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Behind the Scenes: The Complexity of Stakeholders and Documentation in Battery Logistics
December 8, 2023
Behind the Scenes: The Complexity of Stakeholders and Documentation in Battery Logistics
Albin Eklund & Kristina Nilsson.

This article discusses battery logistics documentation, building upon Cling’s previous blog:

Behind the Scenes: The Intricate Logistics of Battery Circularity.

Moving batteries is a complicated process in a complex ecosystem. An eclectic group of stakeholders collaborates in the transportation of li-ion batteries: from the logistics companies themselves, to the sellers and buyers, insurance providers, warehouse partners, and customs officials.

Many actors are involved. The long chain is coupled with the complexity of the necessary documentation, in addition to batteries being hazardous material.

This article is a deep dive into the process. The significance of documentation in shaping the global battery industry will be uncovered. We suggest that streamlining the complexity is imperative to achieve battery circularity.

Table of contents

  1. Stakeholders
  2. Foundational Logistics Documents
  3. Battery-Related Documents
  4. Customs Documents
  5. Looking Ahead

Cling has moved battery packs, modules, and cells for reuse, repurposing, and recycling across the globe. We understand the pains of placing the wrong numbers in the wrong documents…  (Imagery: Valentin Loschinin)
Table displays essential data on battery logistics (Imagery: Filippa Hector)

1. Stakeholders

Numerous stakeholders are involved when transporting li-Ion batteries, all of whom perform different functions and require coordination. As addressed in the following section, up to 14 different documents are required to compliantly transport batteries. These documents will be introduced later, but understanding the necessity of these documents first requires a closer look at the group below:

  • Shipper: The stakeholder who orchestrates the shipping documentation and takes responsibility for the shipment. This can be either the battery buyer, seller or a third party (such as Cling) who takes on the role as the shipper and ensures harmony between all other stakeholders involved. The buyer and seller both benefit from the streamlined efficiency of a singular point of contact – alleviating them from the responsibility of document provision.
  • Suppliers and Sellers: The companies that produce and supply li-ion batteries, responsible for ensuring that their products meet safety standards and regulations. They are required to provide proper documentation and labelling for their shipped batteries. Examples of documents relevant for suppliers and sellers are Material Safety Data Sheets (MSDS', which include detailed information about the chemical product), Dangerous Goods Declarations (DGDs, which are documentation for the hazardous materials being transported), invoices, and Proof of Recycling/Repurposing.
  • Shipping and Logistics Companies: Freight carriers, shipping companies, and logistics providers need to be aware of, and comply with, legislation regarding transportation of batteries given that batteries are so-called “dangerous goods”. Another key participant is the captain of the freight ship, as the captain holds the final authority in determining whether the freight is permitted on the ship or not. The freight company requires documents such as: Pickup form, invoice, MSDS, and DGD.
  • Regulatory Authorities: Various regulatory bodies, such as the EU, UN, and local authorities, set guidelines and legislation to ensure safe transportation of li-ion batteries. These authorities issue the required certifications such as UN38.3, DGD and International Maritime Organization (IMO - a document for shipping hazardous goods overseas). As traceability laws and requirements increase, the authorities will demand more proof of documentation and reporting.
  • Buyers: Organizations purchasing and receiving batteries and products containing li-ion batteries should be aware of proper handling and disposal procedures. These stakeholders play a role in adhering to safety guidelines to prevent accidents and mishandling. The buyer needs to have the MSDS, invoice and sometimes a Transfer of Extended Producer Responsibility Form (TEPR) for the goods when receiving them. On occasion, the buyer requests a UN38.3 certification, which proves that the batteries meet the United Nations’ standards for safe transport.
  • Customs: Authorities responsible for customs and border control ensure that shipments comply with national legislation. They may inspect and verify documentation to prevent the illegal transportation of li-ion batteries. Documents relevant to them include a packaging list, invoice, country of origin, and proof of company registration.
  • Import and Export Agencies: The import and export of lithium-ion batteries involves navigating a complex set of regulations and safety standards. Import and export agents are helpful in ensuring that shipments comply with these regulations, promoting safety, and facilitating a smooth international trade process. Proof of Chamber of Commerce and the invoice are documents which the agencies must receive.
  • Insurance Providers: Insurance companies may be involved in mitigating the risks associated with the transportation of li-ion batteries. In order to maintain insurance coverage, stakeholders may need to comply with certain safety measures. Signing agreements between the shipper and insurance companies is a necessary step in the process. Invoices hold significance for the insurance provider.
  • Warehouse Operators: Warehouse operators manage both the inbound and outbound logistics for goods: providing comprehensive services. The operators are responsible for labelling and packaging the goods in accordance with the packaging guidelines provided. Documents relevant for the warehouse operators are packaging lists and pickup forms.

