1000 Wh fall under IATA DGR Section IA or IB, so air freight is slow to approve and rarely practical in volume. Sea freight is the normal route.
What happens if the UN 38.3 documents are missing at the port?
The carrier refuses the dangerous goods declaration and the container does not load. Cargo already at the terminal accrues storage and demurrage, and the booking rolls to a later vessel. Collect the full document pack before the cargo leaves the plant.
Can damaged or recalled e-bike batteries be returned to China?
Not routinely. Damaged, defective or recalled lithium batteries are forbidden for air transport and require special approval and dedicated packaging by sea. Plan warranty handling in the destination market and agree the process with your supplier in the contract.
Getting your first e-bike container right
Stranded lithium shipments fail on paperwork, not on the battery: a missing test summary, an undeclared state of charge, a transhipment port that never allowed Class 9 transit. Settle the UN number, the SoC, the documents and the routing at booking. See our e-bike and bicycle range.
