Lithium batteries and intercoms: how to store and ship them as dangerous goods
A helmet intercom contains a lithium battery, and that changes how it is classified, stored and shipped. Here is the basic regulatory framework and the documentation you should hold before you sell.
Updated 27 October 2026 · 6 min read
Intercoms, action cameras, rechargeable lights or heated vests: a large part of the motorcycle and sports accessories catalogue contains a lithium battery. For the buyer it is just another device; for logistics it is Class 9 dangerous goods, with its own rules for packaging, marking and transport. This guide summarises the general framework and does not replace the regulations or the judgement of a safety adviser: the rules change with each edition of the ADR and of the air transport regulations.
Why a lithium battery is dangerous goods
A lithium cell stores a lot of energy in a small space. A short circuit, a heavy knock or a manufacturing defect can make it overheat uncontrollably and catch fire. That is why transport regulations require batteries to pass design tests, to be protected against short circuits and for packages to be marked so that anyone handling them knows what they contain.
The four UN numbers you need to know
They are classified by chemistry (lithium ion, rechargeable, or lithium metal, usually non-rechargeable) and by how they travel: on their own, packed with the equipment or installed in it.
| UN number | What it covers | Example in your catalogue |
|---|---|---|
| UN3480 | Lithium ion batteries on their own | Spare battery sold separately |
| UN3481 | Lithium ion batteries contained in equipment or packed with equipment | Intercom with its built-in battery, or a kit with the battery in the same box |
| UN3090 | Lithium metal batteries on their own | Lithium coin cells sold loose |
| UN3091 | Lithium metal batteries contained in equipment or packed with equipment | Sensor or remote control with a lithium cell installed |
Most intercoms fall under UN3481, because the battery sits inside the device. But confirm it with the manufacturer: if you sell spare batteries separately, those SKUs are UN3480 and have stricter rules, especially by air.
What to request from the manufacturer before listing the product
- UN 38.3 test summary. The ADR requires each cell and battery type to pass the tests in the UN Manual of Tests and Criteria, Part III, sub-section 38.3, and requires manufacturers and subsequent distributors to make the test summary (38.3.5) available so that anyone in the chain can check it.
- Nominal energy in watt-hours (Wh) of each cell and of the battery, or the lithium content in grams for lithium metal. This is the figure that decides which regime applies.
- UN number and shipping method recommended by the manufacturer.
- Safety data sheet or equivalent document with the transport information.
- Number of cells and batteries per sales unit, needed for some marking exemptions.
Without the UN 38.3 summary and the Wh rating, no serious operator should accept the product: it would not know how to classify it or which service to ship it with.
Road transport: ADR and special provision 188
By road, the ADR applies: the European agreement on the international carriage of dangerous goods by road, revised every two years. For small batteries there is special provision 188, which exempts cells and batteries meeting all its conditions from the rest of the ADR. According to the text of the 2025 edition, these include:
- Lithium ion cells of up to 20 Wh and lithium ion batteries of up to 100 Wh; for lithium metal, up to 1 g of lithium per cell and 2 g per battery.
- Each cell and battery type must have passed the UN 38.3 tests, and the manufacturer must have the summary available.
- Protection against short circuits and, unless installed in equipment, inner packaging that completely encloses each battery, inside a strong outer packaging.
- The lithium battery mark on the package, with exceptions for packages with few cells or with batteries installed in equipment.
- The Wh rating marked on the outer casing of lithium ion batteries.
There are further conditions, such as a package drop test. If your product does not meet special provision 188, it travels as dangerous goods subject to all ADR requirements: UN-approved packaging, a Class 9A label, a transport document and staff trained in accordance with Chapter 1.3 of the ADR.
In addition, each carrier and each parcel service decides what it accepts. The fact that the regulations allow it does not mean your standard parcel service will take it: check its terms and conditions.
Air transport: more restrictive
By air, the ICAO Technical Instructions and the IATA Dangerous Goods Regulations apply, updated every year. Lithium ion batteries are shipped under packing instructions 965 (on their own), 966 (packed with equipment) and 967 (contained in equipment); lithium metal batteries under packing instructions 968, 969 and 970. Two key points:
- Batteries on their own (UN3480 and UN3090) may not be carried as cargo on passenger aircraft, except with special approvals, and standalone lithium ion batteries must be at a state of charge no higher than 30%.
- State-of-charge limits have been extended to other cases in recent editions. If you sell outside mainland Spain or ship by air, check the current edition with your carrier.
Storage in the warehouse
Spain has no regulation dedicated specifically to storing lithium batteries. The Regulation on the Storage of Chemical Products (Real Decreto 656/2017, Spain’s chemical storage regulation) applies to hazardous substances and mixtures as defined by the CLP Regulation, and its ITC MIE APQ-10 (the technical instruction on storage in mobile containers) governs storage in mobile containers. The sector takes this instruction as the reference for batteries, together with fire protection regulations and insurer requirements. How it applies to your specific case should be decided by a competent technician.
In practice, the usual measures are:
- Flag every SKU with a battery in the system, with its UN number and Wh rating.
- Store them in an area separate from other stock, away from heat sources and combustible products; for loose batteries or significant quantities, in fire-resistant safety cabinets or compartmentalised containers.
- Set aside and isolate damaged units or units returned with knocks: a damaged battery has its own, stricter transport rules. Returns of these products deserve their own flow within your reverse logistics.
- Train the staff who handle and pick them.
This segregation takes up specific space and equipment, so dangerous goods storage commonly has its own rate, higher than a standard pallet. Ask for it to appear separately on the rate card and on the invoice.
Checklist before selling a product with a battery
- Ask the manufacturer for the UN 38.3 summary, the Wh rating and the UN number.
- Check whether the product meets ADR special provision 188.
- Choose transport services that accept lithium batteries to your destinations.
- Define how returns and damaged units are handled.
- Validate everything with a dangerous goods safety adviser (DGSA) and against the regulations in force.
At ZENVU we flag intercoms and other battery SKUs when they are set up, store them separately and ship them only with services that accept batteries. You can see this in motorcycle and car parts and accessories logistics; you may also be interested in how to store helmets and visors.