2. Foundational Logistics Documents

A set of foundational documents ensures the smooth flow of goods. These documents serve as the backbone of any logistics operations: addressing various aspects such as authenticity verification, efficient collection and transportation, and compliance with international shipping regulations. They include:

  • Proof of Authenticity: The Proof of Authenticity verifies the genuine nature of the batteries. It is for manufacturers, distributors, and consumers to guarantee product authenticity. With many counterfeits on the market (UL, 2023, link) access to this document is often necessary to sell batteries.
  • Pickup Form: The Pickup Form specifies details of the battery pickup, aiding in the efficient collection and transportation of batteries. If the exact specified battery is not picked up, traceability is lost (and requires a lot of administration and detective work to re-establish). Furthermore, each battery is unique with different characteristics, making any claims processes lengthy if the batteries that are delivered differ from the ones that were specified.
  • Packaging List: The packaging list provides information about the shipment, including details about the contents, the number of batteries, their size, weight, and any other relevant physical specifications. It provides information to relevant parties such as the exporter, transporter, customs authorities, and importers. The packaging list is important for accurate shipment verification, customs clearance, handling instructions, insurance claims, supply chain visibility, and as a communication tool.
  • Invoice: The invoice serves as a documentation of the financial transaction related to the battery shipment, and it should include details such as price, country of origin, incoterms (global trade and logistics responsibilities), HS-code (an international product classification system for trade), packaging type, dimensions, and weight. Any discrepancies in these numbers pose a risk of customs delays. The invoice aids buyers, sellers, and customs authorities to ensure accurate taxation, valuation, and import/export compliance. In addition, the invoice is also important to distinguish whether the batteries shipped are considered waste vs. used batteries (fit for reuse).
  • International Maritime Organization (IMO) document: The IMO is a declaration required for international sea shipping and encompasses regulations, safety standards, and environmental protection in the maritime industry. If unavailable, loading onto the ship is not permitted. Whether specific goods are allowed is ultimately up to the captain. Proper warehousing documentation, with pictures and history of the goods has shown to be important.

3. Battery-Related Documents

Battery-related documents exist for ensuring the safety and integrity of battery transportation. These documents provide information about the batteries, safety requirements, and compliance with international regulations. It is worth noting that the industry would benefit from a more robust culture of sharing such information. By fostering a collaborative approach to disseminating knowledge, we can collectively contribute to enhancing safety standards, promoting innovation, and ensuring a more sustainable future for battery technology, at a faster speed.

