Lithium batteries

Important rules and regulations

Storage regulations


Currently, there are no public regulations on the storage of lithium batteries. But shouldn’t be seen as a "free pass to do nothing". According to REACH, lithium batteries are simply products and, by definition therefore, not hazardous substances. However, there is general agreement that, within your business, lithium batteries need be treated and stored as a hazardous substance (see also VdS 3103).

The storage of lithium batteries is significantly influenced by their performance classification: low, medium and high performance (see general and specific safety rules). On the part of the insurers, there are written recommendations (leaflet VdS 3103) which are regarded as equivalent and equally binding.


For the storage of lithium batteries, analogies can be derived to the transport regulations for hazardous goods and the hazardous materials ordinance or TRGS


In accordance with the law on hazardous goods: provide a protection design based on the hazard potential, e.g. differentiation between new products, end-of-life batteries, damaged batteries, prototypes, etc.


In accordance with the law on hazardous substances, design the storage facility as for a hazardous materials storage facility in accordance with TRGS 510, including design as F90, access restriction, ventilation, prohibition of combined storage.


The following storage solutions have proven themselves in practice:


Safety cabinets in accordance with EN14470


ADR-compliant container and transportation systems with fire protection function


Fire protection containers with tested fire resistance


Other additional conditions:


storage is only permitted if lithium batteries are tested in accordance with UN38.3, otherwise only following an appropriate risk assessment.


No charging in the storage area!


Charging dealt with separately from storage.


Only daily requirements outside of warehouses


Minimum quantity limitation or encapsulation


Property insurance and, in the case of larger quantities, the fire brigade should be involved in the decision-making process in terms of proper storage. See also fire protection concept.


Transport regulations 

Since 2009, lithium batteries have been officially noted as Class 9 hazardous goods (various hazardous substances and item). And that's no bad thing! For small lithium batteries (<100Wh), the legislation provides relief for e.g. power banks, mobile phones or laptop batteries via special provision 188 in the ADR. Under certain conditions, their transportation does not fall under the considerably more complicated hazardous goods transportation requirements for larger batteries.


The following points must be worked through in connection with the transportation:


UN 3090 (Lithium-metal batteries) or UN 3480 (Lithium-ion battery)


Classification into small (according to SV188) or larger lithium batteries


Choice of container or packaging


Correct packing method


ADR-compliant labelling


For lithium batteries there are various special regulations and packaging instructions in the ADR (i.e. transportation by road). These differ, in some cases considerably, in the requirements associated with them and the choice of container or packaging.


ADR distinguishes between


New/intact lithium batteries (normal case)


Lithium batteries with prototype status


Defective/damaged lithium batteries


Lithium batteries for disposal/recycling


In principle, transportation by air is much more complicated, and the shipping of defective/damaged lithium batteries is even strictly prohibited. Lithium batteries in aircraft have been associated with too many accidents, sometimes even with crashes. It is advisable to consult the transport service provider in advance with regard to the transportation and what needs to be taken into account.


Legal regulations - obligation to instruct:

All persons involved in the transportation of hazardous goods (e.g. lithium batteries) MUST be instructed in the requirements for their area of work and responsibility. Even those who are not subject to the law on hazardous goods (e.g. because of SV 188) should know exactly why they are exempt and what conditions they have to comply with.


Special feature: transportation of lithium batteries as hazardous goods

Lithium batteries are considered hazardous goods under transport law. A UN approval of the container alone does not justify all requirements to carry out the ADR-compliant transportation of lithium batteries for all cases. We therefore recommend that our customers acquire the appropriate technical knowledge in the field and to train the responsible employees extensively so that the containers are used according to the regulations. This includes having appropriate understanding of the official packaging instructions, the labelling in accordance with ADR and the conscious handling of e.g. damaged lithium batteries.


General safety rules 


According to GDV / VdS, the following are to be observed in principle (even for small quantities):


Compliance with all specifications of the respective manufacturers and technical product data sheets


Prevention of external short circuits (protection against short circuiting the battery poles, e.g. by using pole caps)


Prevention of internal short circuits (protection against mechanical damage)


Do not expose to high temperatures or heat sources directly and permanently (e.g. including direct sunlight)


In areas not protected by automatic extinguishing systems, a structural or spatial separation of at least 2.5 m from other flammable materials must be maintained.


