How lithium batteries are shipped and cleared through customs

Updated: 13 November 2026

Almost all electronics today contain a lithium battery. Many buyers therefore assume the goods have to travel as dangerous goods, with a costly declaration, a surcharge and paperwork that is charged for in China. For most goods this is not true. Small lithium batteries are subject to simplified rules in sea transport. If the goods meet them, they travel in a consolidated container as ordinary cargo, entirely legally. This guide sets out those rules and how we check them before the goods are shipped.

1. Which batteries count as small

The carriage of dangerous goods by sea is governed by the International Maritime Dangerous Goods Code (IMDG Code). Since 1 January 2026, its Amendment 42-24 has been mandatory. Special provision 188 of the Code exempts small cells and batteries from almost all dangerous goods rules, provided they stay within the limits in the table:

The watt-hour rating (Wh) is usually printed on the battery. If it is not, it is calculated as voltage (V) times capacity (Ah). For example, a 10,000 mAh, 3.7 V power bank has 3.7 × 10 = 37 Wh. Laptop batteries are usually between 40 and 99 Wh, and phone batteries below 20 Wh.

2. Conditions the goods must meet

It is not enough for the battery to be small. Special provision 188 applies only when the following conditions are also met:

• UN38.3 test. The cell and battery type has passed the prescribed safety test. The manufacturer must have the test summary and make it available on request.
• Short-circuit protection. The terminals are protected, and the battery must not touch other batteries or metal.
• The device must not switch itself on during transport.
• Strong packaging. Batteries not installed in a device are packed so that the package withstands a 1.2 m drop without damage.
• No more than 30 kg gross per package when batteries are shipped on their own. This limit does not apply to batteries installed in a device or packed with a device.
• Lithium battery mark on the package, in most cases. Exceptions include, for example, packages containing devices in which only button cells are installed.

A power bank is treated as a battery, not as a device. The 30 kg per package limit and the packing rules for batteries therefore apply to it.

3. Which documents you need and which you don’t

You need:

• a commercial invoice and packing list, as for any goods;
• the UN38.3 test summary from the manufacturer. The supplier either has it or obtains it from the battery manufacturer, and there is no separate charge for it;
• the battery’s watt-hour rating (Wh) or lithium content (g), if it is not shown on the invoice or in the test summary.

For goods that meet special provision 188, the maritime rules do not require:

• a Dangerous Goods Declaration or class 9 labels;
• a safety data sheet (MSDS or SDS). Many suppliers send one, but the IMDG Code does not require it;
• special “safe transport” certificates, which agents in China often charge for.

If your supplier or agent in China asks for a surcharge for such a document or for “dangerous goods”, let us know before you pay. We will check whether the goods really are dangerous goods.

4. What cannot travel as ordinary cargo

Some goods do not meet special provision 188 and must be shipped as class 9 dangerous goods, with a declaration and the prescribed packaging and markings:

• lithium-ion batteries over 100 Wh: batteries for e-bikes and e-scooters, portable power stations, batteries for solar systems;
• batteries on their own in packages heavier than 30 kg gross;
• batteries without a UN38.3 test summary, for example prototypes and untested goods;
• damaged, defective or recalled batteries and batteries shipped for recycling. Particularly strict rules apply to them, and some may not be transported at all.

We handle such goods too, with a separate quote. What we do not do, and what nobody should do, is hand over dangerous goods as ordinary cargo. This is prohibited by the Montenegrin Law on the Transport of Dangerous Goods (Official Gazette of Montenegro nos. 33/14, 13/18 and 89/25), and the same prohibitions apply in China and on board the ship. Undeclared batteries are a common cause of fires on ships. The goods can be detained, and the shipper bears the costs and penalties.

5. Why by sea and not by air

The rules for air freight are stricter. Lithium-ion batteries on their own may fly only on cargo aircraft, at a state of charge of no more than 30 %. Since 1 January 2026, the same state-of-charge limit also applies to batteries packed with equipment. That is why, for larger quantities of electronics from China, an LCL container to Bar is usually both the cheapest and the simplest solution.

6. Customs clearance in Bar

Batteries are cleared like any other goods: customs value, duty according to the tariff and 21 % VAT. The tariff code depends on the goods:

• lithium-ion batteries on their own (accumulators) fall under tariff heading 8507 60;
• non-rechargeable lithium batteries fall under heading 8506 50;
• a device with a built-in battery is classified as the device, for example a smartphone under heading 8517 13.

You can look up the duty rate for the exact code in TARIC CG (taric.carina.co.me), under Montenegro’s Decree on the Customs Tariff for 2026 (Official Gazette of Montenegro no. 157/25). From Bar to your warehouse, goods that meet special provision 188 travel by ordinary truck, because the same exemption applies to road transport under ADR.

7. What to ask your supplier for before ordering

1. The UN38.3 test summary for each type of battery.
2. The battery rating in Wh (or lithium content in g) for each item.
3. Whether the batteries are installed in the device, packed with the device or shipped on their own.
4. The gross weight of packages containing batteries only, if there are any.
5. Confirmation that the batteries are new and undamaged.

Send us this information together with the invoice and packing list. Before booking, we check whether the goods meet special provision 188 and tell you in advance how they will be shipped and what it will cost.

This text is for information only and is not legal advice. Rules change; for specific goods we always check the current regulations and tariff.