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# Canada Transportation of Dangerous Goods Act: Lithium Battery Shipping Classification

Getting the UN number wrong, missing the lithium battery mark, or shipping untrained staff are the three most common TDG failures for electronics companies. This guide walks through the classification logic, documentation requirements, and training obligations that apply to every lithium battery shipment in Canada.

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At a glance

Law

Transportation of Dangerous Goods Act 1992 (TDGA)

Administrator

Transport Canada

Lithium batteries

Class 9 (UN3480/3481/3090/3091)

Applies to

All modes — air, road, rail, sea

## How TDGA and TDGR apply to lithium battery shipments

### TDGA and the Transportation of Dangerous Goods Regulations (TDGR)

Canada's Transportation of Dangerous Goods Act 1992 and its implementing Regulations govern the transportation of dangerous goods by all modes within Canada — air, road, rail, and marine. Lithium batteries are Class 9 dangerous goods (miscellaneous dangerous substances) under TDG. The TDGR sets out classification criteria, packing requirements, documentation, labelling, placarding, and training obligations that apply to anyone who handles, offers for transport, or transports dangerous goods.

### UN numbers for lithium batteries

Four UN numbers cover lithium batteries: UN3480 for lithium-ion cells and batteries transported alone (not in or with equipment); UN3481 for lithium-ion batteries packed with or installed in equipment; UN3090 for lithium metal cells and batteries alone; and UN3091 for lithium metal batteries packed with or in equipment. Selecting the correct UN number is the first step in determining which packing instruction and quantity limits apply to your shipment.

### TDGR alignment with ICAO and IMDG

Canada's TDGR incorporates ICAO Technical Instructions (for air) and the IMDG Code (for sea) by reference for those transport modes. This means ICAO packing instructions PI 965–970 and IMDG requirements apply to air and sea shipments to and from Canada without separate Canadian-specific requirements for those modes. Road and rail within Canada follow TDGR-specific requirements, which largely align with the North American TDG framework shared with the US DOT HazMat regulations.

### Transport Canada Special Permits

Standard TDG packing instructions limit package quantities for lithium batteries — for example, lithium-ion batteries above 35 kg net weight per package are not permitted under standard packing instructions and require a Special Permit from Transport Canada. Special Permits are also used for new battery chemistries not yet covered by the standard TDGR schedules, for oversized shipments, or for research and prototype batteries that cannot meet standard classification criteria.

## Steps to classify, document, and ship lithium batteries under TDG

01

Classify the lithium battery as ion (rechargeable) or metal (primary, non-rechargeable), and determine the shipping configuration: alone (cells or batteries only), packed with equipment (in the same package), or in equipment (installed in the device). This three-way split maps directly to the four UN numbers — UN3480/3481 for ion, UN3090/3091 for metal.

02

Apply the applicable packing instruction from the TDGR or ICAO Technical Instructions. For lithium-ion batteries: PI 965 (batteries alone), PI 966 (batteries with equipment), PI 967 (batteries in equipment). Check the Watt-hour (Wh) rating of the battery against Section IA, IB, or II thresholds in the packing instruction — each section has different quantity limits and additional requirements.

03

Prepare a TDG shipping document (dangerous goods declaration) for each consignment. The document must include: UN number, proper shipping name, class (9), packing group (none for Class 9 lithium batteries), quantity and number of packages, emergency contact telephone number, and shipper's name and address. The document must accompany the shipment.

04

Apply the correct Class 9 lithium battery handling mark on the outside of the package. Most lithium battery shipments above small quantities require the lithium battery mark — a rectangular mark with a flame symbol and cell/battery details — in addition to the Class 9 miscellaneous label. Confirm the specific labelling requirements for your UN number and quantity.

05

Ensure all personnel who handle, offer for transport, or transport lithium battery products have valid TDG training. The TDGA requires documented training for dangerous goods handlers; training must cover the specific classes of dangerous goods the person works with. Training records must be maintained and available for inspection by Transport Canada.

## Frequently asked questions

### Does TDG apply to small e-commerce shipments of lithium battery products?

Yes, TDG applies to lithium battery shipments regardless of shipment size, though small consumer-quantity shipments (smartphones, laptops, small power banks) often qualify for exemptions or reduced requirements under the TDGR consumer commodity provisions and ICAO Section II packing instructions. The key variable is the Watt-hour rating per battery and the total quantity per package. A single smartphone battery ships under Section II rules with significantly simplified requirements compared to large battery packs. However, even Section II shipments require the lithium battery handling mark and proper UN number identification.

### What is the difference between UN3480 and UN3481?

UN3480 applies to lithium-ion cells and batteries transported on their own — not installed in or packaged together with the equipment they power. UN3481 applies to lithium-ion batteries that are either installed in equipment (in equipment) or packed together with equipment in the same package (with equipment). The distinction matters because the packing instructions differ: UN3480 uses PI 965, while UN3481 uses PI 966 (with equipment) or PI 967 (in equipment). Shipments of phones, laptops, and other consumer electronics with their batteries installed always ship as UN3481 — never UN3480.

### Are UN 38.3 test reports required for TDG shipping?

UN 38.3 testing (the UN Manual of Tests and Criteria, Part III, Section 38.3) is the required safety test for lithium cells and batteries before they can be offered for transport. It is not a certification scheme — there is no UN 38.3 'approval' body — but a testing protocol that batteries must pass. Shippers must be able to provide a test summary upon request from transport authorities or carriers. Most battery manufacturers supply UN 38.3 test summaries with their cells; importers should obtain these from suppliers and retain them as part of shipping documentation.

### What training is required for staff shipping battery products in Canada?

The TDGA requires that any person who handles, offers for transport, or transports dangerous goods must be trained in the appropriate TDG safety requirements for the classes they work with. For lithium batteries (Class 9), training must cover: classification of dangerous goods, documentation requirements, marking and labelling, means of containment (packaging), and emergency response. Training must be documented, with records available for inspection. No specific Training Certificate is mandated — employers must ensure training is appropriate, documented, and refreshed when regulations change or duties expand.

**Disclaimer:** Educational resource only. Regulatory requirements change and vary by product category. Consult an accredited test laboratory or qualified compliance engineer before making certification decisions.

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