Lithium-ion batteries are currently one of the most popular types of energy sources used in portable devices, consumer electronics, and increasingly in electromobility. Due to their specific chemical composition and potentially hazardous properties during improper use or transportation, a question arises: under the current chemical regulations, are manufacturers and suppliers of lithium-ion batteries required to prepare Safety Data Sheets (SDS)?

Batteries as "articles" under the REACH Regulation

 

Regulation (EC) No. 1907/2006 (known as REACH) defines the term "article" in Article 3(3):

“‘Article’ means an object which during production is given a specific shape, surface or design which determines its function to a greater degree than its chemical composition.”

A lithium-ion battery, as a finished product – composed of cells, separators, electrolyte, and a casing – meets the criteria of an article. Its function (providing electrical energy) is primarily determined by its design and form, rather than directly by the substances inside the cells.

No obligation to provide an SDS for articles

 

According to Article 31(1) of the REACH Regulation, a Safety Data Sheet is required for substances and mixtures. Article 31 makes no mention of an obligation to provide an SDS for articles.

This means that articles such as lithium-ion batteries are formally exempt from the requirement to provide an SDS. This results from the fact that REACH primarily regulates the circulation of substances and mixtures, not ready-to-use mechanical or electronic products.

Why are SDSs still created for batteries?

 

Although the REACH Regulation does not impose an obligation on manufacturers of lithium-ion batteries to prepare SDSs, in practice, many companies choose to develop them due to:

Transport requirements and regulations

• The transport of lithium-ion batteries is classified as the transport of dangerous goods (in accordance with ADR, IATA DGR, or IMDG).

• Carriers increasingly require SDSs to verify packaging, labeling, and emergency procedures (e.g. in case of electrolyte leakage or fire).

Transparency for the customer

• Business clients increasingly demand documentation confirming product safety.

• An SDS can also be used to fulfill requirements under Article 33 of the REACH Regulation (information on substances in articles).

• SDSs are structured and widely recognized documents that provide information on hazards, protective measures, emergency procedures, and applicable legal requirements – even if only loosely related to chemical legislation.

Certifications and management systems

• ISO standards (e.g., ISO 9001 or ISO 14001) encourage comprehensive documentation of product and process safety. The SDS provides a convenient and clearly defined format for storing such information.

 

UN numbers for lithium-ion batteries

 

Since specific UN numbers for lithium-ion batteries were introduced in transport regulations, the popularity of SDSs for these products has increased further. During air, road, or sea transport, lithium-ion batteries may be classified under one of the following UN numbers:

• UN 3480 – LITHIUM-ION BATTERIES

• UN 3481 – LITHIUM-ION BATTERIES IN EQUIPMENT

 

Other types of batteries may require different UN numbers, for example:

• UN 3090 – LITHIUM METAL BATTERIES

• UN 3091 – LITHIUM METAL BATTERIES IN EQUIPMENT

 

Or newly introduced entries:

• UN 3551 – SODIUM-ION BATTERIES

• UN 3552 – SODIUM-ION BATTERIES IN EQUIPMENT

 

Summary

 

• According to REACH, lithium-ion batteries, as articles, are not subject to the requirement of having a Safety Data Sheet.

• In practice, many companies voluntarily prepare SDSs for batteries, primarily due to transport requirements (UN 3480 / UN 3481), customer expectations, and quality management standards.

• Having an SDS facilitates compliance with carrier requirements and minimizes the risk of transport refusal, thereby streamlining and safeguarding logistics processes.