Lithium Battery Importer of Record in Japan (UN38.3 / IATA Section II)
Want to ship lithium batteries into Japan without setting up a local company? Aplash becomes your Importer of Record (IOR): the legal company named on the customs entry. We check the manufacturer's UN38.3 test certificate (the UN safety-test report required for lithium cells), confirm the watt-hour and lithium-content limits, classify the shipment under the correct IATA rule, and file the import under the Customs Act (関税法).
How it works
An Importer of Record (IOR) is the company legally responsible for bringing goods through customs. Aplash takes that role so you can sell into Japan without a local entity.
- 1Free commodity assessmentSend your product details. We confirm whether Aplash can be your importer and give you a quote, at no cost.
- 2We import as your Importer of RecordAplash clears customs in its own name under the Customs Act (関税法) and arranges any permits or certifications your goods need.
- 3Delivered to your Japan buyerWe hand the goods to your Japan-side buyer and invoice transparently, so you sell in Japan with no company of your own there.
What Aplash handles
- Review and verify the manufacturer's UN38.3 test certificate, issued by an accredited test lab (Aplash checks the certificate; we are not a UN38.3 test lab ourselves).
- Classify the shipment as IATA Section II or Section IA, confirm State of Charge (SoC, how full the battery is) compliance, and check the packaging against the current IATA packing instructions PI 965 / 966 / 967.
- File the customs declaration as named Importer of Record for lithium-ion, lithium-metal, and lithium-polymer batteries, in three configurations: loose cells, batteries built into equipment, or batteries packed alongside equipment.
- Coordinate the return shipment of end-of-life or used batteries under Japan's waste-handling rules.
- Confirm whether your batteries fall under Section II (allowed on passenger aircraft) or Section IA (forbidden on passenger aircraft) by checking the watt-hour rating and lithium content.
What we do not handle
- Run UN38.3 testing ourselves. Aplash is not an accredited UN38.3 lab, so a certificate from the manufacturer's accredited lab is required before we can act.
- Issue Section IA waivers for carrying batteries on passenger aircraft. Those come from the airline and from civil aviation authorities, not from Aplash.
- Handle salvage or damaged batteries. This needs specialized waste classification and sits outside our scope.
- Import vehicle-mounted EV battery packs above certain size thresholds. These fall under separate vehicle-import rules, so we escalate rather than quote directly.
- Take on lithium-thionyl-chloride cells or other specialty chemistries where the manufacturer's test data is incomplete. We pause the engagement until that data is provided.
Three lithium chemistries Aplash handles
- Lithium-ion (Li-ion): rechargeable cells used in consumer electronics, e-mobility, and grid storage.
- Lithium-metal (Li-metal): single-use cells with a metallic lithium anode, typically not rechargeable.
- Lithium-polymer (Li-poly): polymer-electrolyte cells common in thin, slim-form-factor devices.
Section II vs Section IA: where the line sits
| Configuration | Section II (passenger aircraft allowed) | Section IA (cargo aircraft only, carrier waiver needed) |
|---|---|---|
| Watt-hour rating | 100 Wh or less per cell | Above 100 Wh per cell |
| Lithium-metal content | 2 g or less per cell | Above 2 g per cell |
| Aplash IOR position | Standard pricing band | Complex pricing band; carrier confirmation required |
What we check in your UN38.3 test report
- The 8-test summary: altitude, thermal cycling, vibration, shock, external short circuit, impact, overcharge, and forced discharge.
- The drop-test record (a 1.2 m drop test).
- That the product configuration matches: cell chemistry, capacity, and packaging match what is actually in production.
- The accredited lab's identifier and the report date.
- Any configuration changes made since the report was issued.
Pricing band
Standard Section II (single SKU, built into equipment, 100 Wh or less per cell): from $2,800 per shipment. Section IA, loose cells, multiple SKUs, or air-cargo-only configurations: from $4,800 per shipment.
Customs duty and Japanese consumption tax (JCT) are passed on at cost. Aplash earns no margin on the goods, only on the service.
Not sure if your goods qualify?
Send the product details. We confirm whether Aplash can import it and quote against the public pricing band before you commit.
Frequently asked questions
What is UN38.3?
UN38.3 is the United Nations safety-test standard (ST/SG/AC.10/11/Rev.7) covering eight performance tests required before lithium cells and batteries can be transported. Aplash reviews the manufacturer's accredited-lab certificate before filing customs.
What is the difference between IATA Section II and Section IA?
Section II covers smaller lithium cells (100 Wh or less, 2 g lithium or less) that are allowed on passenger aircraft with standard packaging. Section IA covers larger or higher-energy cells, which are often forbidden on passenger aircraft and need a carrier waiver and cargo-only routing instead.
Can Aplash act as IOR for damaged or recalled lithium batteries?
Damaged, defective, or recalled batteries (UN3090, UN3091 with damage indicators) need specialized waste-classified handling that sits outside Aplash's standard IOR scope. We can refer you to specialized hazardous-waste partners.
Do I need to retest my batteries if the report is old?
UN38.3 certificates do not formally expire, but any change to the configuration (cell chemistry, packaging, or capacity) invalidates the existing report. Accredited labs typically refresh certificates every 4 to 5 years. Aplash flags expiry risk during the engagement review.
What about lithium batteries inside medical devices or IT equipment?
Batteries packed with equipment or built into equipment are routinely handled. The device itself may bring its own regulation alongside the battery rules: the Pharmaceutical and Medical Device Act (薬機法) for medical devices, or PSE (電気用品安全法, Electrical Appliance Safety Act) for IT equipment. Aplash coordinates both in parallel.
Applicable law and standards
- Customs Act (関税法)
- UN38.3 (International standard ST/SG/AC.10/11/Rev.7)
- IATA DGR Section II / Section IA (International transport standard, current edition)
Related pages
Aplash only files the customs entry once the UN38.3 evidence and IATA section classification are confirmed. Every engagement starts with a free review of your manufacturer documents.