Navigating Hazardous Goods Shipping from China to Poland: UN Certifications, ADR, and Air Transport Restrictions for Lithium Batteries & Chemicals

Introduction: Navigating the Complexities of Hazardous Goods Shipping from China to Poland

Shipping hazardous materials, such as lithium batteries and chemicals, across international borders is an inherently complex undertaking. These goods pose significant risks to human health, safety, property, and the environment if they are not handled with the utmost care and precision. Consequently, their transport is governed by a multi-layered web of international and national regulations. Failure to adhere to these stringent requirements can lead to severe repercussions, including cargo rejections, substantial financial penalties, protracted customs delays, and, most critically, serious safety incidents. This comprehensive guide aims to demystify the intricate process of shipping such sensitive cargo from China to Poland, focusing on critical certifications, transport restrictions, and specific customs requirements.  

The transportation of hazardous goods is a high-risk and highly regulated domain. The inherent dangers associated with these materials necessitate a globally harmonized approach to regulation. This global standardization, exemplified by the United Nations (UN) Model Regulations, aims to create a common understanding of hazards across different geographies and languages, thereby reducing miscommunication and enhancing safety. However, while this international framework provides a foundational common language, individual nations and specific modes of transport often introduce their own granular requirements and deviations. This combination of overarching global standards and particular national and modal rules creates a complex compliance landscape. Navigating this intricate environment without specialized knowledge significantly increases the potential for errors, which can result in severe penalties and compromise safety. This complexity underscores the critical importance of expert guidance for all parties involved in the supply chain.  

Section 1: Understanding International Hazardous Goods Classification (UN Model Regulations)

The bedrock of international hazardous goods transportation is the United Nations Globally Harmonized System (GHS) for Hazard Communication, alongside the UN ‘Recommendations on the Transport of Dangerous Goods,’ commonly known as the Model Regulations. These frameworks establish a universal standard for classifying hazardous materials and communicating their associated dangers, ensuring consistency regardless of the origin or destination country or the languages spoken by handlers. This global standard is fundamental to minimizing language barriers and ensuring a consistent understanding of hazards across borders. The adoption of such a uniform system is crucial for international trade, as it significantly reduces the potential for miscommunication, which is a major risk factor in the transport of hazardous materials.  

Dangerous goods are defined as substances or articles that can pose a threat to people, property, and/or the environment. These materials can exist in three physical states—solid, liquid, or gas—and present a range of dangers during transport, with flammability, toxicity, and corrosivity being among the most common. The UN system categorizes these materials into nine primary hazard classes, some of which are further subdivided into divisions:  

• Class 1: Explosives (Divisions 1.1-1.6). These include substances or articles capable of producing gas through chemical reactions that may cause damage to their surroundings, such as ammunition and fireworks.  
• Class 2: Gases (Divisions 2.1-2.3). This class encompasses flammable gases, non-flammable/non-toxic gases, and toxic gases. Examples include aerosols, fire extinguishers, natural gas, and propane.  
• Class 3: Flammable Liquids. These are liquids with a flash point (the lowest temperature required to induce ignition) typically between 23°C and 93°C, such as paints, fuels, acetone, and alcohol.  
• Class 4: Flammable Solids; Substances liable to spontaneous combustion; Substances which, on contact with water, emit flammable gases (Divisions 4.1-4.3). This includes materials like self-reactive substances and solid desensitized explosives.  
• Class 5: Oxidizing Substances and Organic Peroxides (Divisions 5.1-5.2). Examples include hydrogen peroxide and nitrates.  
• Class 6: Toxic and Infectious Substances (Divisions 6.1-6.2). These are substances that can cause harm or death if inhaled or contacted, such as toxic chemicals and infectious medical samples.  
• Class 7: Radioactive Materials. This class covers substances that emit ionizing radiation, including yellowcake, depleted uranium, and medical isotopes.  
• Class 8: Corrosive Substances. These are chemicals that can be harmful to organic or metal materials, causing deterioration upon contact. Examples include battery acids and acid solutions.  
• Class 9: Miscellaneous Dangerous Goods/Hazardous Materials and Articles. This broad category includes substances and articles that do not fit into other classes but still present a danger during transport. Common examples are asbestos, genetically modified organisms (GMOs), vehicles (and engines), dry ice, and, notably, lithium batteries.  

Once a hazardous item has been classified, it is assigned a unique four-digit UN Number and a Proper Shipping Name (PSN). These identifiers are crucial for rapid and precise identification during transport, enabling correct handling, stowage, segregation, and appropriate actions in an emergency. For instance, Kerosene is classified as a flammable liquid (Class 3), its recognized PSN is ‘KEROSENE,’ and its UN Number is UN 1223. Similarly, standalone lithium-ion batteries are assigned UN 3480.  

Hazard information is prominently displayed on packaging through the use of standardized labels, placards (often diamond-shaped warning labels), and pictograms. These visual cues are designed to make it easier to identify the contents being shipped and to convey necessary information about potential hazards. GHS pictograms, for example, are universally recognizable symbols enclosed in red diamond-shaped borders, representing specific hazards such as flammability (a flame symbol), acute toxicity (skull and crossbones), or corrosivity (a corrosion symbol). The consistent application of these symbols ensures that handlers, regardless of their background, can quickly assess the associated risks.  

While the UN system provides a universal classification, the specific regulations governing transport (such as ADR for road, IATA DGR for air, and IMDG Code for maritime) build upon this foundation with mode-specific requirements. This means that while the fundamental classification of a hazardous material remains consistent globally, the precise conditions and procedures for its transport—including packaging, labeling, documentation, and handling—will vary depending on the chosen mode of transport. Therefore, shippers must not only understand the overarching UN framework but also delve into the granular rules specific to air, road, or sea transport to ensure full compliance.  