  • MSDS (Material Safety Data Sheet): The MSDS, sometimes referred to as SDS (Safety Data Sheet), provides information about a battery's chemical composition, hazards, and safety precautions. It ensures the safe handling, storage, and transportation of batteries, benefiting everyone involved in the supply chain. Despite not being required by legislation, MSDS has become industry standard.
  • UN38.3 (UN Manual of Tests and Criteria): The UN38.3 certification ensures batteries comply with international safety and transportation regulations. It is for manufacturers and shippers to demonstrate compliance and safety to authorities and customers. UN38.3 should be available to show upon request.
  • Dangerous Goods Declaration (DGD): The DGD is required because batteries contain substances which pose a risk to health, safety, property, and the environment. It warns and outlines the dangerous properties of the goods, necessary precautions, and emergency response information. For example, different battery chemistries require different fire extinguishing methods. The DGD must be easily available to carriers, regulatory authorities, and first responders, to act correctly in the case of an incident.
  • Transfer of Extended Producer Responsibility Form (TEPR): The TEPR lists the battery identification numbers (BINs) and is used when batteries are sold for second life use. The TEPR is signed by the seller and buyer to ensure proper transfer of EPR. This is expected to become increasingly important as the circular economy holds many (re)-producers of the same products. Clear cut transfer of EPR (read our deep dive) is necessary to properly manage liabilities and reduce legal risks for all parties involved.
  • Proof of Recycling: The Proof of Recycling confirms proper disposal and recycling of batteries, ensuring fulfilment of extended producer responsibility and compliance with recycling regulations. This documentation is relevant for recycling facilities and environmental agencies and must be made available to authorities. Today, the Proof of Recycling is based on weight, but as regulations regarding traceability of batteries become more stringent, the Proof of Recycling could align and be linked to specific battery IDs. This would require an entirely new level of document management.
  • Proof of Repurposing: Currently, Proof of Repurposing is not required. Nevertheless, there is value in establishing it within the industry to verify and track the proper repurposing of batteries and ensure accurate information on sustainability metrics, such as greenhouse gas emission data. Cling believes this proof will become mandatory as new battery regulations are implemented.

4. Customs Documents

Customs documents are utilized for navigating international trade regulations and ensuring the efficient and transparent movement of batteries across borders. Working with customs agents has taught Cling some useful information to be shared with the ecosystem.

  • Power of Attorney (for Import/Export): The PoA authorizes a third party to act on behalf of an importer or exporter during customs procedures. It streamlines customs clearance, thus benefitting importers, exporters, and customs brokers.
  • Proof of Chamber of Commerce: Proof of Chamber of Commerce confirms a company's registration with the local Chamber of Commerce, demonstrating its legitimacy. It is used by customs authorities and partners involved in international trade.
  • Customs Broker Agreement: The Customs Broker Agreement allows an importer to appoint a customs broker to help in clearing imported goods. Consulting a customs broker or a tax professional has benefits. These include their expertise in international trade and EU regulations - useful for navigating the complexities of importing/exporting goods into the EU, especially for li-ion batteries.

Input: Cling's user-friendly document generation portal. Output: ready-for-use, compliant documentation

Necessary documents are generated automatically using Cling’s platform. Compiling them all in one place, connected to the unique battery identification number, removes much of the administrative load in battery logistics. (Imagery: Valentin Loschinin)

5. Looking ahead

The global demand of lithium-ion batteries is increasing exponentially. By 2030, demand is expected to reach 4.7 TWh by 2030 (McKinsey, 2023). In parallel, there is a growing case for proper end of life management of batteries. The volume of batteries expected to reach end of life in 2030 is over 300 GWh (Circular Energy Storage), or more than 6% of the massive global demand (McKinsey, 2023).

The circular economy sits in a powerful position to provide a significant source of necessary energy storage. Efficient logistics and handling of both new and used batteries is becoming a key enabler of the transition to a sustainable and thriving society. As upcoming regulations around the world impose stricter requirements on battery logistics, the industry must prepare to comply.

In summary, safe and compliant battery logistics is complex and challenging. The accurate preparation of the necessary documentation takes time, effort and can cause long lead times. In pursuit of global battery circularity, Cling has gained invaluable experience in moving batteries across the world while developing solutions to drastically improve the efficiency of battery logistics.

Cling Systems automates and simplifies document preparation, storage, and distribution – making all necessary documents easily available to all stakeholders within battery logistics. Do get in touch if you find you are spending too much time and energy transporting batteries, and we can explain how we can smoothen the process.

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