Robot Buying Guide

Shipping Robots with Lithium Batteries from China to the Gulf: UN 3481, UN38.3 and the Paperwork

Facts last checked: 2026-10-14 · Not legal advice

Scope. Moving a delivery, serving or cleaning robot with a lithium-ion battery from China to a GCC state by sea or air. This page summarises the rules and quotes them where we could open the source. It is not a substitute for the regulations themselves or for a trained dangerous-goods shipper: in most cases a forwarder with certified staff prepares and signs the dangerous-goods paperwork. No costs or fees are given. Anything we could not confirm says not verified .

1. Which rules apply

  • Sea: the IMDG Code. IMO says the 2024 Edition (Amendment 42-24) “came into force on 1 January 2026” and is mandatory from that date.[source, retrieved 2026-10-14] China’s Maritime Safety Administration (MSA) published an announcement implementing Amendment 42-24 for shipments from China.[source, retrieved 2026-10-14]
  • Air: the ICAO Technical Instructions and, for airlines, the IATA Dangerous Goods Regulations (DGR). IATA’s 2026 lithium battery guidance is based on the 2025–2026 ICAO Technical Instructions and the 67th edition (2026) of the DGR.[source, retrieved 2026-10-14] We could not open the ICAO text itself; air rules below are taken from IATA’s guidance and are flagged as such.
  • Both modes take their classification from the UN Recommendations on the Transport of Dangerous Goods (Model Regulations) and the UN Manual of Tests and Criteria (sub-section 38.3 for lithium batteries). The UNECE site refused our requests on 2026-10-14, so we quote the UN wording through the national regulators that adopt it.

2. Classifying the robot: UN 3481 or a “vehicle” entry?

Lithium batteries are Class 9 dangerous goods. The usual entries are:[source, retrieved 2026-10-14] [source, retrieved 2026-10-14]

UN numberProper shipping nameWhen it fits a robot shipment
UN 3480Lithium ion batteriesSpare batteries shipped on their own
UN 3481Lithium ion batteries contained in equipmentBattery installed in the robot
UN 3481Lithium ion batteries packed with equipmentBattery in the same package as the robot but not installed
UN 3556Vehicle, lithium-ion battery poweredOnly if the robot counts as a “vehicle” (see below)

The vehicle question. Since Amendment 42-24, China MSA says lithium-ion powered vehicles that used to go under UN 3171 must be shipped as UN 3556, and UN 3171 is limited to vehicles and equipment powered by wet, sodium-metal or sodium-alloy batteries.[source, retrieved 2026-10-14] IATA’s guidance lists UN 3556 under Packing Instruction 952 for “vehicles where the principal source of power is from a battery”.[source, retrieved 2026-10-14]

Zhejiang MSA’s battery guide (January 2026) gives the IMDG definition: the vehicle entry applies only to vehicles, meaning self-propelled apparatus designed to carry one or more persons or goods, with examples such as cars, scooters, wheelchairs, lawn tractors and self-propelled farm and construction equipment.[source, retrieved 2026-10-14] The same UN special provision (SP 388) gives lawnmowers and cleaning machines as examples of equipment, which goes under UN 3481 (secondary copy of the provision text).[source, retrieved 2026-10-14]

What this means for robots:

  • Cleaning robots match the “cleaning machines” example of equipment, which points to UN 3481. This relies on a secondary copy of the UN text; we could not open the UN original.
  • Delivery and serving robots are self-propelled and carry goods. Whether they are “vehicles” (UN 3556) or “equipment” (UN 3481) is not verified . We found no official ruling or guidance that names service robots.
  • Zhejiang MSA says that where classification is unclear, the manufacturer can commission a qualified testing and assessment body for a classification report or transport-condition assessment.[source, retrieved 2026-10-14] Ask your supplier whether it holds one for your model, and agree the UN number with your forwarder before booking.
  • Older documents may still say UN 3171 for battery-powered vehicles. For lithium-ion vehicles that entry no longer applies under Amendment 42-24.[source, retrieved 2026-10-14]

3. Battery size changes the paperwork

Small batteries. Under IMDG Special Provision 188, as summarised by Zhejiang MSA, batteries are relieved from most other IMDG provisions if each lithium-ion cell is not more than 20 Wh and each battery not more than 100 Wh, among other conditions (protection against short circuit, a device to prevent accidental activation for equipment, a lithium battery mark on the package).[source, retrieved 2026-10-14] IATA’s air table uses the same 20 Wh cell / 100 Wh battery split between “Section II” and fully regulated “Section I” shipments.[source, retrieved 2026-10-14]

Larger batteries are fully regulated Class 9 goods: class labels, a dangerous-goods declaration and the full packing instruction apply. The watt-hour rating of a service robot’s battery is often not published; our model pages show it where the manufacturer states it and mark it not verified otherwise (for example KEENON T9, KEENON C55, AGIBOT C5). Get the figure from the UN38.3 test summary.

