(Question on the application of Lithium Battery Mark for PI 967 and PI 970.)
Q.
This is a question pertaining to Lithium Battery Mark on packages of PI 967 and PI 970 as stated in the IATA DGR.

The DGR reads: ”Lithium battery mark does not apply to consignments of two packages or less where each package contains no more than four cells or two batteries installed in equipment.” Let’s say for example there is an AWB with two packages, both package containing devices containing lithium cells. The first package contains 10 devices (or 10 cells), and the other package contains 2 devices (or 2 cells). Is it correct to say that the first package requires the lithium battery mark whereas the second package do not need the mark. Different forwarders have differing interpretation.

Some says the second package must not have the mark, but some says, since the other package on the same AWB has the mark, it is better to have the mark on the second package. Your guidance would be appreciated.  (30 Jun 20)
A.
You may find information in our website (see below), but for Section II of PI 967 and PI 970, when the shipment is two packages or less, and contains no more than 4 cells or 2 batteries per package, the lithium battery mark is not necessary.

In the example given which we feel is a rare case, the package with 10 devices (or 10 cells) require the lithium battery mark, and the second package with 2 devices (or 2 cells) do not require the mark. For commercial export shipments, the normal industry practice is uniform packaging for multiple package shipments. Multiple packages with differing contents is an isolated case. Shippers may place lithium battery mark on the second package to avoid confusion. Carriers would not reject the second package for incorrect marking. After all, lithium cells are inside the package and there is no harm if the package is marked with the lithium battery mark. As a rule, the mark is not needed. But being practical in order to avoid unnecessary confusion and interrogation, there is no harm in placing the mark for this rare case brought to attention. The best method, however is to abide by the rules, and clearly explain that the second package contains 2 cells only and therefore the mark is not needed.

Please note that when the Lithium Battery Mark is applied, the AWB must carry the words: “Lithium (ion/metal) batteries in compliance with Section II of PI (967/970)”.

Note: Additional reference is obtainable on our website. Click “Topics” and open the second title “2020 Version of Lithium Battery Guidance Document (Dec. 12, 2021)”. Go to Page 13 and refer to ”F. When is a lithium battery mark not required on the package.”

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