UN 38.3 Lithium Battery Testing

If you source consumer electronics, promotional products or toys with a lithium cell or battery from China, UN 38.3 testing is not optional. It is the transport safety protocol that every lithium cell must pass before it can ship by air, sea, road or rail, and it sits alongside product safety standards, marketplace requirements and Amazon's own Dangerous Goods programme. This guide to lithium battery testing walks through UN 38.3, the eight tests behind it, how it differs from IEC 62133-2 and UL 1642, what the test summary actually is, which products fall in scope, and what an importer can verify at the factory before the container leaves. For the wider FBA context these tests fit into, see the Amazon FBA requirements guide.

1. What UN 38.3 Actually Is (and Why Every Lithium Battery Ships Under It)

UN 38.3 testing is the international transport safety test protocol for lithium metal and lithium-ion cells and batteries, set out in Sub-section 38.3 of the UN Manual of Tests and Criteria. The current applicable reference is the eighth revised edition, published in 2023, with Amendment 1 dated 12 September 2025. Every lithium cell or battery shipped anywhere in the world, whether on its own or built into a device, is classed as Class 9 miscellaneous dangerous goods under the UN Model Regulations on the Transport of Dangerous Goods, currently in their 23rd revised edition, regardless of chemistry.

Four UN transport classifications cover the different shipping configurations:

• UN 3090: lithium metal batteries shipped by themselves.
• UN 3480: lithium-ion batteries shipped by themselves.
• UN 3091: lithium metal batteries contained in or packed with equipment.
• UN 3481: lithium-ion batteries contained in or packed with equipment.

UN 38.3 has been adopted into the IATA Dangerous Goods Regulations for air transport, the IMDG Code for sea transport, ADR and RID for road and rail transport in Europe, and US federal hazmat regulations under 49 CFR Parts 171 to 180. US practice sometimes calls it UN/DOT 38.3; this guide uses UN 38.3 throughout. For the ocean and air freight side of getting a battery product from a factory in China to a US warehouse, see shipping lithium battery products from China.

2. The Eight UN 38.3 Tests (T.1 to T.8), Named and Explained

UN 38.3 testing comprises eight tests, run in sequence on the same set of cells or batteries for T.1 through T.5, then separate targeted tests for T.6, T.7 and T.8 depending on the cell type. The table below names each test and its purpose. The full test parameters (drop heights, voltages, temperatures, forces, pressures, frequencies) sit inside the UN Manual of Tests and Criteria itself, a paid reference document, and are not reproduced here.

Test	Name	What it simulates	Applies to
T.1	Altitude Simulation	Low-pressure conditions during air transport	All cells and batteries
T.2	Thermal Test	Rapid and extreme temperature cycling	All cells and batteries
T.3	Vibration	Vibration during road, rail, air and sea transport	All cells and batteries
T.4	Shock	Mechanical shock during handling and transport	All cells and batteries
T.5	External Short Circuit	External short circuit at elevated temperature	All cells and batteries
T.6	Impact or Crush	Mechanical abuse that could cause an internal short	Component cells
T.7	Overcharge	Overcharge conditions on rechargeable batteries	Rechargeable batteries only
T.8	Forced Discharge	Forced discharge on cells	Primary and secondary cells

Cells and batteries pass if they show no leaking, venting, disassembly, rupture or fire, and if the open-circuit voltage of each cell or battery is not less than 90 percent of its voltage immediately before the test. Because T.1 to T.5 run sequentially on the same samples, a failure at T.1 fails the whole T.1 to T.5 sequence for that batch of samples, and testing has to restart with a fresh set.

3. UN 38.3 vs IEC 62133-2: Transport Safety vs Product Safety

These two standards are frequently confused. UN 38.3 is about surviving the truck, the ship and the aircraft. IEC 62133-2 is about surviving the customer.

