ADR special provision 188
Small lithium and sodium ion cells and batteries escape most of ADR when the size, packing, marking, drop-test and mass limits are all met.
Cells and batteries are exempt from the rest of ADR only when every limb (a) to (h) is satisfied. "Lithium content" means how much lithium sits in the anode of a lithium metal or alloy cell; "equipment" means the apparatus the cells or batteries run. A single-cell battery as defined in Manual of Tests and Criteria 38.3.2.3 is treated as a cell. Separate entries exist for lithium metal and lithium ion batteries to suit different modes and emergency responses.
| Value | Applies when |
|---|---|
| 1 g | lithium content per lithium metal or lithium alloy cell |
| 20 Wh | rating per lithium ion or sodium ion cell |
| 2 g | aggregate lithium content per lithium metal or lithium alloy battery |
| 100 Wh | rating per lithium ion or sodium ion battery |
| 1.5 g | total lithium metal cell content in a battery conforming to 2.2.9.1.7.1 (f) |
| 10 Wh | total lithium ion cell capacity in a battery conforming to 2.2.9.1.7.1 (f) |
| 12 mm | minimum height of the OVERPACK lettering |
| 1.2 m | drop test height, packages not containing equipment |
| 30 kg | maximum gross mass per package, except cells or batteries installed in or packed with equipment |
Conditions
- (a) Cells: lithium metal or alloy at most 1 g lithium; lithium ion or sodium ion at most 20 Wh (for 2.2.9.1.7.1 (f) batteries, see the 1.5 g / 10 Wh note and SP 387).
- (b) Batteries: lithium metal or alloy at most 2 g aggregate lithium; lithium ion or sodium ion at most 100 Wh, with the Wh rating marked on the case, except lithium ion batteries made before 1 January 2009.
- (c) Lithium cells and batteries meet 2.2.9.1.7.1 (a), (e), (f) where relevant and (g); sodium ion ones meet paragraphs (a), (e) and (f) of 2.2.9.1.7.2.
- (d) Cells and batteries not in equipment travel in inner packagings that wholly enclose them, guarded against short circuit (including touching conductive items in the same packaging), placed in strong outer packagings complying with 4.1.1.5, 4.1.1.1 and 4.1.1.2.
- (e) Installed cells and batteries are protected against damage and short circuit and the equipment cannot be activated by accident (devices meant to be active, such as RFID tags, watches and sensors that cannot generate dangerous heat, are excepted); the equipment goes in strong outer packagings unless it already protects the battery equivalently.
- (f) Each package bears the battery mark of 5.2.1.9, except packages holding only button cells installed in equipment, or up to four cells or two batteries fitted in equipment where the consignment has no more than two packages; overpacks show the mark or reproduce it, plus "OVERPACK" at least 12 mm high. Packages to ICAO PI 965 or 968 Section IB bearing the battery mark and label 9A are deemed compliant.
- (g) Unless installed in equipment, each package survives a 1.2 m drop in any orientation without damaging the contents, letting cells touch each other or releasing contents.
- (h) Unless installed in or packed with equipment, packages are at most 30 kg gross.
Note. Provision runs across pages 611-612.
Refers to: 2.2.9.1.7.1; 2.2.9.1.7.2; 4.1.1.1; 4.1.1.2; 4.1.1.5; 5.2.1.9; 5.2.2.2.2; special provision 387.
Carried by 6 Table A entries
UN 3090 · UN 3091 · UN 3480 · UN 3481 · UN 3551 · UN 3552
Source: ADR 2025 (ECE/TRANS/352), Volume I, section 3.3.1, special provision 188, page 611.
Paraphrase in FreightUtils' own words, not the official text. Not yet reviewed.
ADR 2027 amendments (accepted, applying from 1 January 2027) are not yet reflected on this page.