Specific Q: First: Our company exports some lithium-ion batteries with the UN code 3480, which are classified as Class 9 dangerous goods. Before export, they have passed the UN38.3 test and have a transportation condition appraisal report issued by a qualified organization. The appraisal result states: handle according to the "the International Maritime Dangerous Goods Code", and based on Special Provision 188, the item is not subject to other regulations of the IMO IMDG CODE and can be managed as general cargo for transportation. The packaging requirements are also handled according to the non-restricted cargo packaging requirements. Can we avoid obtaining a dangerous goods packaging certificate and pass customs directly under these circumstances? Second: If the product is a dangerous good, even if the relevant test report proves that it can be transported as non-restricted cargo, it still needs to be declared as a dangerous good during declaration, and cannot be declared as general cargo. If declared as a dangerous good, what documents need to be provided to customs?

A: Question 1: According to the "United Nations Recommendations on the Transport of Dangerous Goods" Special Provision 188, "Batteries and battery packs delivered for transport, if meeting the following requirements, are not subject to other provisions of these regulations." If all requirements of Special Provision 188 are met, there is no need to obtain a dangerous goods packaging certificate. Question 2: According to the "United Nations Recommendations on the Transport of Dangerous Goods" 2.9.4, "Batteries and battery packs, batteries and battery packs installed in equipment, or batteries and battery packs packed with equipment, containing lithium in any form, are classified under UN numbers 3090, 3091, 3480, 3481 as appropriate." Therefore, all lithium batteries should be truthfully declared as dangerous goods information. If they meet Special Provision 188, transportation condition appraisal materials can be provided.

Attachment

United Nations Recommendations on the Transport of Dangerous Goods The First Volume

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