4. State of charge (air, from 2026)

IATA’s guidance says that from 1 January 2026, lithium-ion batteries packed with equipment, and vehicles powered by lithium-ion batteries, must be offered for air transport at a reduced state of charge unless the relevant States approve otherwise (Special Provision A331).[source, retrieved 2026-10-14] For vehicles with batteries over 100 Wh, the limit is a state of charge not exceeding 30% of rated capacity, or an indicated capacity not exceeding 25%.[source, retrieved 2026-10-14] Batteries shipped on their own (UN 3480) must also be at no more than 30% and cannot go on passenger aircraft without approval.[source, retrieved 2026-10-14]

This is a single source (IATA guidance on the ICAO rules). A state-of-charge rule for batteries contained in equipment by air, and any sea-freight state-of-charge rule for export shipments, is not verified .

5. Documents the shipper needs

From the manufacturer (see our supplier documents guide):

  • UN38.3 test summary. Manufacturers and later distributors of lithium cells and batteries, and of equipment containing them, must make it available; any party in the supply chain may request it.[source, retrieved 2026-10-14] [source, retrieved 2026-10-14] IATA says it does not have to travel with every shipment unless a State or operator requires it.[source, retrieved 2026-10-14]
  • Safety data sheet (危险货物安全技术说明书) for the battery.[source, retrieved 2026-10-14] [source, retrieved 2026-10-14]
  • Classification report, where classification is unclear (section 2).

For a sea shipment from China (Zhejiang MSA guide, January 2026): the shipper or its agent files a dangerous-goods safe-transport report (货报) with the MSA through its online portal before the goods are loaded. The listed materials are: applicant ID, a declaration that the dangerous goods are fit for transport, the safety data sheet, transport-condition assessment materials where applicable, packaging and cargo transport unit inspection certificates where applicable, the container packing certificate, and a power of attorney if an agent files. The filing must be made by a certified declarant.[source, retrieved 2026-10-14] Jiangsu MSA’s guide also says the shipper must give the carrier the battery category and quantity, the safety data sheet and packaging inspection certificates.[source, retrieved 2026-10-14] Local MSA offices may simplify filings (Zhejiang, for example, says the UN38.3 summary goes to the carrier rather than the MSA).[source, retrieved 2026-10-14]

For an air shipment from China: China’s civil aviation authority (CAAC) publishes standard MH/T 1020-2018 on air transport of lithium batteries, which requires compliance with the ICAO Technical Instructions and IATA DGR (read through a search index; the CAAC file did not open from our server).[source, retrieved 2026-10-14] The current CAAC requirements for a transport-condition assessment report for robot shipments are not verified ; ask your air forwarder.

6. Marks and labels

  • Lithium battery mark: a rectangle with a red hatched border, minimum 100 mm × 100 mm (or 100 mm × 70 mm on small packages), showing the UN number.[source, retrieved 2026-10-14] [source, retrieved 2026-10-14]
  • Class 9 lithium battery label (fully regulated shipments) and Class 9 placards on the container for sea freight.[source, retrieved 2026-10-14]
  • Vehicles (UN 3556): China MSA says marks and labels are needed when the vehicle is fully enclosed by packaging or crates so that it cannot be readily identified, and a new packing instruction P912 applies to their loading and securing.[source, retrieved 2026-10-14]

7. What Gulf authorities add

  • UAE (air). The GCAA’s CAR Part VI (Rev 1.5, 16 September 2024) requires UAE-originating dangerous goods to be offered and accepted by a GCAA Dangerous Goods Certified entity, and says lithium batteries, including in or with equipment, must be kept from extended direct sunlight, heat and humidity during acceptance, storage, handling and loading, “special attention” being given from 1 June to 31 October.[source, retrieved 2026-10-14] The certified-entity rule is for shipments leaving the UAE; for imports it matters if you re-ship by air within or out of the UAE. Single official source.
  • Saudi Arabia (sea). The national portal lists a “Dangerous Goods Declaration” service for ports (read through a search index; the page refused our request).[source, retrieved 2026-10-14] The details are not verified .
  • Qatar, Kuwait, Oman, Bahrain: national port or civil-aviation rules on lithium battery imports beyond the IMDG Code and ICAO Technical Instructions are not verified .

Import clearance (duty, VAT, conformity, radio approval) is covered in the country guides: UAE, Saudi Arabia, Qatar, Kuwait, Oman, Bahrain. Dangerous-goods handling is line F of the landed-cost worksheet.

8. Checklist before booking

  • Battery chemistry, watt-hour rating and battery model, from the UN38.3 test summary.
  • UN number agreed with your forwarder (UN 3481 contained in / packed with equipment, or UN 3556 if treated as a vehicle).
  • Spare batteries listed separately (UN 3480 or UN 3481 packed with equipment).
  • Safety data sheet with a recent revision date.
  • Classification report, if the supplier has one.
  • State of charge, if shipping by air.
  • Who files the MSA safe-transport report, or prepares the air dangerous-goods declaration.

9. What we could not confirm

  • Whether delivery or serving robots are “vehicles” (UN 3556) or “equipment” (UN 3481). No official ruling found.
  • The UN Model Regulations and ICAO Technical Instructions texts themselves (UNECE refused our requests; ICAO text not public). Air rules come from IATA’s guidance.
  • Current CAAC requirements for air transport-condition assessments of robots.
  • Gulf national rules on lithium battery imports beyond the IMDG Code and ICAO, except the UAE GCAA points above.
  • Battery watt-hour ratings for most robot models.

Sources used

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