Table 1: Overview of UN Hazard Classes and Examples

Class Number	Class Name	Key Characteristics	Common Examples
1	Explosives	Mass explosion, projection, fire, minor blast hazards	Ammunition, fireworks, igniters, flares
2	Gases	Flammable, non-flammable/non-toxic, or toxic gases; aerosols, chemicals under pressure	Natural gas, fire extinguishers, propane
3	Flammable Liquids	Liquids with flash point between 23°C and 93°C	Paints, fuels, acetone, alcohol
4	Flammable Solids; Substances liable to spontaneous combustion; Substances which, on contact with water, emit flammable gases	Solids that ignite easily; substances that self-ignite; substances that react with water to produce flammable gases	Flammable solids, self-reactive substances, solid desensitized explosives
5	Oxidizing Substances and Organic Peroxides	Substances that readily yield oxygen or cause combustion of other materials; thermally unstable substances	Hydrogen peroxide, nitrates (sodium, lead, ammonium)
6	Toxic and Infectious Substances	Substances that can cause harm or death; substances containing pathogens	Toxic chemicals, infectious medical samples
7	Radioactive Materials	Materials containing radionuclides that emit ionizing radiation	Yellowcake, depleted uranium, medical isotopes
8	Corrosive Substances	Chemicals that cause severe damage to living tissue or other materials upon contact	Batteries, acid solutions, flux
9	Miscellaneous Dangerous Goods/Hazardous Materials and Articles	Substances and articles presenting a danger not covered by other classes (e.g., environmental hazards, elevated temperature materials)	Asbestos, GMOs, vehicles (and engines), dry ice, lithium batteries

Section 2: UN38.3 Certification for Lithium Batteries: A Prerequisite for Transport

UN38.3 certification is a mandatory safety test for lithium batteries, serving as a critical prerequisite for their transport by air and sea. The United Nations established the UN 38.3 test methods and procedures specifically to ensure that lithium-ion batteries are robust enough for safe transportation. These tests are meticulously designed to simulate a wide range of extreme conditions that a battery might encounter during international transit, including significant changes in altitude, severe temperature fluctuations, sustained vibrations, and sudden impacts. The comprehensive nature of these tests demonstrates a proactive regulatory approach aimed at mitigating the inherent risks associated with lithium batteries, such as thermal runaway and flammability, under various transport conditions. This means the certification is not merely a bureaucratic requirement but a fundamental safety assurance, directly addressing potential failure modes during real-world transport stresses.  

The UN38.3 test series comprises eight distinct tests (T.1-T.8):

• T.1 Altitude Simulation Test: This test exposes batteries to a reduced pressure environment, simulating an altitude of 50,000 feet (15,200 meters), for a minimum of six hours. The battery must show no signs of leakage, venting, disintegration, cracking, or burning under these conditions.  
• T.2 Thermal Test: Batteries undergo extreme temperature cycling, with ten repetitions of 12-hour dwell times at both 72°C and -40°C. The transition between these temperatures must occur within 30 minutes, followed by a 24-hour storage period at room temperature. The test assesses the battery’s integrity under thermal stress.  
• T.3 Vibration Test: Batteries are subjected to a reciprocating logarithmic frequency sweep sinusoidal vibration, ranging from 7Hz to 200Hz, for three hours in each of three mutually perpendicular dimensions. This simulates vibrations encountered during transport.  
• T.4 Shock Test: This test involves subjecting the battery to half-sine shock pulses. Small batteries receive a peak acceleration of 150gn with a 6-millisecond duration, while larger batteries are subjected to 50gn with an 11-millisecond duration. The battery must exhibit no mass loss, leakage, venting, disassembly, rupture, or fire, and its open-circuit voltage must remain at least 90% of its initial voltage after testing.  
• T.5 External Short Circuit Test: The battery is stabilized at an external case temperature of 57°C ± 4°C, then subjected to a short circuit condition with a total external resistance of less than 0.1 ohms. This short circuit is maintained for at least one hour after the battery’s external case temperature returns to 57°C ± 4°C. The battery’s external temperature must not exceed 170°C, and there should be no disassembly, rupture, or fire during or within six hours after the test.  
• T.6 Impact/Crush Test: Applicable to prismatic, pouch, coin/button cells, and cylindrical cells not exceeding 18mm in diameter. The cell is crushed by applying force (e.g., to the widest side for prismatic cells, flat surfaces for button cells, or perpendicular to the longitudinal axis for cylindrical cells). The external temperature must not exceed 170°C, and there should be no disassembly, rupture, or fire during or within six hours after the test.  
• T.7 Overcharge Test: The battery is charged at twice the manufacturer’s recommended maximum continuous charge current for 24 hours at ambient temperature. The test voltage is specified based on the manufacturer’s recommended charge voltage. There must be no disassembly or fire during the test or within seven days afterward.  
• T.8 Forced Discharge Test: (Applicable to cells only) The cell is connected in series to a 12V power supply at the maximum recommended current.  

Without valid UN38.3 certification, shipments of lithium batteries are highly likely to face delays or outright rejection by carriers and customs authorities due to the strict regulations governing hazardous materials. This certification is a fundamental requirement for ensuring the safe and compliant movement of these energy-dense power sources.  

