Lithium Battery Import Compliance: UN38.3, IEC 62619, CE and UL Explained

September 22, 2026

Haineng Energy LiFePO4 prismatic cells assembled into a lithium battery module for export

Buying lithium batteries from a factory is straightforward. Clearing customs, satisfying your carrier and passing your own customer’s compliance review is where first orders stall. This guide explains the standards that most often get asked for, what each one actually proves, and the documents to request before you transfer a deposit.

The documents that matter on a first order

DocumentWhat it coversTypical source
UN38.3 Test SummaryTransport safety testing of the cell or batteryTest laboratory report, supplied by the factory
MSDS / SDSChemical composition and handling informationFactory or cell manufacturer
IEC 62619 test reportSafety of industrial lithium cells and batteriesAccredited third-party laboratory
IEC 62133-2 test reportSafety of portable lithium-ion cells and batteriesAccredited third-party laboratory
Declaration of ConformityWhich directives and standards the product is declared againstManufacturer, on company letterhead
Shipping declaration and packing certificateCorrect classification and packaging for the mode of transportFreight forwarder, using factory test data

One warning before you rely on any of these: a test report is only meaningful if you can see which cell, which BMS and which pack configuration it was issued against. A report for a 12 V 50 Ah pack does not automatically cover the 48 V 200 Ah pack you are ordering.

UN38.3: the one that stops shipments

UN38.3 is the section of the UN Manual of Tests and Criteria that governs lithium batteries in transport. It covers altitude simulation, thermal cycling, vibration, shock, external short circuit, impact, overcharge and forced discharge. Without a compliant UN38.3 report and an accompanying test summary, most airlines and freight lines will not accept the shipment at all.

  • Since January 2020, air shipments require the UN38.3 Test Summary, not just the full report. Ask for the summary as a separate document.

  • UN3480 covers lithium-ion batteries shipped on their own. UN3481 covers batteries contained in or packed with equipment. Lithium iron phosphate batteries are classified as lithium-ion for transport purposes.

  • The report must be issued for the cell and for the battery as assembled. A cell report alone is not sufficient for a finished pack.

IEC 62619 versus IEC 62133-2

These two standards are frequently confused, and the difference matters when a customer asks for evidence.

StandardApplies toTypical requirement
IEC 62133-2Portable lithium-ion cells and batteriesConsumer devices, power tool packs, portable equipment
IEC 62619Industrial lithium cells and batteriesEnergy storage systems, industrial trucks, telecom backup

If your project is a stationary energy storage system, IEC 62619 is normally the relevant safety standard, together with the system-level requirements your installer works to. If it is a replacement pack for a handheld tool, IEC 62133-2 is the one to quote.

United States: UL standards

UL marks are issued through a Nationally Recognized Testing Laboratory and are commonly required by US distributors, insurers and utilities.

  • UL 2054 — household and commercial battery packs.

  • UL 1973 — batteries for stationary, stationary applications, including energy storage.

  • UL 9540 — the complete energy storage system, covering the battery together with its inverter and controls.

Note that a UL standard reference on a datasheet is not the same as a listed product. Ask for the file number and check it on the UL Product iQ database before you commit to a stocking order.

European Union: CE marking and the battery regulation

“CE” is not a single certificate. It is a manufacturer’s declaration that the product meets the applicable EU legislation, and which legislation applies depends on the product.

  • Low Voltage Directive (2014/35/EU) applies above 75 V DC. A 12 V or even a 51.2 V battery pack usually falls outside its scope, so a supplier who claims “CE for LVD” on a 12 V pack is worth questioning.

  • EMC Directive (2014/30/EU) applies to apparatus that may cause or be affected by electromagnetic disturbance, which is relevant where electronics and communication (CAN, RS485, Bluetooth) are built in.

  • RoHS (2011/65/EU) and REACH restrict hazardous substances and require chemical information up the supply chain.

  • Battery Regulation (EU) 2023/1542 replaces the old Battery Directive and introduces phased obligations: carbon footprint declarations, recycled content targets, supply-chain due diligence, labelling and a digital battery passport. Requirements come in on a timetable, so confirm the current position with your importer of record.

What to ask a supplier before you order

  • UN38.3 report and test summary for the exact cell and pack configuration quoted.

  • Third-party test reports for the standard your market requires, with a visible laboratory name and report date.

  • Cell datasheet and manufacturer — not only a finished-goods datasheet.

  • Declaration of Conformity listing the directives and standards, on company letterhead.

  • MSDS and the shipping classification your forwarder will use.

  • Written confirmation of what documentation accompanies each production batch, and what costs extra.

Red flags when sourcing

  • A UN38.3 report whose model number does not match the product you are buying.

  • Standards quoted without a report: “UL-compliant” and “IEC certified” mean nothing without a document and a number.

  • Capacity claims with no discharge curve to support them — ask for a test at the stated current.

  • No cell-level traceability, which makes any future claim impossible to resolve.

  • Willingness to mark a product with any certification you name. Compliance is verified, not printed.

Frequently asked questions

Is UN38.3 the same as IEC 62619?

No. UN38.3 is a transport safety test that applies to shipping almost all lithium batteries. IEC 62619 is a product safety standard for industrial lithium cells and batteries that applies to their use. A battery usually needs both, for different reasons.

Do I need CE marking for a 48V LiFePO4 battery sold in the EU?

CE marking is required for the directives that apply to the product. For many 48 V packs that is the EMC Directive and RoHS rather than the Low Voltage Directive, whose scope begins above 75 V DC. Batteries also fall under the EU Battery Regulation. Confirm the exact obligations with your importer of record.

Can a battery ship without a UN38.3 report?

In practice, no. Carriers and freight forwarders require it, and air transport specifically requires the UN38.3 Test Summary. Without it, a shipment will normally be refused at booking.

What is a digital battery passport?

It is a requirement introduced by the EU Battery Regulation: a unique electronic record carrying information about a battery’s composition, performance and lifecycle. It is being phased in, so the exact timing depends on the battery category.

How do I verify a UL claim?

Ask for the UL file number and look it up in the UL Product iQ database, or ask for the listing certificate. A logo printed on a case is not evidence of a listed product.

Related products and resources

Documentation requirements vary by product configuration and destination. Tell us your market and application through the contact page, and we will confirm which documents accompany your order.

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