When attaching a passive RFID tag with less than 2 grams of lithium in a battery on steel and pipe for ocean freight, is there a requirement for any dangerous goods declaration to be made on a consignment?
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Passive tags do not have batteries, so I assume you mean active tags. Lithium batteries are covered in Special Provision 188 of the International Maritime Dangerous Goods (IMDG) code, an international agreement on how to handle dangerous goods or hazardous materials on seagoing vessels. There is an exemption for batteries that meet the following criteria:
- Lithium metal or lithium alloy cell in which the lithium content is not more than 1 gram
- Lithium metal or lithium alloy battery in which the aggregate lithium content is not more than 2 grams
- Lithium ion cell for which the watt-hour rating is not more than 20 watt-hours
- Lithium-ion battery for which the watt-hour rating is not more than 100 watt-hours
Cells and batteries must also:
- Meet the provisions of 184.108.40.206 and 220.127.116.11
- Be packed in inner packagings that completely enclose the cell or battery (not applicable when contained in equipment)
- Be protected to prevent short circuits
- Be equipped with an effective means of preventing accidental activation
- Be marked with the appropriate lithium battery mark
- Be capable of withstanding a 1.2-meter drop test in any orientation without damage to cells or batteries contained therein, without shifting of the contents so as to allow battery to battery (or cell to cell) contact and without release of contents (not applicable when installed in equipment).
- Be more than 30 kilograms in gross mass
I would suggest you contact the appropriate government agency or a knowledgeable shipping broker to ensure your shipment meets all government requirements. I would also encourage manufacturers of active tags that have dealt with this issue to post information below.
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