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The batteries do not need labels since the TDG Regulations require them only on means of containment and batteries are not considered means of containment.
Part 4 of the TDG Regulations requires that dangerous goods safety marks be displayed on the means of containment containing dangerous goods in transport.
Does not apply to means of containment containing button cell batteries installed in equipment, including circuit boards, or no more than four cells installed in equipment or no more than two batteries installed in equipment.
Since the batteries are in small means of containment, the labelling requirements of Part 4 of the TDG Regulations apply.
In this case, the pallet containing the batteries may be considered an overpack if it meets the definition found in Section 1.4 of the TDG Regulations (for example, it must contain dangerous goods originating from the same consignor). If it is considered an overpack, Section 4.10.1 of the TDG Regulations will apply.
Note: The TDG Regulations allow an exemption to placard requirements if the gross mass of dangerous goods in a road or railway vehicle is 500 kg or less. However, placards may still be voluntarily displayed. For more details, consult Sections 4.16.1 and 4.1.1 of the TDG Regulations.
Unless otherwise indicated, any large means of containment that transports dangerous goods must be standardized. Since no standard adopted by reference in the TDG Regulations may be used to transport batteries in a large means of containment, an equivalency certificate must be obtained from Transport Canada. This certificate willindicate which safety marks to display on the palette and/or the truck.
When batteries are not individually packaged but instead stacked on a pallet, or when a large battery is placed on a pallet, Section 5.14 of the TDG Regulations refers to standards CGSB-43.146 and CSA B621 (Canadian Standards Association).
Since the batteries are in small means of containment, the labelling requirements of Part 4 of the TDG Regulations apply.
To learn how to apply for an equivalency certificate, please visit the Equivalency Certificate or consult Part 14 of the TDG Regulations.
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As per Section 4.15 of the TDG Regulations, the primary class placard for every dangerous good transported in a large means of containment (Class 9, for example) must be displayed on each side and at each end of the large means of containment (the truck, for example).
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Note: The TDG Regulations allow an exemption to placard requirements if the gross mass of dangerous goods in a road or railway vehicle is 500 kg or less. However, placards may still be voluntarily displayed. For more details, consult Sections 4.16.1 and 4.1.1 of the TDG Regulations.
Lithium metal batteries are usually non-rechargeable, contain metallic lithium, and have a higher energy density than other non-rechargeable batteries. Among other things, they are often used in calculators, pacemakers, remote car locks, and watches.
To learn how to apply for an equivalency certificate, please visit the Equivalency Certificate or consult Part 14 of the TDG Regulations.
In this case, the pallet containing the batteries may be considered an overpack if it meets the definition found in Section 1.4 of the TDG Regulations (for example, it must contain dangerous goods originating from the same consignor).
In addition to the requirements above, cells and batteries installed in equipment must be (unless the equipment containing them offers equal protection):
The consignor is responsible for classifying dangerous goods (batteries in this case) in accordance with Part 2 of the TDG Regulations.
Special Provision 137 of the TDG Regulations states that damaged or defective lithium metal/ion cells and batteries must be packed in accordance with Packing Instructions P908 or LP904 of the UN Recommendations, as applicable.
Lithium ion batteries are rechargeable, do not contain metallic lithium, and have a high energy density. Lithium polymer batteries are considered a type of lithium ion battery. Lithium ion batteries are used in consumer goods such as cell phones, electric vehicles, laptop computers, power tools, drones, etc.
A truck transports batteries that are placed directly on a pallet and secured by shrink wrap. The pallet’s total capacity (volume) is greater than 450 litres. What labels and/or placards are required?
Note: Damaged or defective cells/batteries must be offered for transport or transported under Special Provision 137 of the TDG Regulations.
Batteries are typically classified as Class 8, Corrosives or Class 9, Miscellaneous Products, Substances or Organisms, though some may be considered Class 4.3, Water Reactive Substances.
Special Provision 159 of the TDG Regulations states that the label to be used for these dangerous goods is the one illustrated under the heading ʺClass 9, Lithium Batteriesʺ in the appendix of Part 4 (below).
As per Section 5.12 of the TDG Regulations, when batteries (Classes 4, 8 or 9) are transported in small means of containment, it must be done in compliance with Packing Instruction 801 of Transport Canada Standard TP14850E. This packing instruction states that:
Note: This shipment does not qualify as an overpack as defined in Section 1.4 of the TDG Regulations, since the batteries are placed directly on the pallet rather than in separate small means of containment.
A lithium ion or lithium metal battery packed with equipment is not embedded in the device. An example would be a power tool packed alongside a spare battery.