UN 38.3	IEC 62133-2:2017 + AMD1:2021
Transport safety	Product safety in normal use and reasonably foreseeable misuse
Sub-section 38.3 of the UN Manual of Tests and Criteria	International Electrotechnical Commission (IEC) standard
Mandatory worldwide for shipping	Mandatory for placing on the EU market, widely required across Asia Pacific
Eight tests, T.1 to T.8	Multiple test categories: mechanical, thermal, electrical, environmental, endurance
Cell manufacturer responsibility	Cell and finished-product manufacturer responsibility
Test summary document	Certificate of compliance from a recognised testing body
Class 9 dangerous goods classification	Product safety mark supporting CE, RCM and market access
Reference for IATA DGR, IMDG, ADR, RID	Reference for consumer electronics directive compliance (EU LVD and RED where applicable)

Most consumer electronics products with lithium batteries need both. UN 38.3 clears the product to ship. IEC 62133-2 clears it to sell in the EU and most Asia Pacific markets. IEC 62133-2 also has a European harmonised version, EN 62133-2, used for CE marking presumption of conformity, and a related standard, IEC 62133-1:2017, for portable sealed nickel-based cells rather than lithium. For the US market, a third overlay applies: see UL 1642 in the next section.

Not sure whether your product needs UN 38.3 alone, IEC 62133-2 as well, or both plus an NRTL mark for the US market? AQF's team scopes the compliance package with you before dispatching an inspector, and coordinates test work with an ISO 17025-accredited partner lab. Share the product category, target markets and the factory name, and we come back with a fitted plan.

Get a Lithium Battery Compliance Inspection Quote for Your Factory in Asia

4. IATA Dangerous Goods Regulations 2026: State of Charge, Cargo-Only, Class 9

IATA publishes the Dangerous Goods Regulations annually. The 2026 edition is the 67th edition, applicable from 1 January 2026, and it remains the industry reference for air shipment of dangerous goods, built on the ICAO Technical Instructions for the Safe Transport of Dangerous Goods by Air.

For lithium batteries shipped by air as cargo, the key requirements are:

• State of charge: lithium-ion cells and batteries shipped by themselves (UN 3480) must be set at a state of charge, or SoC, the battery's charge level as a percentage of its rated capacity, not exceeding 30 percent. This is a hard requirement.
• Cargo Aircraft Only: standalone lithium-ion shipments must carry the Cargo Aircraft Only label; passenger aircraft transport of standalone cells and batteries is prohibited.
• Class 9 hazard label: mandatory on the outer packaging for miscellaneous dangerous goods.
• Lithium battery mark: the standard black-and-red UN 38.3 lithium battery marking is required on packages containing lithium batteries under most transport modes.
• UN specification packaging: required for cells and batteries above the small excepted-quantity thresholds.

The shipper must have a UN 38.3 test summary on file and available on request from carriers, freight forwarders, customs or the competent authority, and anyone shipping lithium batteries by air needs training under IATA DGR requirements, or under 49 CFR Part 172 Subpart H for US-origin shipments. For the outer carton, labelling and dangerous goods packaging side of a lithium battery shipment, see our packaging testing guide, and for how these requirements sit alongside Amazon's own SIPP packaging programme, see the ISTA 6-Amazon SIPP certification guide.

5. UL 1642 and the US Marketplace Overlay

For US-bound lithium battery products, the marketplace commonly asks for a UL 1642 or UL 2054 mark on top of UN 38.3. Neither is a federal legal requirement, but Amazon treats them as marketplace requirements for many electrical categories.

UL 1642 is the Underwriters Laboratories standard for lithium cells, both primary and secondary. It is a product safety standard for the cell itself, not the finished product. UL 2054 is the companion standard for household and commercial batteries, covering the pack rather than the cell, and is often bundled with UL 1642 for a finished product built around a lithium battery pack. UL is a private organisation, and one of several OSHA-recognised Nationally Recognized Testing Laboratories, or NRTLs; other NRTLs include competing testing firms. Amazon generally accepts a mark from any NRTL for the categories that require one.

UL 1642 and UL 2054 are US marketplace standards. They do not replace UN 38.3, a transport requirement, and they do not replace IEC 62133-2, which covers EU and Asia Pacific product safety. A finished product sold globally may need all three programmes at once. Amazon commonly asks for a UN 38.3 test report and an SDS for its FBA Dangerous Goods approval, and for categories such as small appliances, e-mobility and hoverboards, also commonly asks for an NRTL mark such as UL 1642, UL 2054, UL 2272 or UL 2849. For the UL, FCC and other marketplace marks Amazon commonly requests across electronics categories, see the Amazon product testing guide. Where new test work is needed against any of these standards, it runs through AQF's lab testing coordination.

