Cross-border operations guide ยท November 6, 2026

Classifying Lithium Batteries: Chapter 85 and the Dangerous Goods Overlap

Short answer: Rechargeable lithium-ion batteries classify at 8507.60, and primary lithium batteries at 8506.50. The same code that sets the duty also triggers dangerous goods rules: UN3480 or UN3481, and a 30 percent state-of-charge limit for air freight.

8507.60, and what it excludes

Lithium batteries fall under Chapter 85 of the HS system, specifically under codes 8506 for primary batteries and 8507 for electric accumulators. The most common classification for lithium-ion battery packs is 8507.60, but the correct code depends on several factors: whether the batteries are assembled or unassembled, whether they are rechargeable or single-use, their intended application, and their state of charge. Precision matters because the code is the first step in ensuring the shipment meets hazardous materials regulations.

The international HS code for lithium-ion batteries is 8507.60, officially described as lithium-ion accumulators, covering rechargeable cells, batteries, packs, and modules under WCO HS 2022, effective through 2026. For lithium-ion battery packs exported to the United States, the applicable HTS code is typically 8507.6060, which further specifies batteries designed for use in vehicles or portable electronic devices. Primary lithium batteries, the non-rechargeable kind, classify separately at 8506.50, at a lower tariff rate in many regions.

The exclusions are where importers get caught. The 8507.60 heading excludes non-rechargeable primary batteries, spent units, and batteries embedded in finished equipment. A battery pack with electronics can classify at 8507.80 instead, and may be classified as electronic goods rather than as a battery. A 10 kWh EV battery pack falls under 8507.60.0020 as an HTS example, attracting 2.5 percent US duty plus Section 301 tariffs from China origins. The application decides the line, not the chemistry alone.

The dangerous goods overlap

The correct HS code has to be paired with the appropriate dangerous goods documentation. Lithium batteries are classified as dangerous goods under IATA and IMO rules, with UN3480 for standalone lithium-ion cells and batteries and UN3481 for batteries packed with or contained in equipment. That classification mandates testing like UN38.3, and an incorrect battery HS code can halt air freight, forcing a costly sea reroute.

For air freight, IATA DGR 2026, effective January 1, 2026, enforces a state-of-charge limit of 30 percent or less for high-capacity units over 2.7 watt-hours, reducing fire risk under packing instructions 966 Sections I and II. Sea shipments follow IMDG Special Provisions 188 and 230, limiting quantities per package. Road and rail align with the UN Model Regulations. The HS code and the transport rule are separate systems, and a shipment has to satisfy both.

The documentation list is specific: a Shipper's Declaration for Dangerous Goods for air shipments, material safety data sheets providing the battery composition and hazards, and proper packaging and labeling under Class 9 hazardous materials standards. The US kept lithium-ion surcharges in place through executive order 14389 in February 2026 despite some tariff reliefs, and PHMSA is phasing out phone numbers on lithium labels by December 31, 2026. No HS revisions are scheduled until 2027, but national refinements persist.

Getting the entry right

Classify by the battery's actual state, not its marketing. A lithium-ion pack is 8507.60. A primary lithium cell is 8506.50. A battery embedded in a finished device may not be a battery entry at all, and a pack with integrated electronics may be 8507.80. The General Rules for the Interpretation of the Harmonized System decide, and a binding tariff ruling from CBP is worth getting before the first large shipment.

Then match the transport paperwork to the code. The UN number, the state-of-charge limit, and the packing instruction all flow from the battery type, and the carrier will refuse a shipment whose declaration does not match its contents. The HS code is the first step, not the last one, and the shipment that gets the code right but the dangerous goods paperwork wrong still does not fly.

And confirm the duty with the broker, including the Section 301 layer. The US rate on 8507.60.00 is around 2.5 percent, with about 25 percent more on China-origin goods, and the EU rate is around 4.7 percent with a battery passport regulation incoming. The duty is knowable in advance. The reroute, the refused shipment, and the storage fees are not, and they are what an incorrect classification actually costs.

Keep reading: Classifying LED strip lights: the fixture, the lamp, and the roll in between, Classifying smartwatches: communication device of heading 8517 or watch of chapter 91.

Frequently asked questions

What exactly does 8507.60 cover?

8507.60 covers lithium-ion accumulators, the rechargeable cells, batteries, packs, and modules, whether standalone or with integrated circuits. In the United States it extends to 8507.60.00, and for vehicle or portable electronic use the line is often 8507.6060. It excludes non-rechargeable primary batteries, spent units, and batteries embedded in finished equipment.

What is the difference between UN3480 and UN3481?

UN3480 is standalone lithium-ion cells and batteries. UN3481 is lithium-ion batteries packed with equipment or contained in equipment. The distinction matters because the packing instructions, state-of-charge limits, and documentation differ, and a shipment declared under the wrong UN number can be refused at the airport.

Do lithium batteries need dangerous goods paperwork even with the right HS code?

Yes. Lithium batteries are classified as dangerous goods by the IATA, the IMO, and the DOT, and the correct HS code has to be paired with the right documentation: a Shipper's Declaration for Dangerous Goods for air shipments, material safety data sheets, and proper packaging and labeling under Class 9 hazardous materials standards.

What duty do lithium-ion batteries pay into the US?

The US duty on 8507.60.00 is around 2.5 percent, but Section 301 adds about 25 percent on China-origin goods, for a total near 28 percent. The duty is the smaller problem: an incorrect battery HS code can halt air freight and force a costly sea reroute, which costs more than the duty ever would.