Hauling lithium batteries in NC: Class 9 rules for small carriers

The short version

Lithium batteries are Class 9 hazardous materials. That covers both lithium ion (rechargeable) and lithium metal (mostly single use) batteries, loose or inside equipment. [1][2]

Domestic Class 9 loads don't need placards. Because of that, a load of lithium batteries alone usually doesn't call for an H endorsement. Papers, packaging and marks still apply. [5][6]

Recycling and damaged battery loads have their own rules. These are the loads small carriers most often get from NC retailers, collectors and recyclers. [1][16]

The older lithium battery mark is allowed only through Dec. 31, 2026. North Carolina's ban on landfilling lithium-ion batteries starts Dec. 1, 2026. [1][14]

This is general information as of November 2026, not legal advice. For your own load, read 49 CFR 173.185 or ask the shipper's hazmat contact. Our Toyota Liberty battery plant guide covers watt-hour marking and pallet rules. [1]

Lithium ion vs lithium metal: the four UN numbers

The federal hazmat table has four main entries. UN3480 is lithium ion batteries. UN3481 is lithium ion batteries packed with or contained in equipment. [2]

UN3090 is lithium metal batteries, including lithium alloy. UN3091 is lithium metal batteries packed with or contained in equipment. All four are Class 9 and point to 173.185. [2]

"Contained in" means the battery is installed, like a laptop or cordless drill in its box. "Packed with" means a spare battery rides in the same box as the device. [2][3]

E-bikes, scooters, electric cars, golf carts and lawn tractors with batteries installed are UN3171, battery-powered vehicle. Lawnmowers and other equipment use the "contained in equipment" entries. Hybrids with an engine use the vehicle or engine entries. [2][3]

By highway, vehicles shipped under 173.220 are excepted from the rest of the hazmat rules. The lithium battery must be a tested type, fastened in its holder and protected from damage and short circuits. [13]

The difference matters in a fire. Responders use ERG Guide 147 for lithium ion batteries and Guide 138, for water-reactive materials, for lithium metal batteries. [17][18]

What the papers, marks and labels should look like

A fully regulated load needs a hazmat shipping paper. The description shows the UN number, proper shipping name, class 9 and total quantity, such as "UN3480, Lithium ion batteries, 9" plus a weight. [9][2]

You may not accept or haul it without that paper. The first carrier also needs the shipper's signed certification on it. [10]

Keep the paper tabbed or on top of your other papers. While driving, it must be within reach with your belt on, and visible or in the driver's door pouch. [10]

Emergency response information and an emergency phone number must be on hand the whole time. That duty doesn't apply to material excepted from shipping papers. [11]

Fully regulated packages carry the Class 9 lithium battery label. It has seven black stripes on the top half and a broken, burning battery symbol over a "9" on the bottom. [3][4]

Our tip: if the bill says UN3480 but the boxes show only a small lithium mark, or the reverse, call the shipper before you leave the dock. [1][10]

Small battery shipments and the lithium battery mark

Smaller batteries can skip shipping papers, labels, placards and emergency information under 173.185(c). The limits are 20 Wh per lithium ion cell and 100 Wh per battery. [1]

For lithium metal, the limits are 1 gram of lithium per cell and 2 grams per battery. By highway or rail only, they rise to 60 Wh and 300 Wh for ion and 5 g and 25 g for metal. [1]

Those higher highway limits need a mark saying the batteries are forbidden aboard aircraft and vessel. Our tip: don't let that freight get cross-docked onto air. [1]

Loose small battery packages are capped at 30 kg (66 lb) gross. Batteries packed with or in equipment don't have that cap. Each package must survive a 1.2 meter drop test. [1]

Most of these packages show the lithium battery mark. It is a rectangle with red hatched edges, a battery symbol and the UN number, at least 100 by 100 mm, or 100 by 70 mm on small boxes. [1]

Overpacks need the mark visible or repeated outside, plus the word "OVERPACK" in letters at least 12 mm high. [1]

Time-sensitive: the mark design in effect on May 9, 2024 may be used only until Dec. 31, 2026. Starting Jan. 1, 2027, packages need the current mark. Our tip: flag older stock you see on loads this winter. [1]

Recycling and disposal loads

Section 173.185(d) covers lithium batteries going by motor vehicle to a permitted storage facility or disposal site, or for recycling. It includes batteries inside equipment. [1]