6. The UN 38.3 Test Summary: What It Is, Who Signs It, When You Need It

The UN 38.3 test summary is the document you actually need to see, read, file and forward. It is not the full test report. It is a standardised summary of the test results, signed by the responsible party.

The summary sets out the cell or battery identification (manufacturer, model, part number), the result of each test from T.1 to T.8, a reference to the underlying test report, and the name, title and signature of the responsible party. That party is the cell manufacturer for standalone cells, the battery pack manufacturer for packs assembled from tested cells, or the responsible entity as defined in the UN Model Regulations.

Since 1 January 2020, the test summary shall be made available on request across the supply chain, which means a shipper, an importer, a freight forwarder or an Amazon FBA reviewer can ask for it and must receive it. In the United States, the Department of Transportation, through PHMSA, formally implemented the test summary requirement on 1 January 2022, then revised the reference publication on 10 May 2024.

A common pattern: the seller asks the factory for the UN 38.3 report, and the factory sends a test summary of the battery cell, sometimes in Chinese, sometimes on an older template. Before relying on it, an importer should verify that the cell reference matches the cell actually assembled in the finished product, that the responsible party listed is a real, contactable entity, that a signature and title are present, and that the summary references the current applicable edition of the UN Manual of Tests and Criteria (the eighth revised edition plus Amendment 1). For how this document fits into the wider paperwork package for a shipment leaving China, see shipping lithium battery products from China.

7. Products in Scope: Consumer Electronics, Promotional Products, Toys, Medical

If your product stores or generates electrical energy in a lithium chemistry, it ships under UN 38.3. That covers more categories than most importers realise.

Product category	Typical lithium content	Additional overlays
Consumer electronics (phones, tablets, laptops, wireless speakers, headphones, power banks, wireless mice, LED torches)	Lithium-ion rechargeable, various capacities	IEC 62133-2, UL 1642/2054, FCC where RF radio is present
Small appliances (hair clippers, hair dryers, blenders, hand vacuums, electric toothbrushes)	Lithium-ion rechargeable	IEC 62133-2, NRTL mark for Amazon US
Toys (electric ride-on cars, RC vehicles, robotic toys, doll accessories with lights)	Lithium-ion and coin cells	ASTM F963, EN 71-3, CPSIA
Children's products with batteries	Various lithium chemistries	Reese's Law and ANSI/UL 4200A for button cells
Promotional products with embedded lights, USB power banks, wireless speakers	Lithium-ion and coin cells	Same as consumer electronics, plus CPSIA where the audience is children
Medical devices (glucose meters, portable diagnostic tools, hearing aids)	Lithium metal and lithium-ion	FDA 510(k), ISO 13485, IEC 60601
E-mobility (e-scooters, hoverboards, e-bikes)	Large lithium-ion packs	UL 2272, UL 2849, UN 38.3 mandatory
Vape and heating devices	Small lithium-ion	UN 38.3, FDA PMTA

Power banks are the single most common category triggering FBA Dangerous Goods review rejections, usually because the SDS is missing or misformatted rather than because the cell itself is unsafe. For the wider Amazon Dangerous Goods context this table sits inside, see the Amazon FBA requirements guide. For children's products specifically, see the CPSIA compliance guide and the toy safety testing guide. For promotional items built around a battery, see our promotional product inspection guide.

8. The Documents That Come from Your Factory (and What Can Go Wrong)

Four documents. Every lithium battery product for Amazon FBA or general trade needs them, and every one of them originates or is finalised at the factory.

1. UN 38.3 test summary, from the cell manufacturer, standardised format, signed. Common failure: an old template, the wrong cell reference, or an uncontactable signatory.
2. Safety Data Sheet, from the finished-product responsible party, in the language of the destination market, referencing the finished product rather than the bare cell. Common failure: the cell manufacturer's SDS is forwarded instead of a finished-product SDS.
3. Battery specification sheet, from the cell or battery pack manufacturer, documenting chemistry, energy content, voltage, capacity and dimensions. Common failure: misdeclared energy content, which can miscategorise the product for the FBA Dangerous Goods programme.
4. UN packaging marking and Class 9 label, applied to the outer packaging by the factory before shipment. Common failure: present on the master carton but missing from the retail box, or vice versa.

