The Blog

Proposed ADR Changes for Lithium Batteries

17 May 2024 by Edward Martin

The Problem

It’s 2009 and the latest amendments to the UN’s Agreement concerning the International Carriage of Dangerous Goods by Road (ADR) regulations have come into force. They include a new special provision re-introducing exemption rules for transporting lithium batteries below a certain lithium content some six years after its removal on the 1st January 2003 which mandated that all lithium metal and lithium batteries at the time must be declared and transported as dangerous goods.


Elsewhere in the world, information technology analyst and then Fellow at the Stanford Center for Internet and Society Larry Downes is preparing for the launch of his new book The Laws of Disruption Among many things, this outlines the ‘pacing problem’, a concept that innovations in technology are increasingly outpacing the ability of laws and regulations to keep up. Now fast forward to 2024 and we could be about to face the biggest shake up in ADR legislation for lithium batteries in over two decades!


The UN Informal Working Group on the transport of lithium batteries have submitted a paper to the Economic and Social Council Transport of Dangerous Goods Sub-Committee (SCoETDG) and the Globally Harmonised System of Classification and Labelling of Chemicals proposing revolutionary changes around the testing and classification of lithium batteries.

United Nations ECOSOC Geneva

The Proposal

The draft proposal will be discussed at the upcoming 64th Session of the SCoETDG in Geneva between 24th June and the 3rd July and outlines:

9 new hazard divisions for lithium cells and batteries

9 new hazard divisions for sodium cells and batteries

5 new tests to be added into the UN Manual of Tests and Criteria

32 new UN numbers for lithium cells and batteries (UN4000 to UN4031)

16 new UN numbers for sodium cells and batteries (UN4100 to UN4115)

Additional Battery Tests

The proposal also outlines five new tests that will form part of the UN Manual of Tests and Criteria:

Cell Propagation (Test T.9)

Cell Gas Volume Determination (Test T.10)

Battery Propagation (Test T.11)

Battery Gas Volume Determination (Test T.12)

Cell Gas Flammability Determination (Test T.13)16 new UN numbers for sodium cells and batteries (UN4100 to UN4115)


It is important to note that the submitted paper by the UN Informal Working Group is in their own words “drafted text and is not fully completed” but it certainly does a very good job shedding some light on what the future of lithium and sodium battery legislation could look and the complexities the wider supply chain could soon face in ensuring overall safety.


The possible addition of up to 48 new UN numbers will provide a more in-depth distinction based off the new test procedures which then classify the batteries into the new hazard divisions. Finally, the proposal could see changes to transport documentation in which it would have to display the maximum state of charge authorised for transport in addition to the existing requirements of ADR Chapter 5.4. Any potential changes will become clearer following the conclusion of the next SCoETDG’s session in early July. You can also find the full proposal on the UN’s website here.



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