Those batteries skip the UN 38.3 testing and records rules and the UN-spec packaging rules. They must still ride in strong outer packaging that meets the general packaging rules. [1]

That exception does not drop the papers, labels or other hazard communication. Those are lifted only when the batteries also meet the small battery size, packaging and marking conditions. [1]

Every lithium battery load still has to be packed to prevent short circuits, damage from shifting and accidental activation. Batteries likely to spark or overheat are forbidden unless packed to prevent it. [1][12]

North Carolina has a lot of this freight. NC DEQ counted 38 battery recyclers collecting or processing lithium-ion batteries from the state in a June 2026 report. Most are collectors or aggregators. [16]

Those recyclers cluster around Charlotte, Raleigh and Garner, Greensboro and Winston-Salem. They told DEQ that poor packing, like mixed chemistries and unprotected terminals, creates fire risk for transporters. [16]

Our tip: on a pickup from a drop-off site, look for taped terminals or bagged batteries and closed, sturdy containers. If a drum holds loose, mixed batteries, ask the shipper to repack it before you load it. [1][16]

Damaged, defective and recalled batteries

Batteries that are damaged, or that the maker calls defective for safety reasons, fall under 173.185(f) if they could overheat, catch fire or short. Recall returns to the maker are an example. [1]

They may go only by highway, rail or vessel, never by air. Each cell or battery goes in its own non-metallic inner packaging. [1]

The inner packaging is surrounded by cushioning that won't burn, won't conduct electricity and absorbs liquid. Then it goes in a Packing Group I box or drum, or a large packaging for one battery. [1]

The outer package is marked "Damaged/defective lithium ion battery" or the lithium metal version, in letters at least 12 mm high. [1]

NC DEQ calls these DDR batteries: swollen, overheating, smoking, leaking, physically damaged or recalled. It tells businesses to plan special packing and transport for them. [15]

These loads cost more to handle. In DEQ's 2025 survey, recyclers charged $1.50 to $20 a pound for DDR batteries, about $8.83 on average. [16]

Placards, CDL, registration and training

A Class 9 placard is not required for domestic transportation. A bulk packaging must still show the UN number on a Class 9 placard, orange panel or white square-on-point display. [5]

For CDL purposes, a load is hazardous material when it must be placarded. So a domestic lithium battery load with no other hazmat generally doesn't need an H endorsement. Confirm with your carrier's safety staff. [6][5]

Mixed loads change this. Other hazmat on the truck may need placards, and then you need the endorsement for that load. [5][6]

PHMSA registration is triggered by loads that need placards and by large bulk packagings. Non-bulk Class 9 alone usually doesn't trigger it, but check the list in 107.601 for your freight. [7]

Hazmat employees, including drivers, need general awareness, function-specific, safety and security awareness training, at least every three years. [8]

A new hazmat employee can work under direct supervision of a trained employee for up to 90 days before finishing training. [8]

If a battery load smokes or catches fire

Lithium ion batteries hold a flammable electrolyte. When damaged or heated past about 150 C (302 F), they can vent, ignite, throw sparks and set off nearby batteries. [17]

The ERG says to call 911 first, then the emergency number on the shipping paper. Keep people away and stay upwind and uphill. [17]

Burning batteries can give off toxic gases, including hydrogen fluoride. For a trailer fire, the guide tells responders to isolate 1/3 mile in all directions. [17]

A battery fire can reignite up to weeks later. For a large battery fire, responders may let it burn and protect what's around it. [17]

One real case: on I-20 in Texas in February 2023, a FedEx Freight driver saw smoke from a trailer carrying two EV batteries. The driver called 911 and dropped the trailers. Both burned, and no one was hurt. [19]

Our tip: pull well off the road, away from buildings. If you can do it safely, drop the trailer, then move away and wait for firefighters. Hand them the papers. [17][19]

North Carolina's Dec. 1, 2026 landfill ban

Starting Dec. 1, 2026, state law bars knowingly putting lithium-ion batteries in landfills or permitted incinerators in North Carolina. [14]

DEQ says the ban covers batteries inside devices and rechargeable tools, but not alkaline batteries. It names retailers, warehouses, contractors, repair shops and auto and e-bike businesses. [15]

DEQ tells those businesses to set up collection areas, train staff and coordinate with haulers. For shipping rules, it points them to PHMSA. [15]

Our tip: expect more battery pickups from stores, shops and county drop-off sites this winter. Ask whether the load moves under the recycling exception or as fully regulated hazmat before you quote it. [1][15][16]