The definition of Lithium Battery and Lithium Cells shown in Appendix A state that from electrochemical observation, the purpose of the batteries whether they are primary or secondary have no bearing. It is the construction that makes the difference.
If lithium metal or metal alloy is used, the battery is classified as UN 3090 and if lithium ion or lithium polymer is used it is classified as UN 3480. This assignment is the same whether the item is a cell or a battery.
When shipping the Lithium ion non-rechargeable primary battery in question, as is, it must be assigned to UN 3480 Lithium ion battery and PI 965 will apply. The 30% SoC must be adhered to.