With the surge in global exports of new energy vehicles, the transportation compliance issues related to UN3171 (lithium battery-powered vehicles) have garnered significant attention. Whether a “dangerous goods certificate” is necessary has become a focal point for the industry. This article will systematically review policy differences and alternatives across various regions to help companies mitigate compliance risks.

The Special Status of Hazardous Goods Certificates in the Export of New Energy Vehicles

In traditional hazardous materials transportation, the “Outbound Hazardous Goods Transportation Packaging Use Certification Result Sheet” (commonly known as the dangerous goods certificate) is a core document. However, due to their uniqueness, new energy vehicles have differentiated requirements:

• Volume exemption: The outer packaging dimensions of complete vehicles far exceed those of conventional hazardous materials, making it physically impossible to conduct traditional dangerous goods inspections.
• Policy flexibility: Ports such as Shenzhen and Ningbo are piloting a “virtual dangerous goods certificate” system that replaces physical certificates with electronic filings.
• Alternative solution: A combination of UN38.3 test reports and MSDS documents can meet the equivalency requirements of some customs authorities.

Comparison of Regional Policy Practices

List of essential core documents that cannot be omitted

Even if exempt from dangerous goods declaration, the following documents must be complete:

• UN38.3 test report (covering 8 tests including vibration, shock, extreme temperature, etc.)
• MSDS material safety data sheet (must include electrolyte composition percentages)
• Short circuit prevention statement (proving insulation treatment of battery terminals)
• Marine transport certification report (issued by a CNAS accredited laboratory)
• Packing operation record (including temperature and humidity monitoring data)

Operational Risk Warning

In 2023, a certain car company had its goods detained at the destination port due to the following oversights:

• Failure to update the MSDS with electrolyte composition (the new national standard requires labeling of LiPF6 concentration).
• Ignoring the new regulations at Rotterdam Port in the Netherlands regarding battery SOC ≤ 50%.
• The container did not display the updated lithium battery label (starting from 2023, a QR code for traceability must be added).

It is recommended that companies establish a “four-in-one” management system:

• Confirm special requirements at each node of the transportation route in advance.
• Use blockchain technology to achieve document anti-counterfeiting.
• Train certified hazardous materials declaration specialists.
• Purchase specialized insurance for hazardous materials transportation.

Industry Trend Outlook

The International Maritime Organization (IMO) is promoting:

• The potential implementation of global mutual recognition of electronic Dangerous Goods Declarations starting in 2026.
• The development of specialized transport containers for new energy vehicles (equipped with automatic fire extinguishing devices).
• The establishment of a shared database for blacklisting lithium battery transportation.