Furthermore, a critical requirement for lithium battery transportation is the availability of a Lithium Battery Test Summary. Manufacturers and subsequent distributors of lithium cells and batteries (with the exception of button cells installed in equipment) produced on or after January 1, 2008, are mandated to make this test summary accessible to other entities within the supply chain. This summary is a standardized document that provides traceability and accountability, serving as verifiable proof that the battery designs offered for transport have successfully met the UN38.3 test requirements. This requirement effectively shifts some of the burden of proof and accountability from the individual shipper to the manufacturer and distributor. This creates a supply chain-wide responsibility for safety, emphasizing that compliance begins at the product design and manufacturing stage, rather than solely at the point of shipment. Shippers are strongly advised to obtain this summary from their battery manufacturer or distributor to ensure compliance.  

Table 2: Detailed UN38.3 Test Requirements

Test Number	Test Name	Brief Description of Test Conditions	Pass/Fail Criteria
T.1	Altitude Simulation	Exposure to pressure ≤11.6kPa (50,000 ft equivalent) at 20 ± 5°C for ≥6 hours	No leakage, exhaust, disintegration, cracking, or burning
T.2	Thermal Test	10 cycles of 12-hour dwell times at 72 ± 2°C and -40 ± 2°C, with ≤30 min transition time, followed by 24h at room temp	No leakage, exhaust, disintegration, cracking, or burning
T.3	Vibration	Reciprocating logarithmic frequency sweep (7Hz to 200Hz) for 15 min per sweep, 12 vibrations in 3 dimensions (3h total)	No mass loss, leakage, venting, disassembly, rupture, or fire
T.4	Shock	Half-sine shock of 150gn (small battery) or 50gn (large battery) for 6 or 11 milliseconds, respectively	No mass loss, leakage, venting, disassembly, rupture, or fire; open-circuit voltage ≥90%
T.5	External Short Circuit	Cell/battery stabilized at 57 ± 4°C, then short-circuited with <0.1 ohms resistance for ≥1 hour after temp returns to 57 ± 4°C	External temperature ≤170°C; no disassembly, rupture, or fire during test and within 6 hours after
T.6	Impact/Crush	Force applied to widest side (prismatic/pouch), flat surfaces (coin/button), or perpendicular to longitudinal axis (cylindrical ≤18mm)	External temperature ≤170°C; no disassembly, rupture, or fire during test and within 6 hours after
T.7	Overcharge	Charged at 2x manufacturer’s max continuous charge current for 24 hours at ambient temperature	No disassembly or fire during test and within 7 days after
T.8	Forced Discharge	(Cells only) 12V power supply connected in series at maximum recommended current	(Implicitly, no hazardous outcome)

Section 3: Air Transport Restrictions for Lithium Batteries (IATA Dangerous Goods Regulations)

The International Air Transport Association (IATA) Dangerous Goods Regulations (DGR) represent the global benchmark for the safe and efficient transportation of dangerous goods by air. This comprehensive manual is indispensable for airlines, freight forwarders, ground handlers, and shippers, guiding them daily in the classification, marking, packing, labeling, and documentation of dangerous shipments to ensure compliance with air transport regulations. The DGR is updated annually, and these revisions often introduce significant changes to procedures and regulations. Consequently, utilizing the most current version is critical to avoiding delays, financial penalties, and breaches of contract.  

The IATA DGR provides specific Packing Instructions (PIs) tailored for various lithium battery configurations. These include PI 965 for standalone lithium-ion batteries, PI 966 for lithium-ion batteries packed with equipment, PI 967 for lithium-ion batteries contained in equipment, PI 968 for standalone lithium metal batteries, PI 969 for lithium metal batteries packed with equipment, and PI 970 for lithium metal batteries contained in equipment. Recent amendments to these instructions have focused on enhancing safety, such as the removal of Section II from PI 965 and 968, clarifications regarding short-circuit protection for PI 966 and 969, and new requirements to ensure that packages within overpacks are secure and their intended function is not compromised.  

A critical aspect of air transport for lithium batteries involves strict State of Charge (SoC) limitations. Currently, all shipments of standalone lithium-ion batteries (UN3480) and lithium metal batteries (UN3090) are mandated to be shipped at a SoC not exceeding 30% of their rated capacity. A significant upcoming change will further expand this requirement: effective January 1, 2026, this 30% SoC limitation will also apply to lithium-ion batteries packed with equipment (under PI 966) and lithium-ion batteries contained in equipment (under PI 967). This evolving nature of IATA DGR, particularly the upcoming mandatory 30% SoC limit for batteries in or with equipment, signifies a continuous regulatory response to perceived safety risks. This change will necessitate substantial adaptations in the production and shipping processes for many companies, as it impacts product readiness for shipment, indicating a clear regulatory trend towards stricter control over lithium battery transport regardless of how they are packaged.  

A crucial distinction in air transport is made between UN3480 (standalone lithium-ion batteries) and UN3481 (lithium-ion batteries packed with or contained in equipment), which dictates whether they can be carried on passenger or cargo aircraft:

• UN3480 (Lithium-ion batteries, standalone): These are strictly prohibited as cargo on passenger aircraft and must be transported exclusively on cargo aircraft only. This prohibition is a fundamental safety measure implemented to significantly reduce the risk of incidents occurring on passenger flights. The strict segregation of standalone lithium batteries to “Cargo Aircraft Only” reflects a high-risk assessment by aviation authorities, which prioritizes passenger safety above all else, even if it means commercial inconvenience. This also implies that air freight options for these specific goods will remain more limited and potentially more expensive.  
• UN3481 (Lithium-ion batteries packed with or contained in equipment): These are generally authorized for transportation as cargo on passenger aircraft, albeit with specific limitations. For instance, the total mass of lithium batteries within a single package typically must not exceed 5 kg. Limited exceptions exist for medical device batteries, which, with special approval, may be transported on passenger aircraft even at a SoC greater than 30%.  