A risk sits underneath all four documents: cell substitution. The test summary is issued once, for a specific cell design. After the test lot is approved, a factory can substitute a cheaper cell into production without updating the paperwork. What matters commercially is the cell inside the retail box on the Amazon receiving dock, not the cell described on paper, and the two are not necessarily the same. Only pre-shipment inspection at the factory, with cell-level checks against the paperwork, can confirm that they match.

The UN 38.3 test summary and the SDS are documents. The cells inside the retail box are physical objects. Only an inspector at the factory can confirm that one matches the other, before the container leaves for the port. AQF dispatches inspectors across the major electronics manufacturing hubs in China, from Shenzhen to Dongguan to Guangzhou, and coordinates lab work through an accredited partner network.

Get a Lithium Battery Compliance Inspection Quote for Your Factory in Asia

9. How AQF Coordinates Factory Verification With a Partner Test Lab

AQF does not run UN 38.3 or IEC 62133-2 tests in-house. Those tests require ISO 17025-accredited laboratory infrastructure. AQF coordinates with an ISO 17025-accredited partner laboratory network, and runs the factory-side verification that ties the lab paperwork to the physical shipment.

1. Scoping: you send the product details, category, cell chemistry, target markets and marketplace requirements, and AQF's team confirms which tests apply: UN 38.3 always for lithium, IEC 62133-2 for EU and Asia Pacific, UL 1642 or UL 2054 for US Amazon categories, FCC and NRTL where relevant, and CE, RoHS or REACH for EU market access.
2. Test lab coordination: where the cell manufacturer's existing test summary is valid for the cell used in production, AQF verifies that. Where new testing is required, a new cell design, a new supplier, or an expired summary, AQF coordinates the work with an accredited partner lab in the region.
3. Factory audit, optional but recommended for first-time suppliers: an initial evaluation verifies the cell supplier chain, the assembly quality control system, and traceability of cells to batch numbers. See our factory audit in China guide for the full workflow.
4. Pre-shipment inspection: before the container leaves, an inspector verifies the retail packaging, the UN packaging marking and Class 9 label, the SDS in the shipping documents, the state of charge on a sample where relevant, and the cell reference against the test summary.
5. Reporting: you receive the inspection report with photos, findings, and a pass or fail against agreed criteria. Test lab reports stay with the responsible party and are forwarded to you for FBA Dangerous Goods or other regulatory submissions.

This factory-side layer connects to consumer product lab testing coordinated by AQF, to AQF's factory audit services, and to our factory audit in China guide for new suppliers. For the shipment itself once compliance is confirmed, see shipping lithium battery products from China.

10. Common Reasons UN 38.3 Compliance Fails in the Field

1. The cell manufacturer's test summary is for a different cell. The finished-product factory sourced a cheaper cell for production without updating the test summary. Only cell-level traceability catches this.
2. The test summary is old and references a superseded UN Manual edition. If the current reference is the eighth revised edition plus Amendment 1 (2025) and the summary references a much older edition, competent authorities can reject the shipment.
3. The SDS is the cell SDS, not the finished-product SDS. Amazon's FBA Dangerous Goods programme rejects the application, and freight forwarders may also refuse the shipment for air transport.
4. The state of charge on air-freighted lithium-ion batteries is above 30 percent. This is a mandatory IATA DGR limit, and the shipment is offloaded at airport screening.
5. The Class 9 label is missing on one pack configuration. The master carton has it, the retail unit does not, or vice versa, and screening rejects the shipment.
6. The declared lithium content or watt-hour rating is incorrect. Misclassification triggers the wrong UN number, UN 3090 instead of UN 3480, or UN 3091 instead of UN 3481, and the shipment fails the paperwork check.

Five of these six failures are visible at the factory before the container leaves. Only cell substitution requires deeper verification, through cell teardown or serial number cross-checking against the test summary.

Frequently Asked Questions

What is UN 38.3 testing?

UN 38.3 is the international transport safety test protocol for lithium metal and lithium-ion cells and batteries, defined in Sub-section 38.3 of the United Nations Manual of Tests and Criteria. It comprises eight tests, commonly named T.1 to T.8, covering altitude, thermal, vibration, shock, short circuit, impact or crush, overcharge and forced discharge. Passing UN 38.3 is a prerequisite for shipping lithium batteries by air, sea, road or rail worldwide.

