Small Vehicles Powered by Lithium
Batteries – Cargo Provisions
This guidance is in response to questions raised by shippers, freight forwarders and operators regarding the
classification of small vehicles that are powered by lithium ion batteries when shipped as cargo, specifically
whether the classification should be UN 3171, Battery-powered vehicle, or UN 3481, Lithium ion batteries
contained in equipment.
Some examples of these small lithium battery-powered vehicles are: airwheel, solowheel, hoverboard, e-bikes
and diver propulsion vehicle.
Special provision A214, which is assigned against UN 3171, Battery-powered vehicle identifies the
considerations on the classification of “vehicles” powered by internal combustion engines, fuel cells and
batteries and also “equipment” powered by lithium batteries. The current wording of Special Provision A214 in
the 62nd edition of the DGR is as follows:
A214 (388) UN 3166 entries apply to vehicles powered by flammable liquid or flammable gas internal
combustion engines or fuel cells.
Vehicles powered by a fuel cell engine must be assigned to the entries UN 3166, Vehicle, fuel cell, flammable
gas powered or UN 3166, Vehicle, fuel cell, flammable liquid powered, as appropriate. These entries include
hybrid electric vehicles powered by both a fuel cell and an internal combustion engine with wet batteries,
sodium batteries, lithium metal batteries or lithium ion batteries, transported with the battery(ies) installed.
Other vehicles which contain an internal combustion engine must be assigned to the entries UN 3166, Vehicle,
flammable gas powered or UN 3166, Vehicle, flammable liquid powered, as appropriate. These entries
include hybrid electric vehicles powered by both an internal combustion engine and wet batteries, sodium
batteries, lithium metal batteries or lithium ion batteries, transported with the battery(ies) installed.
If a vehicle is powered by a flammable liquid and a flammable gas internal combustion engine, it must be
assigned to UN 3166, Vehicle, flammable gas powered.
UN 3171 only applies to vehicles powered by wet batteries, sodium batteries, lithium metal batteries or lithium
ion batteries and equipment powered by wet batteries or sodium batteries transported with these batteries
installed.
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For the purpose of this special provision, vehicles are self-propelled apparatus designed to carry one or more
persons or goods. Examples of such vehicles are cars, motorcycles, scooters, three- and four-wheeled
vehicles or motorcycles, trucks, locomotives, bicycles (pedal cycles with a motor) and other vehicles of this
type (e.g. self-balancing vehicles or vehicles not equipped with at least one seating position), wheelchairs, lawn
tractors, self-propelled farming and construction equipment, boats and aircraft. This includes vehicles
transported in a packaging. In this case some parts of the vehicle may be detached from its frame to fit into the
packaging.
Examples of equipment are lawn mowers, cleaning machines or model boats and model aircraft. Equipment
powered by lithium metal batteries or lithium ion batteries must be assigned to the entries UN 3091, Lithium
metal batteries contained in equipment or UN 3091 Lithium metal batteries packed with equipment or UN
3481 Lithium ion batteries contained in equipment or UN 3481 Lithium ion batteries packed with
equipment, as appropriate. Lithium ion batteries or lithium metal batteries installed in a cargo transport unit
designed only to provide power external to the cargo transport unit must be assigned to UN 3536, Lithium
batteries installed in cargo transport unit.
For the purposes of this guidance document, the relevant text is “For the purpose of this special provision,
vehicles are self-propelled apparatus designed to carry one or more persons or goods.”
Classification
As these small lithium battery-powered vehicles meet the definition of “vehicles” as set out in Special Provision
A214, and as they are powered by a lithium ion battery, the correct classification for these small vehicles is
UN 3171, Battery-powered vehicle. Therefore, they must be packed in accordance with Packing instruction
952.
There are several important considerations with respect to the use of UN 3171 for these small vehicles, as
follows:
1. the lithium cells and batteries must be of a type that have successfully passed the applicable tests in
subsection 38.3 of the UN Manual of Tests and Criteria;
2. the assignment to UN 3171 does not provide for any exception from the full application of the
Regulations, i.e. there is no exception for vehicles that contain lithium ion batteries with a Watt-hour
rating not exceeding 100 Wh;
3. the net quantity required on the Shipper’s Declaration for UN 3171 is the net weight of the complete
vehicle. There is no limit on the weight of a lithium ion battery in a vehicle or in a package and there is no
net quantity difference between passenger aircraft and Cargo Aircraft Only;
4. if the lithium battery is removed from the vehicle and packed separate from the vehicle in the same
outer packaging, then as per Packing Instruction 952, the classification becomes UN 3481, Lithium ion
batteries packed with equipment and Packing Instruction 966 applies, or UN 3091, Lithium metal
batteries packed with equipment and Packing Instruction 969 applies.
Recommendations
In locations where these devices are readily available and being consigned as cargo, operators should engage
with freight forwarders and their ground service provider to clarify the classification of these small vehicles and
the additional considerations that apply. Forwarders should be encouraged to reach out to shippers of these
products to ensure that the shippers are made aware of the classification requirement as UN 3171.
You can contact the IATA Dangerous Goods Support team if you have questions or concerns that may not
have been addressed in this document at: dangood@iata.org.
2 Small Vehicles Powered by Lithium Batteries – Cargo Provisions 26 January 2021