Given these restrictions, packages containing lithium batteries forbidden on passenger aircraft (e.g., UN3480) must prominently display a “Cargo Aircraft Only” label or equivalent text. This standardized pictogram serves as an immediate visual warning, ensuring that such packages are loaded only onto aircraft specifically designed for cargo operations.  

Specific packaging requirements are also paramount for lithium batteries to prevent hazards such as fire or short circuits :  

• Fireproof Packaging: The use of fire-resistant packaging materials and UN-certified outer packaging is essential for mitigating the risk of fire.  
• Short-Circuit Protection: Battery terminals must be individually insulated to prevent accidental contact, and batteries should be packed separately or within anti-short circuit containers.  
• Cushioning and Anti-Crushing: Strong outer packaging, reinforced with cushioning materials such as foam or bubble film, is required to protect against physical damage and prevent thermal runaway caused by impact or compression.  
• Rigid Outer Packages: For small lithium battery shipments, the use of padded or poly bags is explicitly prohibited; outer packages must be rigid.  
• Watt-hour Rating: Lithium batteries manufactured after December 31, 2011, must be clearly marked with their Watt-hour rating on the outside of the case.  
• Labeling Updates: It is important to note that, effective December 31, 2026, the requirement for a telephone number on the lithium battery mark will be removed.  

Table 3: Lithium Battery Air Transport Restrictions (IATA DGR) Summary

UN Number	Description	State of Charge (SoC) Requirement	Passenger Aircraft Eligibility	Key Packaging Requirements	Labeling
UN3480	Lithium-ion batteries (standalone)	Current: ≤30% <br> Jan 2026: No change	FORBIDDEN	UN-certified, fireproof, short-circuit protection, anti-crushing, rigid outer packaging, Watt-hour rating on case	“Cargo Aircraft Only” label, UN3480, Lithium Battery Mark (phone number removed by Dec 2026)
UN3090	Lithium metal batteries (standalone)	Current: ≤30% <br> Jan 2026: No change	FORBIDDEN	UN-certified, fireproof, short-circuit protection, thermal insulation, specialized packaging, anti-crushing, rigid outer packaging	“Cargo Aircraft Only” label, UN3090, Lithium Battery Mark (phone number removed by Dec 2026)
UN3481	Lithium-ion batteries packed with equipment	Current: Recommendation ≤30% <br> Jan 2026: Mandatory ≤30%	Authorized (package mass ≤5 kg)	UN-certified, short-circuit protection, equipment secured to prevent activation/damage, rigid outer packaging, Watt-hour rating on case	UN3481, Lithium Battery Mark (phone number removed by Dec 2026). Air waybill may need specific wording
UN3481	Lithium-ion batteries contained in equipment	Current: Recommendation ≤30% <br> Jan 2026: No change (still recommendation)	Authorized (package mass ≤5 kg)	UN-certified, short-circuit protection, equipment secured to prevent activation/damage, rigid outer packaging, Watt-hour rating on case	UN3481, Lithium Battery Mark (phone number removed by Dec 2026)
UN3091	Lithium metal batteries packed with equipment	Current: No specific SoC <br> Jan 2026: No change	Authorized	UN-certified, short-circuit protection, equipment secured to prevent activation/damage, rigid outer packaging	UN3091, Lithium Battery Mark (phone number removed by Dec 2026)
UN3091	Lithium metal batteries contained in equipment	Current: No specific SoC <br> Jan 2026: No change	Authorized	UN-certified, short-circuit protection, equipment secured to prevent activation/damage, rigid outer packaging	UN3091, Lithium Battery Mark (phone number removed by Dec 2026)

Section 4: Road Transport of Hazardous Chemicals: ADR Regulations in Poland

The Agreement concerning the International Carriage of Dangerous Goods by Road (ADR) is a foundational international convention that governs the road transport of dangerous goods. Established in Geneva on September 30, 1957, under the auspices of the United Nations Economic Commission for Europe (UNECE), the ADR entered into force on January 29, 1968. Its primary objective is to ensure that dangerous goods can be transported by road across international borders without impediment, provided that the goods themselves, the vehicles used, and the drivers operating them comply with its comprehensive rules. The structure of the ADR is designed to be consistent with the UN Recommendations on the Transport of Dangerous Goods, Model Regulations, ensuring a harmonized approach to safety across different transport modes.  

The ADR framework’s holistic approach, encompassing not only the classification and packaging of goods but also mandatory driver training and vehicle certification, creates a multi-layered safety net for road transport. This comprehensive control is crucial given the direct human interaction and public road exposure inherent in road logistics.

Core ADR requirements span classification, packaging, marking, labeling, and documentation:

• Classification: ADR adopts the same nine UN hazard classes (1-9) and their divisions as the UN Model Regulations. Beyond this, it further categorizes materials into three Hazard Groups based on their level of danger: Group I for materials posing a high level of danger, Group II for medium danger, and Group III for low danger.  
• Packaging: Dangerous goods must be packed correctly and safely. This includes the mandatory use of UN-specification packaging, ensuring that all specification markings are clearly visible and unobscured.  
• Marking, Labeling, and Placarding: Packages must be accurately marked, labeled, and, for larger quantities, placarded. Labels are typically diamond-shaped warning labels that visually highlight the potential dangers of the contents. For chemicals, the Globally Harmonized System (GHS) labeling elements, including pictograms, signal words, hazard statements, and precautionary statements, are also required to ensure clear communication of risks.  
• Documentation: A transport document is mandatory for all dangerous goods shipments, providing detailed information about the load, including the full classification of all substances carried and instructions on how they are packaged. This document must specify the UN number, technical name, hazard label numbers, packing group, and, if applicable, the tunnel restriction code. Additionally, emergency instructions in writing, based on a standardized four-page model, must be carried on the transport unit and must be in languages understood by every member of the vehicle crew.  
• Exemptions: ADR provides specific exemptions for small loads below certain threshold limits, or for dangerous goods packed in limited quantities (LQ) or excepted quantities (EQ). In such cases, many parts of the ADR regulations may not apply, or they may apply in a modified form, simplifying compliance for smaller consignments.  