Is UN 38.3 testing mandatory for lithium batteries?

Yes. UN 38.3 has been adopted by regulators and competent authorities around the world, and it is a de facto requirement for global market access. Any lithium cell or battery shipped as cargo, on its own or installed in a device, must have been tested to UN 38.3 by the cell manufacturer, and a test summary must be available on request from the shipper.

What is the difference between UN 38.3 and IEC 62133-2?

UN 38.3 is a transport safety standard. It verifies that cells and batteries survive the environmental and mechanical stresses of shipping without fire, rupture or leakage. IEC 62133-2:2017 (with Amendment 1:2021) is a product safety standard for portable sealed secondary lithium cells and batteries. It verifies safety under normal and reasonably foreseeable misuse. Most consumer electronics need both.

What is a UN 38.3 test summary?

The UN 38.3 test summary is a standardised document produced by the cell or battery manufacturer, listing the test results, the responsible party, and a signed statement of compliance. Since 1 January 2020, the test summary must be made available on request across the supply chain. The US Department of Transportation formally implemented the requirement on 1 January 2022, then revised the reference document in May 2024.

Do I need UN 38.3 testing to sell on Amazon FBA?

Yes, if your product contains a lithium cell or battery. Amazon's FBA Dangerous Goods programme requires a UN 38.3 test report and a Safety Data Sheet before approving the product for FBA fulfilment. The test itself is done at the cell manufacturer, but the importer must obtain the test summary and forward it, together with the finished-product SDS, when submitting the application.

Which products contain lithium batteries and need UN 38.3?

Consumer electronics with rechargeable batteries (phones, tablets, laptops, wireless speakers, headphones, power banks, wireless mice, LED torches), promotional products with embedded batteries, electric toys, medical devices, hand tools, and small appliances. Products with button cells (watches, hearing aids) also fall under UN 38.3, with lithium metal cell provisions. If it stores or generates electrical energy in a lithium chemistry, it ships under UN 38.3.

Can UN 38.3 testing be done in China?

Yes. Testing is normal practice in ISO 17025-accredited laboratories in China, including in the Pearl River Delta cities where most consumer electronics manufacturing is located. What testing does not prove is that the cells in the actual production run are the cells that were tested. Cell substitution after sample approval is a documented failure mode, and a factory-side pre-shipment inspection can catch it.

What is the current UN Manual of Tests and Criteria edition?

The applicable reference is the eighth revised edition of the UN Manual of Tests and Criteria, published in 2023, with Amendment 1 dated 12 September 2025. Individual national and modal regulators (US DOT, IATA, IMDG) transpose UN Model Regulations into their own instruments on a two-year cycle. The 2026 IATA Dangerous Goods Regulations are the 67th edition, applicable from 1 January 2026.

What is the state-of-charge limit for lithium-ion batteries shipped by air?

Lithium-ion cells and batteries shipped by air as cargo, on their own (UN 3480), must be set at a state of charge not exceeding 30 percent of rated capacity. This limit is a hard requirement in the IATA Dangerous Goods Regulations and in ICAO Technical Instructions. Competent authorities can grant exemptions for specific medical device batteries that must ship at higher SoC.

What happens if a lithium battery fails UN 38.3?

The battery cannot be shipped commercially. The cell manufacturer must redesign, retest, and reissue a test summary before the product can enter the supply chain. Untested cells and batteries can only be transported under the more restrictive prototype or low production run provisions, which require formal approvals from the departure country, the operator's country and, for the US, from the Department of Transportation.

Get Your Lithium Battery Product Verified Before It Ships

Considering a compliance inspection for your lithium battery product at the factory in China or Asia, ahead of Amazon FBA submission or your first shipment? AQF's team runs pre-shipment inspections that verify the cells match the UN 38.3 test summary, the SDS matches the finished product, and the state of charge and Class 9 labelling meet IATA and IMDG requirements. Testing is coordinated with an ISO 17025-accredited partner laboratory network that AQF works with. Send us the product details and the factory location.

Get a Lithium Battery Compliance Inspection Quote for Your Factory in Asia