Newsletter 01/2024

22.03.2024: Neuerungen/Änderungen 2024/2025 und 2027 

We provide information on the latest news from the cell/battery shipping sector as part of our semi-annual online seminars on new and changed regulations.  

On 22nd March 2024 we presented the planned and largely already finalized changes as of 1 January 2025. This will be followed by a brief outlook on the regulatory landscape from 2027.  
 
Online Seminar on New and changed regulations 2024/2025 and 2027 

22.03.2024, Start 1.30 pm German Time (UTC+1), End 2.30 pm (UTC+2) 

For Lithium Battery Service License Customer this online seminar is free of charge. 

For Not-Yet-Customers the participation fee is EUR 150,— plus VAT for companies based in Germany. 
 
Here the link for participation: 
https://www.strober-partner.de/kurs/online-seminar-new-and-changed-regulations-for-shipping-lithium-cells-and-batteries-on-all-transport-modes-2024-to-2027/ 
 
 

You are welcome to send us questions from your business practice in advance. We will address these questions during the online seminar and where possible present solutions. 
 
Of course questions can also be asked at any time during the online seminar, preferably via the chat function. We will explain this again at the beginning of the online seminar. 

2. On our own behalf - change in legal structure and name 

At the moment our GbR is changing to become a GmbH in two steps. The first step is already completed with the GbR changing to a Partnership. Our official name is right now: 

ABS All Battery Service Werny und Glimsche Partnerschaft Unternehmensberater 

The second step will be completed by the end of March when we will then have the legal structure and name: 

All Battery Service GmbH 

In this context we have also changed our bank details. We have switched to GLS Bank, which plays a pioneering role in terms of the sustainability of investments. 

Our new IBAN is: 

 DE96 4306 0967 1324 4012 00 

3. Air Transport: State of Charge max. 30% will probably be extended 

The ICAO Dangerous Goods Panel (DGP) has discussed extending the regulation of the maximum state of charge (SoC). Until now this regulation has only applied to the shipment of cells/batteries without equipment in accordance with packing instruction 965. From 1 January 2025 (subject to final approval by the ANC (Air Navigation Commission), the subordinatebody to the DGP), it should also apply to battery-powered vehicles and possibly also hybrid vehicles (UN 3166). As there were some concerns and comments from DGP members at the last meeting, it is possible that this change will not yet be implemented on 1 January 2025.   

4. Air Transport: LH Lufthansa Variation: Clarification on the acceptance of vehicles 

In connection with the fire on board a ship carrying vehicles as cargo, Lufthansa announced a ban on the transport of battery-powered vehicles (UN 3171 and hybrid vehicles (UN 3166)) last year. In our newsletter we had mentioned the complete UN 3166. Lufthansa has now clarified that the embargo on UN 3166 only applies to hybrid vehicles, 

This embargo is currently still in place, Lufthansa confirmed in response to our question about its validity. 

5. Air Transport: Reminder: New Variation from Argentina RAG-01 refers only to inner Argentinian flights 

As already described in our newsletter 07-2023, RAG-01 only applies to transport within Argentina. 

There was a clarification on RAG-01 published in the IATA DGR by the Argentinian aviation authority.  

The requirement to have the documentation and labelling in Spanish only applies to the transport of dangerous goods with Argentina as the country of departure and destination, i.e. only for flights within Argentina. Argentina has announced this via an amendment to the ICAO TI 2025/2026.  

IATA will of course include this amendment in an addendum to the 65th IATA DGR 2024 as soon as one is published. 

6. All transport modes: USA: emergency information: Where does this requirement come from? 

We have included this point in our newsletter because a customer asked us why an emergency number is required in their IMO declaration for maritime transport. 

The USA has its own federal law 49 CFR and as soon as a shipment of dangerous goods reaches the territory of the USA, emergency information is required. 

I had enquired about the interpretation in air transport in 2017. The answer from PHMSA 170082 can be found under this link: 

https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/hazmat/interpretations/56866/170082.pdf 

Here is the link to the corresponding passage on emergency information in 49 CFR: 

https://www.ecfr.gov/current/title-49/subtitle-B/chapter-I/subchapter-C/part-172/subpart-G/section-172.600 

The refusal of the shipping company was therefore not a deviation on the part of the shipping company, but comes from the requirements of the USA. Both the emergency number and emergency information are therefore required. In maritime transport, the information on the emergency measures to be taken is regulated by the entry of the FA or SI coding. However, here too, an additional entry in the IMO declaration makes sense for the shipment of lithium metal cells/batteries in order to exclude water as a possible extinguishing agent. 

7. Requirements for packing tests for safety critically defective lithium cells/batteries - BAM Dangerous Goods Rule 024 (BAM Gefahrgutregel 024 (BAM-GGR-024)) published 

 On 1 March 2024, BAM published BAM-GGR-024 with the title  

"Procedure for the fulfilment of the additional test requirements for the transport of critically defective lithium batteries". 

Here is the link to all dangerous goods regulations. We will be happy to send you the PDFs directly by e-mail on request. Yet it is only available in German for the moment: 

https://tes.bam.de/TES/Navigation/DE/Recht-und-Regelwerke/Regelwerke-Gefahrgut/Amtliche-Mitteilungen/amtliche-mitteilungen.html 

8. Datenlogger and tracking systems 
The Dangerous Goods Panel (DGP) of the ICAO adopted the 2025 amendments at its last meeting in November 2023. The exemption for data loggers and tracking systems already contained in Appendix H of the 65th IATA edition of 2024 was confirmed, so that the square brackets in Appendix H which refer to outstanding points are no longer relevant. In Appendix H you will find the new regulation in subsection H.1.2.7.1, letter (i). It should be noted in particular that the nominal energy of lithium ion cells and batteries is limited to 20 Wh and that the lithium content of lithium metal cells and batteries is limited to 1 gram.