For NiMH AA batteries.
NiMH AA Cells

Nickel-Metal Hydride Batteries are rechargeable batteries. These batteries have equivalent energy density as lithium-ion batteries but looses its charge more quickly in shelf than lithium-ion batteries.

During transport these batteries do not pose much danger however they can be a concern sometimes.

APL Peru during a voyage experienced fire in cargo hold attributed to two containers carrying Nickel-Metal Hydride Batteries. These containers were said-to-contain merely 46 cartons of NiMH batteries only!

There are further cases involving fire due to NiMH batteries, one in a non-live reefer. Considering these experiences and facts IMO DSC agreed to include Nickel-Metal Hydride Batteries as Dangerous Goods.

Requirement as per IMDG Code 35th Amendment

35th amendment of IMDG Code came with new entry UN 3496 BATTERIES, NICKEL-METAL HYDRIDE, Class 9 with Special Provision 117 and 963 assigned.

Though not subject to any other provisions of IMDG Code these batteries  require to meet following provisions

  • Shall be securely packed and protected from short circuit.
  • When gross mass of nickel-metal hydride batteries per container is 100 Kg of more then they shall be subject to below three requirements :
  1. Dangerous Goods Declaration
  2. Inclusion in Dangerous Goods Manifest placed on board vessel
  3. Stowage “Away from” sources of heat



Container no. AAAA1234567 Container no. BBBB1234567
Commodity Total Package Weight Requirement Commodity Total Package Weight Requirement

99 KG


100 kg

Or more


2.Include in Manifest

3. Stowage away from sources of Heat


Now we know that when weight per container is 100 KG or more the changes in requirement is triggered.

However Nickel-metal hydride button cells or nickel-metal hydride cells or batteries packed with or contained in equipment are not subject to any requirement of IMDG Code. Example packed with Radios or Cameras, or Packed inside Radios or Cameras.



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  1. Thanks Shashi for the informative article, quick question;
    do Ni-MH batteries require the Class 9 label to be placed on packages during sea transportation?
    Thank you in advance for your response.

    1. Good Day,

      In case gross mass of Ni-MH batteries are 100 Kg or more per container
      you need only
      1. Dangerous Goods Declaration ( you need to book it with the line as UN 3496,
      2. Manifest ( shipping line will prepare this )
      3. Stowage away from heat, ( shipping line will ensure this )

      Class 9 Label is not required on the Package!
      Trust this clarifies.


  2. Fantastic, thanks for the quick reponse!

    I understand the terms when Ni-MH become classed as Dangerous Goods Class 9 including the Dangerous Goods Declaration however I can’t find any official documentation that says Class 9 Label is NOT required.

    FYI, I will be shipping Ni-MH batteries over 100kg.

    Could you kindly point me the way to where it says No Label is required, or am I missing something?

    Thank you in advance.


    1. Dear Tom,

      The article about Ni-MH batteries are based on IMDG Code 35th Amendment which will come into force from 1st Jan 2012.

      Most of the shipping lines will switch over to IMDG Code 35th Amendment by October as it will give sufficient time for the consignment according to previous edition of the rule to reach destination before mid night 31st December 2011.

      You may check with the line which amendment of IMDG Code they are following for your Ni-MH consignment.

      Regarding Label: If you look into IMDG Code 35th amendment
      UN 3496, BATTERIES, NICKEL-METAL HYDRIDE, is assigned with two special provisions, SP 117 and SP 963

      SP 117 says “Only regulated when transported by sea.”
      which means by road, rail these are not hazardous, hazardous only when transported by sea.

      As per SP 963 Ni-MH batteries need not meet the provisions of IMDG Code if they are packed with or contained in the equipments.

      If they are only batteries then they must be securely packed and protected.

      When loaded in a container in a total quantity of 100 Kg gross mass or morethen they shall be issued with
      dangerous goods declaration ( section 5.4.1),
      Manifest (section 5.4.3) and
      stowage on board vessel “away from sources of heat” ( column (16) ).

      For your reference Special Provision 963 is quoted below

      SP 963 “Nickel-metal hydride button cells or nickel-metal hydride cells or batteries packed with or contained in equipment are not subject to the provisions of this Code.

      All other nickel-metal hydride cells or batteries shall be securely packed and protected from short circuit. They are not subject to other provisions of this Code provided that
      they are loaded in a cargo transport unit in a total quantity of less than 100 Kg gross mass.