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Yes. In Canada, the shipping and importing of lithium batteries is subject to the Transportation of Dangerous Goods Act, 1992 (TDG Act) and its regulations. They are considered dangerous goods much like gasoline, propane and sulfuric acid.
Under Section 4.15 of the TDG Regulations, the primary class placard for every dangerous good transported in a large means of containment (Class 9, for example) must be displayed on each side and at each end of the large means of containment (the truck, for example).
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To learn about dangerous goods safety mark requirements for batteries transported by air, please consult Part 12 of the TDG Regulations.
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Safety marks to display on the means of containmentFootnote *: The appropriate lithium battery mark in accordance with Section 4.24 of the TDG Regulations.
As per Section 4.15 of the TDG Regulations, the primary class placard for every dangerous good transported in a large means of containment (Class 9, for example) must be displayed on each side and at each end of the large means of containment (the truck, for example).
Part 6 of the TDG Regulations requires that a person who handles, offers for transport or transports dangerous goods, be adequately trained and hold a valid training certificate. However, a person who does not have proper training or a valid training certificate may perform these activities in the presence and under direct supervision of a person who is properly trained and holds a valid training certificate.
Special cases are situations partly or fully exempt from the TDG Regulations. These special cases are found in Sections 1.15 to 1.50 of the Regulations.
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A battery consists of two or more cells connected electrically and equipped with features such as casings, terminals, markings, and protective devices to ensure they work properly (e.g., cordless phone batteries, etc.).
As such, these exemptions apply only to the transport of batteries in means of containment with a gross mass of less than 30 kg. If batteries are transported on pallets, the pallets are considered the means of containment. Therefore, the calculation of the gross mass takes the pallet’s mass into account.
As per Section 4.15 of the TDG Regulations, the primary class placard for every dangerous good transported in a large means of containment (Class 9, for example) must be displayed on each side and at each end of the large means of containment (the truck, for example).
A truck transports batteries that are placed directly on a pallet and secured by shrink wrap. The pallet’s total capacity (volume) is 450 litres or less. What labels and/or placards are required?
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When shipping batteries by marine or air transport, consult Parts 11 and 12 of the TDG Regulations as well as the following documents:
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If this pallet is the only small means of containment transported, the shipping document will display “1” in the column indicating the number of small means of containment on which labels are displayed.
To ship or import batteries internationally by air, Part 12 of the TDG Regulations requires that you comply with the ICAO Technical Instructions and additional requirements under the TDG Regulations.
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Note: Other information may be required depending on the mode of transport. For more information on shipping documents, consult Part 3 of the TDG Regulations and the following TDG Bulletin: TDG Bulletin - Shipping Documents.
Special Provision 34 exempts a person from the TDG Regulations (except for Parts 1 and 2) if lithium cells or batteries are handled, offered for transport or transported on a road vehicle, railway vehicle or vessel on a domestic voyage and if certain conditions are met.
No. A paper copy of the shipping document must always accompany the dangerous goods. Even if the consignor sends electronic copies to the carrier, the carrier must print the document before transporting the dangerous goods and keep a copy of it with the shipment.
Under Section 4.15 of the TDG Regulations, the primary class placard for every dangerous good transported in a large means of containment (Class 9, for example) must be displayed on each side and at each end of the large means of containment (the truck, for example).
Note: If the pallet is not considered an overpack, Section 4.10.1 of the TDG Regulations does not apply and the word OVERPACK will not be required. However, the pallet will still need to meet dangerous goods safety marks requirements for small means of containment.
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Safety Marks to Display on the Means of ContainmentFootnote **: The appropriate lithium battery mark in accordance with Section 4.24 of the TDG Regulations.
However, means of containment built to these two standards are not designed for batteries. Therefore, to transport batteries in a non-standardized means of containment, you must apply for an equivalency certificate delivered by Transport Canada.
Special Provision 138 of the TDG Regulations states that lithium metal and lithium ion cells or batteries and equipment containing them, transported for disposal or recycling:
However, when dangerous goods are shipped by air, the shipping document must have, in the left and right margins, red hatchings that slant to the left or right as shown below. In addition, Section 12.2 of the TDG Regulations states that the shipping document must be completed in accordance with Chapter 4, Documentation, of Part 5, Shipper's Responsibilities, of the ICAO Technical Instructions.
Yes. Special Provision 149 of the TDG Regulations states that UN3090, LITHIUM METAL BATTERIES and UN3480, LITHIUM ION BATTERIES are forbidden for transport as cargo on a passenger aircraft.
This bulletin explains battery transport requirements. It does not change, create, amend or suggest deviations to the Transportation of Dangerous Goods (TDG) Regulations. For specific details, consult the TDG Regulations.
