When powered by lithium-ion batteries and transported with the batteries installed, such vehicles are classified under UN No. 3556.
Classification according to ADR/RID 2025, IMDG Code (amdt. 42-24):
UN 3556 VEHICLE, LITHIUM ION BATTERY POWERED, class 9
UN 3556 was introduced in 2025 to classify battery-powered vehicles more accurately. The new UN No. 3556 may be applied from 1 January 2025; however, transitional periods have been established to allow continued use of the previous classification, UN 3171. For road transport (ADR), the use of UN 3171 is permitted until 30 June 2025. For sea transport (IMDG Code), the use of UN 3171 is permitted until 31 December 2025.
According to dangerous goods regulations, vehicles are defined as self-propelled apparatuses designed to transport people or goods. This includes not only conventional transport modes like cars, motorcycles, trucks, and boats, but also non-traditional or personal mobility devices such as e-scooters, hoverboards, wheelchairs, lawn tractors, and self-propelled machinery used in farming, construction, or recreation.
Lithium batteries installed in vehicles must comply with the testing requirements specified in Section 38.3 of the UN Manual of Tests and Criteria (commonly known as “UN 38.3 testing”). However, this requirement does not apply to pre-production prototypes or batteries from production runs of no more than 100 units, provided they are installed in vehicles and transported for testing purposes.
Dangerous goods such as batteries, airbags, fire extinguishers, compressed gas accumulators, safety devices, and other components essential to the vehicle’s operation or the safety of its operator or passengers must be securely installed and are otherwise exempt from the dangerous goods regulations.
Both the ADR/RID and the IMDG Code include Special Provisions (SPs) for the transport of vehicles powered by lithium-ion batteries, though the provisions and their numbering differ:
SP 388 (ADR/RID & IMDG): Provides an explanation of vehicle classification, including which vehicles are covered and the criteria for lithium batteries installed in them.
SP 666 (ADR/RID only): Provides exemptions for vehicles when transported by road/railway.
SP 961 (IMDG only): Provides exemptions for certain vehicles transported by sea.
SP 962 (IMDG only): Applies when the conditions of SP 961 are not met; such vehicles must be classified under Class 9 and transported according to full IMDG Code requirements.
Vehicles powered by lithium-ion batteries, when carried as cargo, are exempt from all other ADR provisions if conditions detailed in paragraph (e) of SP666 are met.
SP 666 (e): Vehicles that are fully enclosed by packagings, crates or other means that prevent ready identification are subject to the marking and labelling requirements of Chapter 5.2.
Operational Checklist (UN 3556 - SP 666 - ADR 2025):
Marking and labelling (“UN 3556” and No. 9A label):
✔ Yes – Required if vehicles are fully enclosed and not readily identifiable (SP 666(e)).
Dangerous Goods Declaration (DGD):
✘ Not required.
Vehicle crew requirements, safety equipment, operational rules, and documentation:
✘ Not applicable.
Dangerous goods training:
✘ Not required.
Important Note:
Since its entry into force in January 2025, it has become evident that the wording of SP 666(e) lacks sufficient clarity, leading to difficulties in its practical application. As a result, discussions are ongoing regarding possible amendments or clarifications to this provision. In the meantime, ADR countries have the option to sign the multilateral agreement M363 to postpone the implementation of SP 666(e) in ADR 2025 until a consensus is reached.
Special provision 961 requires no marking, no labelling, no placarding, no documentation, and no special handling conditions other than those detailed in special provision 961.
SP961 + Lithium-ion battery-powered vehicles driven on and off the ship on their own wheels
Lithium-ion battery-powered vehicles that are driven on and off ro-ro vessels on their own wheels are exempt under SP961.1, provided the following conditions are met:
The vehicle is stowed in a vehicle space, special category space, ro-ro space, or on the weather deck of a ro-ro ship; or
In a cargo space designated by the Administration (flag State) under SOLAS 74, Chapter II-2, Regulation 20 as specifically designed and approved for vehicle carriage.
There are no signs of leakage from the battery.
SP 961 + Lithium-ion battery-powered vehicles driven in containers
Special Provision 961.1 of the IMDG Code does not apply to containers carrying vehicles. If a vehicle (UN 3556) is loaded into a container and the container is then transported on a ro-ro vessel or another type of ship, SP 961.1 is not applicable. Instead, the shipment must comply with the requirements of SP 962.
SP 961 + Lithium-ion battery-powered vehicles driven carried as load on a CTU that is a vehicle
When lithium-ion battery-powered vehicles (classified under UN 3556) are transported as cargo on a cargo transport unit (CTU) that is itself a vehicle—such as a trailer or truck—there is ambiguity as to whether such transport arrangements fall within the scope of Special Provision 961.1. Other exceptions in SP 961.2 to 961.6 are not applicable to vehicles classified as UN 3556.
This includes, for example, an electric car being transported on a car trailer or electric scooters loaded inside a truck.
There is no unified interpretation if these vehicles carrying UN 3556 vehicles are covered by the exception in SP 961.1. Competent authorities and regulatory bodies in different countries interpret the provision in various ways. If there is uncertainty regarding the applicability of the exception in SP 961.1 for the route, it is advisable for the shipment to comply with the provisions of SP 962.
Vehicles powered by lithium-ion batteries that do not meet the conditions of Special Provision 961 must be classified as Class 9 and transported in accordance with the requirements specified in Special Provision 962, as follows:
No Leakage: Vehicles must show no signs of leakage from the installed batteries.
Battery Compliance: Batteries must comply with the requirements of Special Provision 388, and be protected against damage, short circuits, and accidental activation during transport.
Marking, Labelling, and Placarding: These IMDG Code provisions in Chapter 5.2 and 5.3 apply only if the vehicle is fully enclosed in packaging, crates, or other means that prevent ready identification.
Operational Checklist (UN 3556 - SP 962 - IMDG Code amdt 42-24):
Marking & Labelling of Packages (Chapter 5.2):
✔ Yes, if the vehicle is fully enclosed – Packages must be marked: “UN 3556 VEHICLE, LITHIUM ION BATTERY POWERED” and labelled with Label No. 9A.
Placarding & Marking of Cargo Transport Units (CTUs) (Chapter 5.3):
✔ Yes, if the vehicle is fully enclosed – CTU must display Placard No. 9. Additionally, if the CTU contains packaged dangerous goods exceeding 4000 kg gross mass, assigned only one UN number (UN 3556), and no other dangerous goods, it must also display “UN 3556”.
Dangerous Goods Declaration (DGD):
✔ Yes
Stowage:
✔ Category A
Dangerous goods training:
✔ Yes - Personnel must be trained in accordance with Chapter 1.3.