Lithium Battery Importer of Record in Japan (UN38.3 / IATA DGR)
Want to ship lithium batteries into Japan without setting up a local company? Aplash becomes your Importer of Record (IOR): the company named on the customs entry. We review the manufacturer's UN38.3 test summary, confirm the watt-hour or lithium-content limits, identify the UN number and current IATA packing instruction, 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 the manufacturer's UN38.3 test summary and match its model information to the batteries being shipped (Aplash reviews the supplied record; we are not a UN38.3 test laboratory).
- Classify the shipment by chemistry, UN number, standalone / packed-with / contained-in-equipment configuration, energy or lithium content, quantity, applicable section, and current IATA packing instruction PI 965-970.
- 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.
- Check State of Charge (SoC), packaging, marking, documentation, quantity, and passenger-aircraft or cargo-aircraft restrictions for the specific configuration.
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 State or operator approvals or exemptions for passenger-aircraft carriage or exceptional State of Charge. Those decisions sit with the relevant authorities and operator, not 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.
How the 2026 IATA classification changes by configuration
| Shipment form | Packing instruction and section | Passenger-aircraft position |
|---|---|---|
| Standalone lithium-ion (UN3480) | PI 965 Section IA above 20 Wh per cell or 100 Wh per battery; Section IB at or below those limits | Forbidden unless the specific State / operator approval route applies; normally 30% SoC maximum |
| Standalone lithium-metal (UN3090) | PI 968 Section IA above 1 g per cell or 2 g per battery; Section IB at or below those limits | Forbidden unless the specific approval or exemption route applies |
| Packed with or contained in equipment (UN3481 / UN3091) | PI 966 / 967 / 969 / 970; Section I above the relevant energy or lithium limits, Section II at or below | May be permitted subject to the applicable packing instruction and per-package quantity limit |
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.
- Manufacturer, laboratory, report identifier, report date, and the responsible signatory shown in the test summary.
- That the cell or battery model, chemistry, mass, watt-hour rating or lithium content match what is actually being shipped.
- The edition of the UN Manual of Tests and Criteria used for testing.
- Any design changes that may require a new assessment or testing under the UN38.3 design-type rules.
Pricing band
Standard single-SKU batteries packed with or contained in equipment under the applicable lower-energy section: from $2,800 per shipment. Standalone batteries, Section IA / IB, multiple SKUs, or cargo-aircraft-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.
How do IATA Sections IA, IB, I, and II apply?
The section depends on chemistry, whether the battery is standalone or packed with / contained in equipment, cell-versus-battery energy or lithium content, and quantity. Standalone UN3480 and UN3090 use PI 965 / 968 Sections IA or IB and are forbidden on passenger aircraft unless a specific approval or exemption applies. Equipment configurations use PI 966 / 967 / 969 / 970 Sections I or II and have their own passenger-aircraft quantity limits.
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?
A UN38.3 test summary does not have a simple fixed expiry date. However, the shipped model must match the tested design type, and design changes can trigger a need for new assessment or testing. We compare the supplied summary and model data rather than relying on the report date alone.
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 PI 965-970 (Sections IA / IB / I / II as applicable, 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.