A lithium ion or lithium metal battery contained in equipment means a battery that is embedded in the device. Examples include calculators, laptop computers, or watches.
Failure to comply with the TDG Act and Regulations may lead to fines and/or imprisonment. For more information, visit the TDG website.
Does not apply to means of containment containing button cell batteries installed in equipment, including circuit boards, or no more than four cells installed in equipment or no more than two batteries installed in equipment.
Note: This requirement does not apply to cells and batteries installed in devices that are intentionally active during transport such as radio frequency identification transmitters, watches and sensors, and that are not capable of generating a dangerous evolution of heat.
The batteries do not need labels since the TDG Regulations require them only on small means of containment and batteries are not considered means of containment.
If each cell and battery type passed all the tests in subsection 2.43.1(2) of Part 2 of the TDG Regulations (Classification), then see below for additional information.
Note: The TDG Regulations allow an exemption to placard requirements if the gross mass of dangerous goods in a road or railway vehicle is 500 kg or less. However, placards may still be voluntarily displayed. For more details, consult Sections 4.16.1 and 4.1.1 of the TDG Regulations.
The outer means of containment or the overpack must be marked legibly and visibly on a contrasting background with the words “Damaged/Defective Lithium Ion Batteries” or “piles au lithium ionique endommagées/défectueuses” or “Damaged/Defective Lithium Metal Batteries” or “piles au lithium métal endommagées/défectueuses”, as applicable.
Note: The TDG Regulations allow an exemption to placard requirements if the gross mass of dangerous goods in a road or railway vehicle is 500 kg or less. However, placards may still be voluntarily displayed. For more details, consult Sections 4.16.1 and 4.1.1 of the TDG Regulations.
Section 1.15 (150 kg Gross Mass Exemption) and Section 1.16 (500 kg Gross Mass Exemption) could apply to the transport of batteries. The two sections limit the gross mass of batteries to 150 or 500 kg respectively and require them to be transported in one or more means of containment, each with a gross mass of 30 kg or less.
Since the term “battery” is not defined in the TDG Regulations, we must rely on the dictionary definition. The French dictionary Larousse defines a battery as a device that stores energy to be released as needed (for example, cells or batteries).
The batteries do not need labels, since the TDG Regulations require them only on small means of containment and batteries are not considered means of containment.
Note: Under the TDG Regulations, safety marks do not have to be displayed directly on batteries because they are considered dangerous goods and not means of containment.
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Note: The TDG Regulations allow an exemption to placard requirements if the gross mass of dangerous goods in a road or railway vehicle is 500 kg or less. However, placards may still be voluntarily displayed. For more details, consult Sections 4.16.1 and 4.1.1 of the TDG Regulations.
A truck transports batteries that are placed in small means of containment and then put on a pallet and secured by shrink wrap. The pallet’s total capacity (volume) is 450 litres or less. What labels and/or placards are required?
Yes. Special Provision 39 states that the TDG Regulations (except for Parts 1 and 2) do not apply to these dangerous goods if:
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A cell is a single encased electrochemical unit (one positive and one negative electrode) with a voltage differential across its two terminals (e.g., AA and AAA batteries).
However, the palette must meet dangerous goods safety marks requirements for large means of containment under Section 4.15 of the TDG Regulations. Therefore, unless otherwise indicated, any large means of containment that transports dangerous goods must be standardized. Since no standard adopted by reference in the TDG Regulations may be used to transport batteries in a large means of containment, an equivalency certificate must be obtained from Transport Canada. This certificate will indicate which safety marks to display on the palette and/or the truck.
Yes. Unless exempt from the TDG Regulations through a special case, special provision or equivalency certificate, battery shipments must fully comply with the TDG Regulations.
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Since the batteries are in small means of containment, the labelling requirements of Part 4 of the TDG Regulations apply.
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To learn how to apply for an equivalency certificate, please visit the Equivalency Certificates or consult Part 14 of the TDG Regulations.
A truck transports batteries that are placed in small means of containment and then put on a pallet and secured by shrink wrap. The pallet’s total capacity (volume) is greater than 450 litres. What labels and/or placards are required?
To learn about dangerous goods safety marks requirements for batteries transported by vessel, please consult Part 11 of the TDG Regulations.
Note: A special case (Part 1 of the TDG Regulations) or a special provision (Schedule 2 of the TDG Regulations) may exempt you from these training requirements.
If each cell and battery type has not passed all the tests in subsection 2.43.1(2) of Part 2 of the TDG Regulations (Classification) then an exemption cannot be used.