The ADR also imposes strict requirements on the personnel and vehicles involved in transport:

• Driver Training and Certification: Drivers of all vehicles transporting dangerous goods must possess a valid ADR training certificate. To obtain this certification, drivers must be at least 21 years old (with an exception for drivers of vehicles belonging to the Armed Forces of the Republic of Poland), successfully complete an ADR course, and pass a specialized examination. This rigorous training ensures that drivers are fully aware of the hazards associated with the goods they transport, are equipped to take steps to reduce the likelihood of an incident, and can implement all necessary measures for their own safety, as well as that of the public and the environment, should an incident occur.  
• Vehicle Certification (“ADR Test”): Fixed-tank vehicles, tank-battery vehicles, and other vehicles designated for carrying explosives must undergo an annual technical inspection and certification procedure in their country of registration. This “ADR test” ensures that the vehicles conform to ADR requirements, particularly Part 9, and comply with standard safety regulations, such as those pertaining to brakes and lighting. Furthermore, tanks used to carry dangerous goods by road must be examined and tested by an inspection body approved by the relevant governmental authority before any ADR vehicle inspection is carried out.  

ADR also specifies the use of hazard group labels (Group I, II, III) for chemical transport, indicating the level of danger. Vehicles transporting dangerous goods must carry specific emergency equipment tailored to the nature of the hazards. This equipment may include protective gloves, a portable lighting device, and, for certain toxic (Class 2.3) or infectious (Class 6.1) materials, an escape mask for each person in the vehicle. For solid and liquid materials labeled with hazard labels 3, 4.1, 4.3, 8, or 9, a shovel, drain cover, and container for residue collection are also required.  

Poland is a signatory to the ADR Agreement and actively enforces its regulations within its borders. Polish companies specializing in ADR transport offer comprehensive services, encompassing logistical planning, preparation of all necessary documentation, selection of appropriate vehicles, and strict adherence to safety procedures at every stage of transport. The effectiveness of Poland’s commitment to ADR compliance is reflected in the fact that the number of accidents and incidents resulting from the road transport of hazardous materials in Poland is growing slower than the overall volume of such transport. This trend indicates a continuous improvement in adherence to safety procedures and regulations, suggesting a mature and effective regulatory environment for dangerous goods road transport. For shippers, this implies a degree of assurance regarding safety standards in Poland, but it also underscores the expectation of strict compliance and a low tolerance for non-adherence.  

Section 5: Essential Documentation and Polish Customs Requirements for Hazardous Goods

The successful international shipment of hazardous goods, particularly from China to Poland, relies heavily on meticulous documentation and adherence to specific customs requirements. Without proper paperwork, shipments face significant delays or outright rejection.

Safety Data Sheet (SDS/MSDS)

The Safety Data Sheet (SDS), formerly known as the Material Safety Data Sheet (MSDS), is an indispensable and often mandatory document for shipping hazardous materials, including liquids, powders, and batteries. It functions as a critical compliance and risk management tool, providing comprehensive safety information about the materials being transported. The primary responsibility for providing an SDS typically rests with the manufacturer, though professional laboratories may also be engaged to prepare these documents. The absence of an SDS can lead to substantial delays due to strict regulations governing hazardous materials transport.  

An SDS must contain detailed information, often structured into 16 sections, aligned with the Globally Harmonized System (GHS) for hazard communication. Key content includes:  

• Product Identifier: Clearly states the chemical name or unique identification number (e.g., CAS number).  
• Hazard Identification: Details potential hazards such as flammability, reactivity, or toxicity.  
• First Aid Procedures: Instructions for immediate medical attention in case of exposure.  
• Accidental Release Measures: Procedures for clean-up and containment of spills.  
• Handling and Storage: Guidelines for safe handling, storage conditions, and segregation from incompatible materials.  
• Exposure Controls/Personal Protection: Specifies any Personal Protective Equipment (PPE) that must be worn when handling the chemicals.  
• Physical and Chemical Properties: Information on the chemical’s physical state (solid, liquid, gas), melting point, color, flash point, etc..  
• Stability and Reactivity: Describes the chemical’s stability under normal conditions and potential hazardous reactions.  
• Toxicological Information: Data on health effects from exposure.  
• Ecological Information: Details on environmental impact.  
• Disposal Considerations: Guidance on safe disposal methods.  
• Transport Information: Includes UN number, proper shipping name, hazard class, and packing group.  
• Regulatory Information: Relevant safety, health, and environmental regulations.
• Other Information: Date of preparation or last revision.
• Emergency Response Information: Critical contact information and procedures in the event of an incident.  
• Supplier Identification: Contact details of the manufacturer or supplier, including company name, address, and phone number.  

For lithium-ion batteries, the SDS must specifically cover risks associated with their transport, proper packaging and labeling requirements, and emergency response information in case of a fire or other incidents involving the batteries. Shippers should always consult Section 14 of the SDS, which explicitly states whether a product is classified as dangerous goods.  

