Why Compliance Documents Matter
Used and end-of-life batteries are classified as hazardous goods under transport and environmental regulations in most jurisdictions. Suppliers must declare compliance status — and where applicable upload supporting documents — at the time of listing.
Buyers and recyclers rely on this information to plan collection logistics and meet their own regulatory obligations. Missing or inaccurate compliance information can delay deals, create liability for the parties involved, and in some cases prevent a transaction from completing.
Which Documents Are Required?
The documents required depend on the battery chemistry and transaction type:
| Chemistry | SDS Required | UN38.3 Relevant |
|---|---|---|
| Lithium-ion (NMC, LFP, NCA, LCO) | Yes | Yes — especially for transport |
| Lithium metal | Yes | Yes |
| Lead-acid (VRLA, flooded) | Recommended | Not applicable |
| NiMH and other chemistries | Recommended | Not applicable |
For lithium batteries, both an SDS and a UN38.3 declaration are expected. For other chemistries, compliance is strongly recommended but the platform does not block listing without it.
Safety Data Sheet (SDS)
An SDS describes the chemical composition, hazard classification, handling requirements, and emergency procedures for a battery. It is required for all lithium-ion and lithium metal listings.
What to upload:
- Use the original manufacturer's SDS where available. This is the most reliable source.
- If the battery has been modified, or the manufacturer's SDS is unavailable, a third-party SDS is acceptable — provided it accurately reflects the battery's chemistry and form factor.
- SDS documents must be in English (or accompanied by an English translation for UK transactions).
Where to upload: Step 3 of the listing wizard, under Safety Documents.
A valid SDS covers: chemical identity, physical and health hazards, protective equipment requirements, and emergency procedures for fire, spill, or accidental exposure.
UN38.3 Compliance
UN38.3 is the United Nations test standard for lithium batteries. It certifies that a battery has passed a series of tests covering shock, vibration, temperature cycling, altitude simulation, and short circuit. Compliance is required by most carriers for the transport of lithium batteries by air, sea, and road.
When to confirm UN38.3:
- Any lithium-ion or lithium metal battery being transported
- Lithium-ion packs destined for export or cross-border shipment
- Large-format or high-capacity cells (above 100Wh)
- Batteries with non-standard configurations
Where to declare: In the condition declaration section of the listing wizard, you will be asked whether your stock holds a UN38.3 test report. You can also upload the test report as a document.
If your stock does not hold a UN38.3 certificate, declare this clearly. Buyers and recyclers need to factor this into their transport planning. Some carriers will not move non-UN38.3-certified lithium batteries regardless of condition.
Condition Declaration
Every listing requires a condition declaration. This is your statement of the battery's physical and functional state at the time of listing. It is incorporated into the deal agreement and becomes part of the transaction record.
The condition declaration covers:
- Physical condition — casing integrity, connector state, visible wear or damage
- Damage assessment — whether any units have visible damage, and a description if so
- State of charge — the approximate charge level at the time of listing, where known
- Known faults or operational history — anything relevant to how the battery has been used
Accuracy Matters
The condition declaration is what buyers and recyclers rely on when deciding whether to proceed. Inaccurate declarations — whether through omission or misrepresentation — can affect dispute outcomes if the physical condition does not match what was stated. If in doubt, err on the side of disclosure.
Compliance for Recycling Deals
When submitting a recycling enquiry, the recycler may require compliance documents before accepting the batch. Review the recycler's processing terms for specific requirements.
Common document requests for recycling:
- SDS for the specific chemistry (especially for lithium batteries)
- UN38.3 test report, if the battery needs to be transported to the recycling facility
- Discharge confirmation — evidence that the battery has been discharged to a safe state of charge for handling and transport
Some recyclers require batteries to be discharged to a specific SOC before collection. If this is a requirement, it will be stated in the recycler's processing terms.
State of Charge and Safe Handling
High state-of-charge lithium batteries present additional handling and transport risks. Some carriers and recyclers require batteries to be discharged to 30% or below before transport.
If you are planning to sell or send batteries for recycling, consider the SOC at the time of listing. Discharging batteries before listing may broaden the range of buyers and recyclers willing to accept them.
Regulatory Responsibility
ReBattery provides the tools to declare and share compliance documents. Regulatory compliance for transport, handling, and disposal remains the responsibility of the parties to each transaction.
Requirements vary by jurisdiction. If you are unsure of your obligations — particularly for cross-border shipments or specific battery chemistries — consult a specialist in hazardous goods transport or environmental regulation. The platform cannot provide regulatory advice.