Damaged or defective lithium batteries must be removed immediately from storage and production areas and temporarily stored at a safe distance or in a fire protection area until disposal.


Only cells and batteries for which proof of testing according to UN 38.3 is available may be stored (prototypes may be stored in exceptional cases and only with a risk assessment).

When charging batteries, the instructions of the manufacturers and insurers must be observed.



Specific safety rules

According to GDV / VdS, the following are to be observed in particular:

Low-power lithium batteries (≤ 100 Wh)


For batteries in this category the general   safety rules apply;   for  this   there are  no  specific  safety rules.  For  larger  connected  storage quantities (volumes over 7 m³ or more than six Euro pallets) the instructions for medium capacity lithium batteries apply.


Medium capacity lithium batteries (> 100 Wh and ≤ 12 kg)

Areas with medium power batteries must be separated from other   areas   spatially   (at least   5   m)   or  structurally  fire resistant    mixed bearing arrangements   with   other   products,   which   can accelerate a   fire   ,   should be avoided    The  storage area  is to be monitored  by means of  a  suitable fire alarm system with connection to a permanently  occupied  location   .  In terms of the  presence  of  fire extinguishing systems,   the  information  in  reference  to  suitable  extinguishing agents  in  the  respective   technical product data sheets must be taken into account.  For  larger  storage quantities (occupied area > 60 m² and/or storage heights > 3 m), the instructions for high-performance  lithium batteries apply.


High-performance lithium batteries (> 100 Wh and > 12 kg)

In terms of    high-performance  batteries   no     no  secure  knowledge currently exists  regarding   the adequate   protective measures  .   Protective measures  are  therefore to be taken  in  agreement  with  the property insurer for the individual case. Conceivable measures in this respect include e.g:


Separation and quantity limits


Storage in fireproof separated areas or with adherence to a safety distance (spatial separation of 5 m)


Automatic fire extinguishing systems



Risk assessment


The operating instructions and, if necessary, a "safety data sheet" from the battery manufacturer should provide initial orientation. Lithium batteries pose an array of hazards: electrical hazard, fire hazard, environmental hazard, acid leakage etc.

In order to determine all the hazards posed by lithium batteries, it is necessary to look at the entire process within the company (i.e. from goods receipt, operation, storage and disposal). It is crucial to make a breakdown in the classification because of the considerable differences in risk: new, damaged, in use, charging, etc.


Typical examples of what needs to be identified and evaluated in terms of a risk assessment


Employees must be aware of the criteria that apply when a lithium battery becomes conspicuous or is considered defective/damaged (meaning that it is no longer in use)


The correct handling of returns/complaints from customers must be clarified if they arrive in an unknown (hazardous) condition at your own company. In any case, the charging of lithium batteries must be considered in the employer's risk assessment. All hazards associated with the charging processes and storage of the batteries must be assessed and it must be determined which occupational safety measures are necessary. Employee instruction and operating instructions for handling lithium batteries can then be derived from the written documented risk assessment.


Fire protection concept


A holistic fire protection concept is important. This should include not only structural/technical protective measures (e.g. a safety cabinet) but also organisational/behavioural protective measures (e.g. the separation of damaged batteries). In terms of the concept design, the employer must also consider the question of a sprinkler system or smoke detector/fire alarm system.

Even the best fire protection concept is useless if the employees are not prepared for an emergency.  This means that staff training, definition of the rescue chain, the commissioning of hand fire extinguishers and PPE if necessary, emergency training are all important.


Discussions with the fire brigade & property insurers


A fire protection concept should never worked out behind closed doors, but should be a team effort involving a range of participants and experts. These should include above all, storage solution manufacturers, affected employees, managers, fire safety officers, insurance representatives, the fire brigade and external experts.


The effectiveness and timeliness of the fire protection concept should be reviewed regularly.

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