Table 4: Key Elements of a Safety Data Sheet (SDS)

Section Number	Section Title	Brief Description of Information
1	Identification	Product name, recommended uses, supplier contact information, emergency phone number
2	Hazard(s) Identification	Classification of the chemical, GHS pictograms, signal words, hazard statements, precautionary statements
3	Composition/Information on Ingredients	Chemical identity, common names, concentration of ingredients
4	First-Aid Measures	Symptoms and effects of exposure, immediate medical attention needed, specific treatments
5	Fire-Fighting Measures	Suitable extinguishing media, specific hazards arising from the chemical, special protective equipment for firefighters
6	Accidental Release Measures	Emergency procedures, personal protective equipment, methods for containment and clean-up
7	Handling and Storage	Precautions for safe handling, conditions for safe storage, incompatibilities
8	Exposure Controls/Personal Protection	OSHA Permissible Exposure Limits (PELs), ACGIH Threshold Limit Values (TLVs), appropriate engineering controls, PPE recommendations
9	Physical and Chemical Properties	Appearance, odor, pH, melting/freezing point, boiling point, flash point, flammability, vapor pressure, density, solubility, etc.
10	Stability and Reactivity	Reactivity hazards, chemical stability, possibility of hazardous reactions, conditions to avoid, incompatible materials, hazardous decomposition products
11	Toxicological Information	Routes of exposure, symptoms, acute and chronic health effects, numerical measures of toxicity
12	Ecological Information	Ecotoxicity, persistence and degradability, bioaccumulative potential, mobility in soil, other adverse effects
13	Disposal Considerations	Waste treatment methods, specific disposal requirements
14	Transport Information	UN number, proper shipping name, hazard class, packing group, environmental hazards, special precautions for user
15	Regulatory Information	Safety, health, and environmental regulations specific for the product
16	Other Information	Date of preparation or last revision, key to abbreviations

Shipper’s Declaration for Dangerous Goods (DGD)

The Shipper’s Declaration for Dangerous Goods (DGD) is a mandatory document for fully regulated dangerous goods shipments by air and sea. This document serves as a legal declaration by the shipper, confirming that the hazardous goods have been classified, packed, marked, and labeled in accordance with all applicable dangerous goods regulations.  

Air Waybill and Commercial Invoice

Standard customs documentation, including the Air Waybill and Commercial Invoice, is required for all international shipments. For lithium-ion batteries shipped under Packing Instruction 966, Section II, the Air Waybill may require specific wording such as “lithium ion batteries, in compliance with Section II of PI966”.  

EORI Number: Requirement for EU Imports

For any import from or export to countries outside the European Union, an Economic Operator Registration and Identification (EORI) number is a legal necessity for all customs declarations. Customs authorities in Poland, as part of the EU, will refuse entry of goods if a valid EORI number is not provided. Companies established outside the EU must formally request this number from the Polish authorities.  

Poland’s SENT System: Applicability for Sensitive Goods

Poland has implemented the SENT system, a digital monitoring system for the transport of certain sensitive goods. Starting January 2025, all freight entering or transiting Poland, including goods transported by foreign carriers, must be registered in the SENT system. Initially, this system applied to sensitive goods such as fuel, alcohol, or tobacco. The SENT system’s primary objective is to enhance transparency in the supply chain and combat smuggling, requiring real-time location tracking and accurate reporting.  

A significant development is the expansion of the SENT system’s scope. It is being extended to include items like clothing and footwear (specifically those listed in CN chapters 61 and 62). This expansion indicates a broader governmental strategy to close the VAT gap and increase the digitization of trade monitoring across various sectors. This suggests that even seemingly innocuous goods could become subject to increased scrutiny, highlighting a trend towards more pervasive digital monitoring of imports in Poland. Failure to register a required shipment in SENT can lead to severe penalties, including fines of up to 12,000 PLN (approximately €2,800) per violation, and potentially the detention or seizure of the transport vehicle.  

Other Polish Import Licenses and the TARIC Database

Poland, as a full member of the European Union, adheres to the Common Customs Tariff (CCT) of the EU, which applies to goods imported from outside Europe. However, certain goods are subject to specific import restrictions or outright prohibitions to safeguard human life, animal and plant health, national security, or artistic, cultural, and intellectual property. Examples of such restricted items include certain food products, drugs, pharmaceuticals, environmentally hazardous products, seeds, weapons, explosives, and antiques.  

To ascertain whether a product is prohibited or subject to restriction, importers should consult the online customs tariff database known as TARIC (Integrated Tariff of the European Union). TARIC provides various rules applicable to specific products imported into or, in some cases, exported from the EU customs territory. Shippers should specifically look for codes such as CITES (Convention on International Trade of Endangered Species), PROHI (Import Suspension), and RSTR (Import Restriction).  

Beyond the general EU framework, Poland maintains its own “Import List” which details goods requiring specific national licenses, their corresponding code numbers, any applicable restrictions, and the agency responsible for issuing the relevant license. This list also clarifies whether the license is mandated under Polish or EU law. Various Polish ministries hold special jurisdiction over specific product categories. For example, the Ministry of Transportation oversees permits related to air, sea, or road transport, while the Ministry of Environmental Protection handles natural resources. For highly sensitive items like arms, ammunition, and explosives (Class 1 dangerous goods), the consignee must obtain import or transit approval from the Ministry of Interior at least 15 working days before the scheduled arrival. For exports of arms and ammunition, the shipper must obtain approval from the Ministry of Defense. The dual layer of regulation in Poland—EU harmonization combined with national specificities like the SENT system and ministerial oversight—creates a complex compliance environment that demands granular attention to detail. This means that relying solely on EU-wide regulations is insufficient for successful hazardous goods import into Poland.  

