（A question on Lithium Battery Mark pertaining to PI 967 and PI 970.）
Q.
We would like to know how to handle a consolidation shipment from multiple shippers involving equipment having lithium batteries installed. In the case of the below described scenario, we will place the Lithium Battery Mark on all the packages, enter the required statement on the MAWB that all lithium batteries (lithium ion or lithium metal) are in conformity with Section II of PI 967 or PI 970, with no entry made on the HAWB？ Would this handling be acceptable？
Scenario (1)
Two (2) packages each containing one (1) lithium ion battery installed in one (1) equipment and another one (1) package containing three (3) equipment each installing one (1) lithium ion battery, and
Scenario (2)
Two(2) packages each containing one (1) equipment with one (1) lithium ion battery installed and another one (1) package containing one (1) equipment with one (1) lithium metal battery installed.
How would these be handled?
Furthermore, the rule says if the MAWB carries no more than two packages, thence the lithium battery mark is not applicable. What if we enter the required statement on the MAWB necessitating the application of the lithium battery mark, will this constitute an error subject to rejection? What will be the ways and means not to be rejected. We need your guidance.
We would like to know how, why and when the 2-package quantity restriction was introduced.
As a personal opinion, I interpret the rule as:
(a) Regardless of the type of lithium battery, the package quantity rule applies only when the package count is no more than two package per one AWB, and
(b) Each package must not contain more than four cells and two batteries installed in equipment,
Consequently if the AWB carries three package or more containing equipment where lithium battery, regardless of type or quantity, is installed in the equipment, the lithium battery mark must be applied to the packages, and the AWB must carry the required statement. Kindly verify whether my understanding is correct or not. I need your guidance. (31 Dec 21)
A.
I will answer your questions by referring to the wordings of PI 967 and PI 970.
The first question pertains to why, how and when the rule on restricting lithium battery quantity count started. This rule was introduced in 2016 per DGR 57th Edition. I am unaware of the direct cause but I feel thc intent must have been to ease the rules. In the 57th Edition in both PI 967 and PI 970, in Additional Reuirements – Section II, it reads: “Each package must be labeled with a lithium battery handling label（Figure 7.4.H）. This requirement 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.” This rule is carried over to the 63rd Edition effective from 1 January 2022, in both PI 967 and PI 970, under Additional Requirements – Section II as, ”The application of the lithium battery mark (Figure 7.1.C) 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.”
Having said so, Scenario (1) has a total of three (3) packages per AWB and thus not eligible for the exemption of the lithium battery mark. All three (3) packages must carry the lithium battery mark and the AWB must carry the required statement. It is the same with Scenario (2) where you have three (3) packages per AWB. You need to apply the lithium battery mark on all three (3) packages and enter the required statement on the AWB. Please take note that the DGR uses the term “consignments of two packages or less”. It is referring to a consignment, e.g. a shipment or packages moving under a single AWB. If there are more than two packages on a single AWB, the lithium battery mark must be affied on all the packages.
One of your question referred to entering the lithium battery statement on the AWB creating a scenario obligating the application of the lithium battery mark. You asked whether this was acceptable. I am unable to figure out why should you insist in applying the lithium battery mark when you have only two packages and the quantity of lithium cells and batteries are both within limits. This would not be an offense but it certainly will cause confusion at the job site. It is an action against established rules and must not be encouraged.
Furthermore the document of transport contract between the forwarder and the airline is the MAWB. It is not the HAWB. Dangerous Goods transport contract is also done per conditions of the MAWB. Please take due note.
Lastly, your interpretation (a) and (b) stated as your personal opinion are both correct. Your understanding is correct.
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