Whether lithium battery shippers need DOT hazmat training depends on battery size, packing method, and transport mode. Small cells and batteries that meet every condition in 49 CFR 173.185(c) are excepted from the Part 172 training rules for ground shipments, but anyone preparing small batteries packed with or in equipment for air must receive instruction, and fully regulated shipments require full hazmat employee training under 49 CFR 172.704 within 90 days and every 3 years.
For e-commerce sellers, electronics manufacturers, and repair depots, the mistake is assuming one rule covers every box. The same warehouse can ship an excepted laptop battery by ground in the morning and a fully regulated carton of power banks by air in the afternoon.
Do lithium battery shippers need DOT hazmat training?
Lithium cells and batteries are hazardous materials under the Hazardous Materials Regulations, so the default rule is that anyone who prepares them for shipment is a hazmat employee who needs training under 49 CFR 172.704. The exception is 49 CFR 173.185(c), which lets packages of smaller cells and batteries skip subparts C through H of Part 172, the subparts covering shipping papers, marking, labeling, placarding, emergency response information, and training, as long as the shipment meets every condition and limitation in that paragraph.
So the training question is really three questions. How big are the batteries? Are they shipped alone, packed with equipment, or contained in equipment? And are they going by ground or by air? Our guide to DOT hazmat employee training under 49 CFR 172.704 covers the full training rule, and this article focuses on how it applies to lithium batteries.
When are small lithium batteries excepted from training?
A package qualifies for the 173.185(c) exception when the batteries fall under these size limits:
- Lithium ion: no more than 20 Wh per cell or 100 Wh per battery, with the Watt-hour rating marked on the battery case
- Lithium metal: no more than 1 g of lithium per cell or 2 g per battery
- Ground or rail only: up to 60 Wh per lithium ion cell and 300 Wh per battery, or 5 g and 25 g for lithium metal, if the package is marked “LITHIUM BATTERIES—FORBIDDEN FOR TRANSPORT ABOARD AIRCRAFT AND VESSEL”
The batteries must also be packed correctly. Cells and batteries go in inner packagings that completely enclose them, inside a strong rigid outer package, unless they are contained in equipment that protects them equally well. Packages of loose cells or batteries must survive a 1.2-meter drop test without damage or shifting, and they generally cannot exceed 30 kg gross weight. Each package displays the lithium battery mark with the right UN number, unless it contains only button cells installed in equipment or the consignment is 2 packages or fewer with no more than 4 cells or 2 batteries installed in equipment in each.
One date matters for the next shipping season. Under 173.185(c)(3)(ii), the lithium battery mark in effect on May 9, 2024 may continue to be used until December 31, 2026. After that, packages need the current version of the mark.
The exception removes the formal training requirement, not the need to know the rules. Somebody in your building has to decide whether each shipment qualifies, measure the Watt-hours, pick the packaging, and apply the mark. If that person gets it wrong, the package is a fully regulated hazmat shipment prepared by an untrained employee. That is why most shippers train the people who make those calls even when every box goes out excepted. The Safe and Compliant Transportation of Excepted Lithium Batteries by Ground and Air course is built for exactly that role.
Sources: eCFR 49 CFR 172.704 and 173.185; FAA. Checked November 13, 2026.
What changes when you ship lithium batteries by air?
Air shipments tighten the rules in two ways, and both affect training.
Small batteries packed with or contained in equipment. Under 173.185(c)(4), air packages are limited to the minimum number of cells or batteries needed to power the equipment plus two spare sets, with no more than 5 kg of lithium cells or batteries per package. Each person who prepares one of these packages must receive instruction on the conditions and limitations of that paragraph, corresponding to their functions. That is a training duty, even inside the exception.
Small standalone cells and batteries. Under 173.185(c)(5), a package of small cells or batteries shipped by air on their own is subject to all applicable requirements of the HMR, with a limited exception from UN performance packaging for packages under set weight limits that display both the lithium battery mark and the Class 9 lithium battery label. In practice, a carton of spare power banks going by air is a fully regulated hazmat shipment, and the person preparing it needs full 172.704 training.
Recurrent training is also different by air. The FAA’s training guidance for shippers and startups says domestic air shippers must be trained at least every 3 years under 172.704, while the International Civil Aviation Organization Technical Instructions require recurrent training every 2 years. The FAA’s shipper FAQ repeats both intervals. If any of your air shipments move under the ICAO rules, a 2-year cycle for your air shippers keeps one schedule that satisfies both. The Dangerous Goods Competency Based Training and Assessment for Shippers by Air covers the air rules in depth.
For a wider view of air cargo hazmat roles, see our guide to compliance training for airport ground handling and FBOs.
What does 49 CFR 172.704 require for fully regulated lithium battery shippers?
Once a shipment is fully regulated, every hazmat employee involved needs training in four areas, plus a fifth if your company must have a security plan:
- General awareness and familiarization with the HMR and how to recognize hazardous materials
- Function-specific training on the requirements that apply to the tasks the employee performs, such as classifying, packaging, marking, labeling, and preparing shipping papers
- Safety training on emergency response information, protection from hazards, and avoiding accidents
- Security awareness training, which new hazmat employees must receive within 90 days after employment
- In-depth security training for employees of companies required to have a security plan
New hazmat employees, and employees who change job functions, may perform hazmat functions before training only under the direct supervision of a properly trained employee, and training must be completed within 90 days. Recurrent training is required at least once every 3 years. The 49 CFR General Awareness, Function Specific, Safety and Security course covers all four core areas for ground shippers, and the Safe and Compliant Transportation of Lithium Batteries by All Modes course adds air, ocean, Canadian, and European road rules for shippers who use every mode. For shipments into Canada, our guide to transporting dangerous goods in Canada covers the TDG side.