Furthermore, Poland implements the Rotterdam Convention on the Prior Informed Consent (PIC) procedure for certain hazardous chemicals in international trade, which is implemented in the European Union via Regulation (EU) No 649/2012. This requires the importing state’s consent for chemicals listed in Annex III of the Convention. Additionally, an “export notification” procedure mandates that a party seeking to export chemicals whose manufacture or use is restricted or banned in its own territory must notify the importing country before the first export and annually thereafter. Importers and exporters of chemicals listed in Annex I to Regulation 649/2012 are required to register in the ePIC system and submit annual reports on quantities shipped.  

GHS Labeling Requirements for Chemicals

For chemical shipments, the Globally Harmonized System (GHS) plays a vital role in ensuring universal labeling and communication for safe handling, shipping, and storage. GHS shipping labels are designed to provide critical safety information to anyone involved in the transportation or handling of dangerous chemicals. These labels include several key elements:  

• Product Identifier: The chemical name or unique identification number.  
• Pictograms: Standardized, red diamond-shaped images representing specific hazards (e.g., flame for flammable, skull and crossbones for acute toxicity, corrosion for corrosive materials).  
• Signal Word: Either “Danger” (for severe hazards) or “Warning” (for less severe hazards), indicating the severity of the hazard.  
• Hazard Statements: Detailed information about the nature of the chemical’s risks (e.g., “May cause cancer,” “Highly flammable liquid and vapor”).  
• Precautionary Statements: Instructions on how to handle, store, and dispose of the chemical safely (e.g., “Keep away from heat,” “Wear protective gloves”).  
• Supplier Identification: Contact details of the manufacturer or supplier.  

Proper GHS labeling is essential not only for preventing accidents and protecting workers but also for meeting regulatory requirements. Non-compliance can result in legal penalties, fines, and shipment rejections, disrupting business operations.  

Table 5: Comprehensive Hazardous Goods Shipping Documentation Checklist (China to Poland)

Document Name	Purpose/Key Information	Responsible Party	Relevant Regulations/Notes
Safety Data Sheet (SDS)	Comprehensive safety info (hazards, first aid, handling, properties, transport details, emergency response). Mandatory for hazardous goods.	Manufacturer/Shipper	UN GHS, EU REACH, Poland national regulations. Section 14 indicates DG classification
Shipper’s Declaration for Dangerous Goods (DGD)	Legal declaration confirming compliance with DG regulations (classification, packing, marking, labeling).	Shipper	IATA DGR (air), IMDG Code (sea), ADR (road). Required for fully regulated DG.
Air Waybill / Bill of Lading	Contract of carriage, details shipment, consignor, consignee, route.	Shipper/Carrier	Standard international shipping document. May require specific DG notes (e.g., PI966 Section II for Li-ion batteries)
Commercial Invoice	Details goods’ value, quantity, description for customs duties/taxes.	Shipper	Required for customs clearance.
Packing List	Itemized list of contents in each package, weight, dimensions.	Shipper	Aids customs inspection and cargo handling.
UN38.3 Test Summary	Proof that lithium batteries have passed UN transport safety tests (T.1-T.8).	Manufacturer/Distributor	Mandatory for lithium batteries manufactured after Jan 1, 2008. Shippers should obtain this.
EORI Number	Economic Operator Registration and Identification number for customs declarations.	Importer/Exporter	Mandatory for trade with non-EU countries. Required by Polish/EU customs.
SENT System Registration	Digital registration for transport of sensitive goods entering/transiting Poland (e.g., fuel, alcohol, tobacco, expanding to clothing/footwear).	Carrier/Shipper	Poland national regulation. Failure to register incurs fines/seizure.
Import Licenses/Permits	Specific permits for certain restricted goods (e.g., chemicals, weapons, certain food products).	Importer (consignee)	Poland’s “Import List,” TARIC database. Issued by various Polish ministries (e.g., Ministry of Interior for Class 1 DG)
Prior Informed Consent (PIC) Procedure Documentation	Consent from importing state for certain hazardous chemicals (Rotterdam Convention).	Importer/Exporter	EU Regulation 649/2012. Requires registration in ePIC system and annual reports.
ADR Transport Document (CMR Waybill)	Specific to road transport, includes UN number, technical name, hazard labels, packing group, tunnel code.	Shipper/Carrier	Mandatory for ADR-regulated road transport. Must be in local language + English/German/French.
Emergency Instructions in Writing	4-page model instructions for drivers on hazards and emergency actions.	Driver/Haulier	Mandatory for ADR road transport. Must be in languages understood by crew.
ADR Training Certificate (Driver)	Proof of specialized training for drivers transporting dangerous goods by road.	Driver	Mandatory for ADR.
ADR Vehicle Certificate	Proof of annual technical inspection and conformity for vehicles carrying dangerous goods.	Vehicle Owner	Mandatory for certain vehicle types (e.g., tanks, explosives carriers).
IEC 62133, CE, RoHS Certifications	International electrical safety, EU market conformity, hazardous substances restriction compliance.	Manufacturer/Supplier	Important for product quality assurance and EU market access.

Section 6: Best Practices and Navigating Challenges in China-Poland Hazardous Goods Shipping

Successfully navigating the complexities of hazardous goods shipping from China to Poland demands more than just regulatory adherence; it requires proactive planning and strategic collaboration with specialized experts.