      When loaded in a cargo transport unit in a total quantity of 100 Kg gross mass or more, they are not subject to other provisions of this Code except those of 5.4.1, 5.4.3 and column (16) of the dangerous good list in Chapter 3.2.”

      Above does not ask for label so not required.
      This is what I interpret from the Code.


  3. Perfect,
    This is just the clarification I needed. Thank you kindly for all the information you have provided.
    Best Regards

  4. Hi Shashi,

    Thanks for the info you provided above. Possible confirm my understanding for the special requirement and the placard requirement on the container.

    1. “If it classified as non-DG if Nickel-metal hydride button cells or nickel-metal hydride cells or batteries packed with or contained in equipment”

    2. For total quantity less than 100 kgs in a container, it is classified DG cargo but do not require to meet the requirement 1) DG declaration 2) Manifest 3) Stow away from heater.
    How about the placard on the container ??

    1. Good Day,

      Please find my reply below

      1. NiMH batteries contained in or packed with equipment is considered not hazardous irrespective of quantity in container, batteries shall be securely packed and protected from short circuit.

      2. When not packed or not contained with equipments and quantity is less than 100 KG per container then considered as non-hazardous

      3. When not packed or contained with equipments and quantity is 100 kg or more per container then it is considered as hazardous and need to comply with below three points

      a) dangerous goods declaration ( shipper to provide)
      b) include in the manifest ( shipping line will prepare)
      c) stow the container away from heat ( shipping line will ensure)

      Trust this clarifies.
      I am posting one topic a day to on pass the information about DG rules to all visitors, if you have any suggestion for topic you are welcome to suggest same.

      Best regards/ Shashi

  5. many thanks for your clarification. Everything is clear.

    If you don’t remind, please try to let us know more info about IMDG vs CFR49 in USA. Since it is required to show RQ / (PIH) zone A-D if applicable on the DG declaration for shipment import into USA.


    “ERAP” is also another required from Canada.


    How to determine whether a battery is hazardous or not based on MSDS (section 14) provided by the customer. Possible share with us how you determine it and what are the criteria you are used to check in MSDS ? e.g. 1. Express wording must be shown in .14 for any exemption under special provision that not subject to the IMDG or UN Manual of test must be present to you ? LOI ?

    1. Good Day,

      Three questions you have asked (1) IMDG vs CFR 49 (2) EARP & non hazardous batteries.

      For Canadian EARP you may visit and see the FAQ, also consult with your consignee to check with local authorities for latest rules pertaining the chemical being shipped.

      On other two points will make one post on each and put up soonest on this blog benefiting all who are interested in these topics


  6. Dear Shashi, Thanks a lot for the info posted on your site. Please I will like to know whether a placard is required for ocean transport after filing the IMO declaration. Thank you.

    1. Dear Asempa,

      Your Question about placarding of Nickel Metal Hydride Batteries posted on website is replied below

      Nickel Metal Hydride Batteries less than 100 KG mass per container does not need to meet any requirements of IMDG Code
      however Nickel metal Hydride Batteries 100 KG mass or more per container must be declared by shipper through dangerous goods declaration and line must stow it away from heat.
      There is no requirement to mark, label the packages or container.

      Trust this will assist you.


  7. Hi Shashi,
    I haven’t been on board for a while now.
    This is a little off topic- but where can I get my hands on the IMDG code, CFR etc – both hard copy and CD (or some other electronic form).

    Is there any online resource where I can get basic DG stowage ,segration, packing etc info from?


    1. Good Day,

      Depending on which country you are from you may purchase IMDG Code and CFR 49 through local distributor. You may as well look at link for online purchase.

      Complete DG Stowage, segregation and packing instructions may not be available online for free. However you may find some articles explaining these provisions on this website.


      1. Hi Shashi,
        Thank you for your reply.

        Also, what are your thoughts on the carriage of Nitromethane ?
        Looking at the recent fire on the MSC Flaminia, Nitromethane seems to be the prime suspect.


        1. Hi

          Nitromethane: If the package breaks there is possibility of fire and explosion. Only allowed in small packages, i.e. less than 450 Liters per package due to the possibility of explosion when transported in larger volumes.

          This is generally shipped in drums. Securing cargo in container has to be done properly, improper securing may result in falling off of packages or movement resulting in leakage and subsequent fire/explosion if nitromethane is involved.
          Though Nitromethane is prime suspect in case of Flaminia we will have to wait till final report to see any other cause for that ill fated vessel.


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