UN 38.3, SDS and DG Declaration: Shipping Emergency Lights with Lithium Batteries

Short answer: an emergency luminaire with a built-in lithium battery is a dangerous-goods consignment, not ordinary lighting cargo. Before booking, prepare four things: a written UN 38.3 test summary for the exact cell or battery model, a safety data sheet (SDS/MSDS), the correct dangerous-goods declaration or lithium battery statement, and compliant packing, marking and labelling.

1. Why a light fitting becomes "dangerous goods"

The risk is the cell, not the LED. Lithium cells can short-circuit, overheat or enter thermal runaway if damaged or incorrectly packed, so air (IATA DGR), sea (IMDG Code), road (ADR / 49 CFR) and courier networks all apply lithium-battery rules. Two UN numbers matter for our industry:

• UN3481 — lithium ion batteries packed with equipment or contained in equipment. This is the usual case for a self-contained emergency light or exit sign shipped assembled.
• UN3480 — lithium ion batteries shipped on their own, e.g. a carton of replacement battery packs.

Classify the shipment before choosing a route. "Section II" or "excepted" is a reduced set of requirements, not an exemption: the lithium battery mark, a transport document with the required wording and compliant packing still apply.

2. The document set your forwarder will ask for

UN 38.3 test summary

Since 2020, a written test summary must be made available on request — a bare statement "complies with UN 38.3" on a specification sheet is not enough. The summary should identify the cell/battery manufacturer and the test laboratory, carry a unique report number and date, describe the cell or battery in detail, list the tests and results, reference the revision of the UN Manual of Tests and Criteria used, and be signed by an authorised person. It must cover the actual model being shipped, not a "similar" battery.

Sub-section 38.3 comprises eight tests: T1 altitude simulation, T2 thermal test, T3 vibration, T4 shock, T5 external short circuit, T6 impact/crush, T7 overcharge and T8 forced discharge.

Safety data sheet (SDS / MSDS)

The SDS identifies the chemistry, watt-hour rating, lithium content, handling, storage and emergency response. Many carriers and customs authorities request it as supporting documentation; keep it current with the applicable GHS revision.

Dangerous goods declaration

A shipper's declaration is required for fully regulated air and sea consignments and states the proper shipping name, UN number, class, quantity and packing instruction. For small "excepted" batteries a full declaration may not be required, but the airway bill still needs the prescribed lithium battery statement.

Commercial documents and marks

Commercial invoice, packing list and bill of lading / airway bill, plus the Class 9 lithium battery mark on the outer package with the UN number and a reachable emergency telephone number. For imports, check whether the destination also asks for battery conformity evidence such as IEC 62133 or local registration.

3. The watt-hour line and what it changes

Classification depends on nominal energy, not ampere-hours: Wh = nominal voltage (V) × capacity (Ah). A 3.2 V 1.8 Ah LiFePO4 pack is 5.76 Wh; a 3.2 V 4 Ah pack is 12.8 Wh. Both are well under the 100 Wh threshold that separates Section I from Section II for many air shipments. Large central battery systems above 100 Wh move into fully regulated Class 9 territory with UN-approved packaging and significantly higher freight cost. Always recompute Wh from the datasheet rather than copying a number from an old SDS.

4. Packing, state of charge and labelling

• Protect every battery against short circuit: insulated terminals, individual inner packaging or dividers, and no loose cells in a carton.
• Use strong outer packaging that withstands a 1.2 m drop test where required, with cushioning that stops movement. Equipment must be secured so a switch cannot be activated in transit.
• Where batteries are shipped outside the fitting, they need separate non-conductive inner packaging. Watch the cable glands and gasket line: on sealed luminaires these are common failure points.
• For UN3480 Section II air shipments, cells and batteries must be offered at a state of charge not exceeding 30% of rated capacity. Do not generalise this rule to assembled UN3481 goods without checking the current packing instruction with your carrier.
• Damaged, defective or recalled batteries require special packaging and prior carrier approval.

5. Why LiFePO4 matters in this conversation

Lithium iron phosphate is widely used in self-contained emergency fittings because of its thermal stability and long cycle life compared with conventional lithium-ion chemistries. It reduces risk in a warm container, but it does not remove the classification: a LiFePO4 cell is still a lithium ion cell and still needs UN 38.3 documentation. Ask for the test summary for the specific cell used in your SKU.

6. A checklist to send your supplier

• UN 38.3 test summary (report number, lab, date, exact cell/battery model).
• SDS with chemistry, Wh rating and emergency contact.
• Declared UN number and packing instruction for the planned transport mode.
• Photos of inner packing, outer carton and the lithium battery mark.
• State-of-charge declaration for air freight where applicable.
• Confirmation that the documents match the SKUs on the commercial invoice.

Quick answers

Is a CE or RoHS certificate enough to ship an emergency light?

No. Those are product compliance documents. Transport requires UN 38.3, SDS and the applicable dangerous-goods paperwork for the battery.

Can we ship assembled emergency lights as normal cargo?

Usually they are UN3481 (batteries contained in equipment) and still carry lithium-battery marking and documentation obligations. Confirm the section and packing instruction with the carrier before booking.

Does a test report for a similar battery model work?

No. The test summary must cover the specific cell or battery model being shipped. A generic report is a common reason for rejected shipments.

About Anshine — JiangMen Anshine Technology Co., Ltd. is a Jiangmen, Guangdong-based manufacturer of LED emergency luminaires, exit signs and emergency power supplies for B2B buyers. The company was registered in 2025; our founding team has about 20 years of experience in the emergency lighting industry. To request documentation for a specific model, use the enquiry form on this website.

Standards and transport rules change. This article is general buying guidance, not a declaration of conformity or legal advice. Verify the current edition of each standard, the applicable national annex and the requirements of the authority having jurisdiction, and always request SKU-specific documents before placing an order.