Lithium Battery Importer of Record Japan (UN38.3 / IATA Section II)

Lithium battery imports require UN38.3 test evidence, correct IATA classification (Section II vs Section IA), and configuration-specific packaging. Aplash reviews the manufacturer's accredited-lab UN38.3 certificate, confirms watt-hour and lithium-content thresholds, and acts as named Importer of Record under 関税法 (Customs Act).

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Engagement scope

  • UN38.3 test report review and verification (Aplash reviews the manufacturer's accredited-lab certificate; Aplash itself is not a UN38.3 lab).
  • IATA Section II vs Section IA classification, State of Charge (SoC) compliance verification, packaging instruction PI 965 / 966 / 967 verification per current IATA edition.
  • Customs declaration as named Importer of Record for lithium-ion, lithium-metal, and lithium-polymer batteries in three packing configurations: loose cells, equipment-contained, and packed-with-equipment.
  • Coordination of end-of-life and used-battery return shipment under Japan-side waste regulations.
  • Watt-hour and lithium-content threshold verification (the line between Section II passenger-aircraft-acceptable and Section IA forbidden-on-passenger-aircraft).

Outside scope

  • Perform UN38.3 testing — Aplash is not a UN38.3 accredited lab. Manufacturer's accredited-lab certificate is required input.
  • Issue Section IA forbidden-on-passenger-aircraft waivers — these come from the carrier and from civil aviation authorities, not from Aplash.
  • Salvage or damaged battery handling — specialized waste classification, out of scope.
  • Vehicle-mounted EV traction pack imports above certain size thresholds — vehicle import regulation overlay; escalate.
  • Lithium-thionyl-chloride and other specialty cells where the manufacturer's test data is incomplete — decline pending data.

Three lithium chemistries Aplash handles

  • Lithium-ion (Li-ion) — rechargeable cells used in consumer electronics, e-mobility, and grid storage.
  • Lithium-metal (Li-metal) — primary cells with metallic lithium anodes, typically non-rechargeable.
  • Lithium-polymer (Li-poly) — polymer-electrolyte cells common in slim-form-factor devices.

Section II vs Section IA threshold

ConfigurationSection II (passenger-aircraft acceptable)Section IA (cargo-only, carrier waiver)
Watt-hour rating≤100 Wh per cellAbove 100 Wh per cell
Lithium-metal content≤2 g per cellAbove 2 g per cell
Aplash IOR positionStandard pricing bandComplex pricing band; carrier confirmation required

UN38.3 test report checklist

  • 8-test summary covering altitude, thermal, vibration, shock, external short circuit, impact, overcharge, forced discharge.
  • Drop test record (1.2 m).
  • Product-configuration match: cell chemistry, capacity, packaging matched to current production.
  • Issuing accredited-lab identifier and report date.
  • Configuration-change history since report issuance.

Pricing band

Standard Section II (single SKU, equipment-contained, ≤100 Wh cells): from $2,800 per shipment. Section IA, loose cells, multi-SKU, or air-cargo-only configurations: from $4,800 per shipment.

Customs duties and Japanese consumption tax (JCT) pass through at cost. Aplash earns no margin on the goods, only on the service.

Frequently asked questions

What is UN38.3?

UN38.3 is the United Nations test standard (ST/SG/AC.10/11/Rev.7) covering eight performance tests required for the transport of lithium cells and batteries. Aplash reviews the manufacturer's accredited-lab certificate before customs filing.

What is the difference between IATA Section II and Section IA?

Section II covers smaller lithium cells (≤100 Wh, ≤2 g lithium) acceptable on passenger aircraft with standard packaging. Section IA covers larger or higher-energy cells, often forbidden on passenger aircraft or requiring carrier waiver and cargo-only routing.

Can Aplash IOR for damaged or recalled lithium batteries?

Damaged, defective, or recalled batteries (UN3090, UN3091 with damage indicators) require specialized waste-classified handling outside Aplash's standard IOR scope. We coordinate referrals to specialized hazardous-waste partners.

Do I need to test my batteries again if the report is old?

UN38.3 does not formally expire, but configuration changes (cell chemistry, packaging, capacity) invalidate the report. Accredited labs typically refresh certificates every 4 to 5 years. Aplash flags expiry risk during the engagement review.

What about lithium batteries in medical devices or in IT equipment?

Packed-with-equipment and contained-in-equipment configurations are routinely handled. The underlying device may bring additional regulation (薬機法 (Pharmaceutical and Medical Device Act) for medical, PSE (電気用品安全法) for IT) that Aplash coordinates in parallel.

Applicable law and standards

  • 関税法 (Customs Act) [R1]
  • UN38.3 (International standard ST/SG/AC.10/11/Rev.7) [R1]
  • IATA DGR Section II / Section IA (International transport standard, current edition) [R1]

Related pages

Aplash sequences customs filing only after the UN38.3 evidence and IATA section classification are confirmed. Engagement starts with a manufacturer-document review at no cost.

Request a no-cost commodity assessment. We confirm IOR feasibility and quote against the public pricing band before any commitment.

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