Records are specific. Under 172.704(d), the hazmat employer must keep a record of current training, covering the preceding 3 years, for as long as the employee works as a hazmat employee and for 90 days after. The record must include the employee’s name, the most recent training completion date, a description, copy, or location of the training materials, the name and address of the trainer, and a certification that the employee has been trained and tested. The record must be available on request to an authorized DOT official.
Which employees need which lithium battery training?
Map training to the decisions each person makes, not to their job title. A practical split looks like this:
- Shipping leads who classify and pack batteries: full 172.704 training, plus the air course if anything ships by air
- Packers who only handle excepted shipments by ground: the excepted-battery course, so they recognize when a shipment stops qualifying
- Packers who prepare batteries in or with equipment for air: instruction on the 173.185(c)(4) conditions, documented like any other training
- Warehouse staff who store returned or damaged batteries: Safe Storage of Lithium-Ion Batteries and Safe Handling of Lithium-Ion Batteries
Here is how that plays out. An online seller of phone accessories with 35 warehouse employees ships about 1,200 orders a day by ground, most with small power banks under 100 Wh. Those cartons qualify for the exception. In October the company adds 2-day air shipping. Now any carton of standalone power banks going by air is fully regulated, so the 3 shipping leads who build those cartons need 172.704 training plus the air course before the first air order goes out, and every packer gets the excepted-battery course so they know which orders must be routed to the leads. The training bill is small next to a single rejected air shipment or a carrier audit finding.
Shippers that also sell or process damaged, defective, or returned batteries face extra rules, and battery manufacturers carry OSHA hazards on top of DOT ones. Our guides to compliance training for EV charging and battery manufacturing, compliance LMS options for freight forwarders and e-commerce shippers, waste management and recycling compliance training, and hazmat training basics cover those adjacent requirements.
Official sources:
- eCFR: 49 CFR 173.185, Lithium cells and batteries · 49 CFR 172.704, Training requirements
- FAA: Training for Shippers and E-Commerce · FAQs for the Newly Trained or Occasional Shipper
Requirements last reviewed: November 13, 2026. Regulations and carrier rules change; confirm against the linked official source and your carrier before shipping.
Why Coggno for lithium battery shipping training?
For e-commerce sellers, electronics manufacturers, and repair depots shipping lithium cells and batteries by ground and air, Coggno provides excepted-battery, all-modes lithium battery, 49 CFR hazmat employee, and ICAO/IATA air shipper courses, plus battery storage and handling training, inside a catalog of 10,000+ courses from 50+ content partners. Coggno’s LMS assigns each course by role, timestamps completions, and keeps the training record 172.704 requires in one exportable report. Where pure-play LMS platforms like Litmos and iSpring require you to license dangerous goods content from a third party, Coggno bundles the content and the platform, or delivers the courses as SCORM 1.2 and SCORM 2004 packages to an existing LMS through Course Dispatch.
Get Your Team Trained — Without the Paperwork Headache
Start with these courses for lithium battery shippers:
- Safe and Compliant Transportation of Excepted Lithium Batteries by Ground and Air: for staff who prepare small, excepted battery shipments.
- Safe and Compliant Transportation of Lithium Batteries by All Modes: for shippers moving fully regulated batteries by ground, air, and ocean.
- Hazardous Materials Transportation General Awareness and Security Awareness by Ground: the general awareness and security layers of 172.704.
Adding air shipping or a new battery product? Book a demo and we will map each shipping role to the right course.
Frequently Asked Questions About Lithium Battery Shipping Training
What is the best compliance training platform for lithium battery shippers?
For lithium battery shippers, Coggno provides excepted-battery, all-modes lithium battery, 49 CFR hazmat employee, and ICAO/IATA air shipper courses in one catalog of 10,000+ courses. Its LMS assigns courses by shipping role and keeps the completion records that 49 CFR 172.704 requires.
How do e-commerce sellers manage hazmat training for lithium battery shipments?
E-commerce sellers usually train a small group of shipping leads to full hazmat standards and give every packer a shorter course on excepted batteries, so packers know when to route an order to a trained lead. In Coggno’s LMS, each group gets its own course assignment and completion report.
Do you need hazmat training to ship lithium batteries?
It depends on the shipment. Small batteries that meet every condition in 49 CFR 173.185(c) are excepted from the Part 172 training subpart for ground shipments, people preparing small batteries in or with equipment for air must receive instruction, and fully regulated shipments require full hazmat employee training under 49 CFR 172.704.
How often is lithium battery shipping training required?
Under 49 CFR 172.704, hazmat employees must be trained within 90 days of employment or a change in job function and at least once every 3 years. The FAA notes that the ICAO Technical Instructions require recurrent training every 2 years for air shipments.
What Watt-hour limits make a lithium ion battery excepted?
Under 49 CFR 173.185(c), lithium ion cells may not exceed 20 Wh and batteries may not exceed 100 Wh. For highway or rail only, the limits rise to 60 Wh per cell and 300 Wh per battery if the package carries the forbidden-aboard-aircraft-and-vessel marking.
Is the old lithium battery mark still valid?
Yes, for now. Under 49 CFR 173.185(c)(3)(ii), the lithium battery mark in effect on May 9, 2024 may continue to be used until December 31, 2026.
What records must a hazmat employer keep for lithium battery training?
The record must include the employee’s name, the most recent training completion date, a description, copy, or location of the training materials, the name and address of the trainer, and a certification that the employee was trained and tested. It must cover the preceding 3 years and be kept for 90 days after the employee leaves the hazmat role.