Battery Shipping & Handling Guidelines

EV & Hybrid Battery Packs | Medium & Large Format

Purpose & Regulatory Basis

This guide explains how Greentec Auto and Greentec Recycling personnel package, mark, and document medium-and large-format EV and hybrid battery packs for shipment. It serves two purposes: a hazmat training reference under 49 CFR Part 172 Subpart H, and a packaging standard that can be shared with customers and vendors who ship batteries to or from a Greentec facility.

Battery transport is governed by the U.S. Department of Transportation (DOT) Hazardous Materials Regulations (HMR), 49 CFR, principally §173.185 (lithium cells and batteries) and the Special Provisions in §172.102. The chemistries Greentec handles map to four UN numbers:

UN Number	Proper Shipping Name	Greentec Chemistry / Example
UN3480	Lithium-ion batteries (standalone)	EV / large-format Li-ion packs, module trays
UN3481	Lithium-ion batteries packed with / in equipment	Packs shipped with modules or in a unit
UN3496	Batteries, nickel-metal hydride	NiMH hybrid packs — regulated by vessel >100 kg only
UN3171	Battery-powered vehicle	Complete EV with battery installed

Recycling & Disposal Exceptions (49 CFR 173.185(d))

Because Greentec ships batteries for recycling or disposal, two exceptions apply and are worth knowing:
• Testing / record-keeping exception — batteries shipped for disposal or recycling are excepted from UN Manual of Tests and Criteria Part III, 38.3 testing and its records (49 CFR 173.185(d)).
• UN-specification packaging exception — when packed in a strong outer packaging, such batteries are excepted from UN-spec packaging requirements (49 CFR 173.185(d)). Damaged/defective/recalled (DDR) batteries do NOT qualify — see Guide 4.

Battery transport is governed by the U.S. Department of Transportation (DOT) Hazardous Materials Regulations (HMR), 49 CFR, principally §173.185 (lithium cells and batteries) and the Special Provisions in §172.102. The chemistries Greentec handles map to four UN numbers:

NOTE — Scope

This is U.S. ground-transport guidance. It does not cover air transport (most large and all DDR lithium batteries are forbidden by aircraft) or international ocean carriage without additional review. The shipper is always responsible for confirming current requirements before tender.

Guide Selector — Which Procedure Applies

Identify the chemistry, size, and condition of the pack, then follow the matching guide.

Guide	Chemistry	Size / Condition	UN #	Typical Greentec Example
1	Lithium-ion	Large: cell >60 Wh or battery >300 Wh	UN3480 / 3481	Large-format Li-ion packs & modules
2	Lithium-ion	Large EV pack ≥ 12 kg (26.5 lb)	UN3480	Full EV traction packs; hybrid Li-ion packs
3	NiMH / dry	Any size (ground); >100 kg by vessel	UN3496	NiMH hybrid packs (Prius, etc.)
4	Li-ion & Li-metal	Damaged, Defective or Recalled (DDR)	UN3480 / 3090	Swollen, hot, punctured, or leaking packs
5	Li-ion (installed)	Battery installed in vehicle	UN3171	Complete electric vehicle

CAUTION — Always assess condition first

Any pack that is swollen, hot to the touch, hissing, leaking, punctured, or has been in a crash or fire is DDR and must go to Guide 4 regardless of chemistry or size. When in doubt, treat it as DDR.

Large-Format Lithium-Ion Cells & Batteries — UN3480 / UN3481

Applies to Li-ion cells >60 Wh or batteries >300 Wh in standard (non-DDR) end-of-life condition.

Packaging

Place each battery in inner packaging of nonconductive material (e.g., plastic) that fully encloses it and prevents contact with conductive materials.
Pack to prevent shifting that could damage cells (bubble wrap, vermiculite, or silicone foam).
Place inner packaging in a strong rigid outer packaging. UN-spec packaging is not required for recycling shipments but is preferred.
When Li-ion batteries are installed in a vehicle, use Guide 5 (UN3171).

Marking

Class 9 lithium battery hazard label
Correct UN number (UN3480 or UN3481)
Proper shipping name (e.g., “Lithium-ion batteries”)
Shipper or consignee name and address

NOTE — Shipping Papers & Training

Large Li-ion shipments require a hazardous materials shipping paper per 49 CFR 172.200–205 (see Supplement A). All employees involved in preparing the shipment are subject to the training requirements of 49 CFR 172.704.

Large EV Packs ≥ 12 kg & the Hybrid Safety Plug — UN3480, 49 CFR 173.185(b)(5)

Heavy-battery packing options — 49 CFR 173.185(b)(5)

A single battery weighing 12 kg (26.5 lb) or more with a strong, impact-resistant outer casing (and assemblies of such batteries) may be packed:

in strong outer packaging;
in protective enclosures (e.g., fully enclosed or wooden-slatted crates); or
on pallets or other handling devices.

Additional requirements

Batteries / assemblies must be secured to prevent movement.
Terminals must be disconnected or capped/covered to prevent short circuit, and must not bear the weight of superimposed elements.
The 12 kg reference is battery weight only — not accompanying equipment.

Hybrid Safety Plug (Service Disconnect) Removal

Many hybrid and EV packs carry a manual service disconnect (“safety plug”). Removing it isolates the high-voltage bus beyond the pack. In addition to packing and marking the pack, the shipper must disconnect this plug before handling or shipping a hybrid or EV battery.

CRITICAL — High voltage — qualified personnel only

EV and hybrid packs operate at hazardous DC voltages. Only personnel trained on de-energization, wearing the correct voltage-rated PPE (Class 0 gloves rated to 1,000 V for HV packs), may remove the service disconnect, cap terminals, or handle exposed bus bars. Verify zero energy before packaging.