Importance of Selecting Experienced Suppliers and Freight Forwarders

Shipping hazardous materials by air freight from China is inherently complex, necessitating strict adherence to international regulations, precise documentation, and meticulous attention to safety. Therefore, the selection of both the supplier in China and the freight forwarder is paramount. An experienced supplier will possess the necessary knowledge and processes to ensure all required documentation and packaging comply with international standards, thereby preventing customs delays or outright rejection of shipments. Shippers should thoroughly vet potential suppliers by inquiring about their past export experience to the EU, their compliance with IATA and IMO transport rules, and their expertise in dangerous goods packaging and labeling, including the use of UN-certified packaging and hazard labels.  

Equally critical is partnering with a qualified freight forwarder. Such a partner will ensure full compliance with IATA (air), IMO (sea), and UN regulations. They can provide invaluable assistance in obtaining necessary dangerous goods documentation, such as the UN38.3 certification, offer specialized packaging and labeling services for lithium battery shipments, and provide expert customs clearance assistance to prevent delays or fines. It is particularly beneficial to work with a direct-operated dangerous goods forwarder, as this minimizes information lag and reduces the likelihood of uncertain costs that can arise when multiple intermediaries are involved. Many general Chinese freight forwarders may not possess the specialized expertise required to handle dangerous cargo effectively.  

Pre-Shipment Testing and Quality Assurance Certifications

Beyond the mandatory UN38.3 certification, shippers should insist on additional quality assurance certifications from their potential suppliers in China. These include:

• IEC 62133 certification: This ensures compliance with international electrical safety standards for secondary cells and batteries containing alkaline or other non-acid electrolytes.  
• CE (Conformité Européenne) marking: This is a mandatory conformity marking for products imported into the European Union, indicating that the product meets EU health, safety, and environmental protection standards.  
• RoHS (Restriction of Hazardous Substances) compliance: This confirms that the product adheres to environmental safety regulations by restricting the use of certain hazardous substances in electrical and electronic equipment.  

The emphasis on obtaining multiple certifications and conducting pre-shipment testing highlights a critical need for due diligence at the supplier selection stage in China. This proactive quality assurance is vital to prevent issues downstream in the supply chain. It underscores that compliance and safety are built into the product’s design and manufacturing, rather than merely being applied at the shipping dock. Shippers should always request product samples and, if possible, conduct independent third-party testing before placing bulk orders. This allows for verification of the battery’s performance, capacity, and cycle life, as well as confirmation of packaging quality and compliance with UN38.3 shipping standards, and detection of any defects such as overheating or leakage.  

Strategic Planning: Booking in Advance, Controlled Storage, and Segregation

Effective strategic planning is essential for the smooth transport of hazardous goods. It is highly recommended to book dangerous goods shipments from China to Europe well in advance, typically 2 weeks to 2 months prior to the desired shipping date. This extended lead time accounts for potentially longer customs clearance procedures, especially during peak shipping seasons.  

For air transport, it is crucial to secure space on cargo-only flights, as passenger flights have stringent bans on standalone lithium batteries. Hazardous materials also necessitate controlled storage conditions and proper segregation from incompatible materials throughout the shipment process to prevent accidents.  

The complex and dynamic nature of China’s export environment for hazardous goods, characterized by strict customs inspections, potential container shortages, rising freight costs, and even political factors, necessitates a strategic shift in procurement and logistics approaches. This implies that importers should consider moving away from traditional Cost, Insurance, and Freight (CIF) terms towards Free On Board (FOB) terms. Opting for FOB allows the importer greater control over the shipping process, enabling them to select their own, specialized dangerous goods forwarder. This can help mitigate risks and avoid the often-high, uncertain costs associated with CIF terms when dealing with hazardous cargo.  

Customs Clearance Assistance and Avoiding Delays

Upon arrival in Poland, goods must be promptly declared to local customs authorities to complete the clearance process. This typically requires essential documents such as the cargo manifest, Safety Data Sheet (SDS), and relevant safety certificates. The importer plays a crucial role in ensuring timely delivery by responding quickly to any import-related inquiries or issues from customs, such as missing EORI numbers, Power of Attorney documentation, or incomplete product information.  

Emergency Preparedness and Safety Management Plans

A robust safety management plan is indispensable for hazardous goods transport. This includes implementing preventive maintenance protocols and comprehensive incident response procedures. Furthermore, it is critical to ensure that all personnel involved in the transport of dangerous goods, from classification and packaging to loading and unloading, have received appropriate training, such as ADR 1.3 training. This ongoing training ensures that everyone in the supply chain is aware of the hazards, can take steps to reduce the likelihood of incidents, and is prepared to respond effectively in an emergency.  

Conclusion: Ensuring Safe and Compliant Hazardous Goods Transport

Successfully shipping hazardous goods, particularly lithium batteries and chemicals, from China to Poland requires a deep understanding and rigorous adherence to a multi-faceted regulatory framework. This framework encompasses global UN classifications, specific modal regulations such as the IATA Dangerous Goods Regulations for air transport and the ADR Agreement for road transport, mandatory product certifications like UN38.3, and intricate Polish national customs requirements.

Proactive compliance, meticulous documentation, and the establishment of strategic partnerships with experienced suppliers and freight forwarders are not merely recommended best practices but essential safeguards. By prioritizing safety and compliance at every stage—from initial product classification and rigorous testing to precise packaging, accurate labeling, comprehensive documentation, and secure transport—businesses can effectively mitigate significant risks. This diligent approach helps avoid costly delays and penalties, ultimately ensuring the secure and efficient movement of sensitive cargo across international borders. The continuously evolving regulatory landscape, particularly concerning lithium batteries and Poland’s increasing national import controls, underscores the critical need for ongoing vigilance and adaptability from all stakeholders in the supply chain.