NiMH Hybrid & Dry Batteries — UN3496 (Vessel), “Batteries, dry, sealed, n.o.s.”

Ground vs. vessel classification

Under 49 CFR 172.102 Special Provision 130, nickel-metal hydride batteries — including hybrid-vehicle packs — fall under “Batteries, dry, sealed, n.o.s.” Unlike lithium batteries, when shipped by ground within the U.S. NiMH dry batteries are not fully regulated Class 9 dangerous goods. Dry batteries also include alkaline, NiCd, and carbon-zinc.

Packing requirements

Cover / tape / isolate terminals to prevent short circuit. For NiMH hybrid packs this means removing the orange safety plug (see Guide 2).
Pack in strong outer packaging or casing that prevents dangerous heat generation and short circuit.

CAUTION — Two limits to remember

(1) Used/spent dry batteries rated up to 9 volts, combined in one package and moved by highway for recycling, are not subject to other HMR requirements — but different chemistries or ratings above 9 V may not be combined with them. (2) By vessel, NiMH is Class 9 dangerous goods (UN3496); quantities over 100 kg ship as fully regulated dangerous goods.

Damaged, Defective or Recalled (DDR) Packs — 49 CFR 173.185(f)

Packaging requirements (173.185(f))

Place the cell/battery in individual, non-metallic inner packaging that fully encloses it.
Surround it with non-combustible, electrically non-conductive, absorbent cushioning (vermiculite, perlite, steel wool, silicone foam).
Place inner packaging in UN Packing Group I performance-tested outer packaging. Only one DDR battery per outer package unless shipped under a special permit.
Mark the outer package to indicate it contains a damaged battery, in addition to the Class 9 label, UN number, proper shipping name, UN-spec mark, and shipper/consignee address.

DDR Packing Sequence

Step 1

Protect from short circuit

Cover positive/negative terminals and any leads with non-conductive tape.

Step 2

Select inner packaging

Non-metallic packaging (e.g., plastic bag) that fully encloses the battery.

Step 3

Select outer packaging

UN Packing Group I (e.g., 1A2 steel drum). Fibreboard is not allowed.

Step 4

Fill outer packaging

Non-combustible, non-conductive, absorbent cushioning. One DDR battery per package.

Step 5

Close outer packaging

Follow the packaging manufacturer’s closure instructions exactly.

Step 6

Apply DDR marks / labels

Shipper/consignee, UN number, PSN, “DAMAGED/DEFECTIVE”, Class 9 label.

Step 7

Complete papers & tender

Complete DDR shipping papers and offer to the carrier.

Battery-Powered Vehicles — UN3171 (Li-ion battery installed)

When UN3171 applies

Under 49 CFR Special Provision 134, a battery-powered vehicle classification applies only to vehicles transported with the Li-ion battery installed. If the battery is removed, the shipment is classified as UN3481, lithium-ion batteries packed with equipment (Guide 1).

By ground: no marks, labels, or shipping papers

Battery-powered vehicles do not require UN-spec packaging; a strong fiberboard box is allowable.
Vehicle packed to prevent shifting within the box.
Protected against accidental activation.
The battery is installed in the vehicle.

NOTE — Cross-reference

If a pack is pulled from a vehicle for separate shipment, it leaves UN3171 and re-enters Guide 1 (UN3481) or, if heavy, Guide 2. If it is damaged, it goes to Guide 4 (DDR).

Supplement A — Hazardous Materials Shipping Paper (Example)

A shipping paper is required for large Li-ion (UN3480/3481), all DDR shipments, and any vessel/fully-regulated NiMH (UN3496). Fields below use a table layout so they stay aligned. Replace bracketed values per shipment.

NOTE — Booking note

If a recycler books the shipment, the shipping paper / BOL is typically provided by them and referenced to a purchase-order number. Confirm who is the DOT shipper of record for each load.

Supplement B — Shipping Batteries in an Overpack

Definition

An overpack is a collection of completed packages enclosed by the shipper for protection or handling convenience (e.g., shrink-wrapped pallet, or a crate/outer box holding several battery packages).

Rules

No weight limit on the overpack itself (weight limits apply to the individual packages).
Marks/labels on the inner boxes must be reproduced on the outside of the overpack unless clearly visible through it (e.g., shrink wrap).
The word “OVERPACK” must be marked on the outside, at least 12 mm high.

Training & Recordkeeping — 49 CFR Part 172, Subpart H

Every Greentec hazmat employee who prepares, packages, marks, loads, or documents these shipments must be trained and certified. Subpart H requires five components:

Component	What it covers (Greentec context)
General awareness / familiarization	Recognizing and identifying hazmat; UN numbers, hazard classes, and the guides in this document.
Function-specific	The exact packaging, marking, and paperwork steps for the packs each employee actually handles.
Safety	HV de-energization, PPE, thermal-runaway recognition/response, emergency procedures, exposure controls.
Security awareness	Security risks of hazmat transport and methods to reduce them.
In-depth security	Required only if a facility has a security plan under Subpart I; covers the plan's specifics.

Recurrent training at least once every three years (49 CFR 172.704(c)(2)); new hires may perform functions under direct supervision for up to 90 days pending training.
Records retained while employed and for 90 days after, including name, most recent training date, materials/description, trainer, and certification (49 CFR 172.704(d)).

NOTE — Companion documents

This guide pairs with the Greentec hazmat course, the training certificate, and the training log. Together they meet both the training-effectiveness and the federal recordkeeping objectives.