Quick answer: A UN 38.3 test summary is a document, mandatory since January 1, 2020, that lithium cell and battery manufacturers and distributors must make available to prove the product passed the eight UN 38.3 transport safety tests. It records the manufacturer, test lab, report number, product description, tests passed, and an authorized signatory.
The UN 38.3 test summary is the single piece of paper that decides whether a lithium battery load moves or sits on a dock. It is a standardized attestation that a cell or battery passed the design tests in Section 38.3 of the UN Manual of Tests and Criteria, and both the manufacturer and every subsequent distributor are required to make it available. Miss it, and the carrier can lawfully refuse the freight. This guide covers exactly what the document must contain, who owns the obligation, and who eats the cost when it is not there at tender.
What a UN 38.3 test summary actually is
A UN 38.3 test summary is a short, standardized document that certifies a lithium product passed the required transport tests, and it is not the same thing as a test report or a certificate. The summary is a roughly one-page attestation of results, defined in Section 38.3.5 of the UN Manual of Tests and Criteria. The full test report is a separate, usually confidential engineering document held by the manufacturer or lab. And there is no government-issued "UN 38.3 certificate," so any party promising one is describing something the standard does not create. Confusing these three is the most common documentation failure we see.
The requirement is now baked into U.S. law at 49 CFR 173.185 (PHMSA), and it reaches every cell or battery manufactured on or after January 1, 2008. The obligation to make the summary available took effect January 1, 2020.
The eight tests behind the summary
The summary attests to the results of eight tests, run to prove a battery survives the physical realities of transport. The first tests are applied in sequence to the same units, so the stresses accumulate the way a real journey stacks them.
TestNameApplies to
T.1
Altitude simulation
Cells and batteries
T.2
Thermal test
Cells and batteries
T.3
Vibration
Cells and batteries
T.4
Shock
Cells and batteries
T.5
External short circuit
Cells and batteries
T.6
Impact / crush
Cells only
T.7
Overcharge
Rechargeable batteries only
T.8
Forced discharge
Cells only
One point trips up assemblers constantly: a battery built from already-tested cells still needs its own applicable testing. Passing cells do not automatically qualify the pack. For the broader classification and packaging picture these tests sit inside, see our overview of hazmat shipping and load rates.
What a compliant test summary must contain
A compliant summary has ten required data elements, and a missing or blank field is enough to get a load questioned. Run this as a pass or fail audit before you tender freight:
- Name of the manufacturer of the cell, battery, or product.
- Manufacturer contact information: address, phone, email, and website.
- Name of the test laboratory, with its contact information.
- Unique test report identification number.
- Date of the test report.
- Description of the cell or battery: lithium-ion or lithium-metal, mass, watt-hour rating (ion) or lithium content in grams (metal), physical description, and model numbers.
- List of each test conducted and its result, T.1 through T.8, pass or fail.
- Reference to assembled-battery testing requirements, where a battery and not just its cells was tested.
- Reference to the revised edition of the UN Manual of Tests and Criteria, including amendments, used to perform the tests.
- Name, title, and signature of the person responsible for the summary's accuracy.
Two fields fail most often. Element nine, the edition and amendment reference, is where stale summaries get caught, because a summary that cites an outdated edition of the Manual invites a bounce. Element six is the other, when the watt-hour or lithium-content data is incomplete. Audit those two first.
Who is responsible, and who pays when it is missing
Responsibility for the test summary runs down the entire supply chain, not just to the manufacturer. The regulation states that each manufacturer and subsequent distributor must make the summary available. A distributor cannot shrug and say the manufacturer has it somewhere. If you tender the freight, you need to be able to produce the document.
When the summary is missing at pickup, the consequences fall in a predictable order. The carrier can lawfully refuse the load. The offeror who tendered non-compliant hazmat is exposed to PHMSA civil penalties, which reached up to $102,348 per violation per day in 2025 and as much as $238,809 when a violation causes death, serious injury, or substantial property loss (PHMSA, 2025). And the practical costs, demurrage, storage, and redelivery on the held freight, generally land on the shipper or consignor unless a contract shifts them to the manufacturer. That last point is worth negotiating before a shipment, not after. When a battery is not just undocumented but actually damaged or recalled, the stakes climb again, as our guide to shipping damaged and defective lithium batteries explains.
Which shipments need a test summary
The test summary requirement applies to all four lithium battery UN numbers, across every transport mode. That means UN3480 and UN3481 for lithium-ion, and UN3090 and UN3091 for lithium-metal, whether the battery ships alone, packed with equipment, or installed in it. The obligation traces to the same UN standard whether your load moves under the domestic hazardous materials regulations enforced by FMCSA for highway and rail, the IATA Dangerous Goods Regulations for air, or the IMDG Code for ocean. If you move electrified vehicles rather than loose packs, the same documentation logic underpins our guide to hybrid and electric vehicle shipping.
A pre-tender documentation checklist
Before any lithium battery load leaves your dock, confirm the following:
- You hold a current UN 38.3 test summary for every distinct cell and battery model in the shipment.
- All ten required fields are present and complete, with special attention to the Manual edition and the watt-hour or lithium-content data.
- The summary reflects the assembled battery, not only its component cells, where applicable.
- You can produce the document on request, whether or not it physically travels with the load.
- Your contract specifies who bears redelivery and storage cost if documentation fails at tender.
Treat the summary as ship-with paperwork even though the rule only requires it to be "available." Most carriers and forwarders now ask for it at tender, so having it ready keeps freight moving.
The test summary versus the rest of the battery paperwork
The UN 38.3 test summary is one document in a small stack, and mixing them up causes real delays. The Safety Data Sheet (SDS) describes chemical hazards and handling for workplace safety; it is not proof of transport testing and does not replace the summary. The full test report is the detailed engineering record behind the summary, usually held confidentially by the manufacturer or lab. And the shipping papers that travel with a hazmat load carry the UN number, proper shipping name, and emergency response information, a separate requirement from the test summary. A buyer who asks a supplier only for "the battery paperwork" often receives an SDS and assumes the transport question is settled. It is not. Ask specifically for the UN 38.3 test summary, by name, for the exact model you are buying.
Building a supplier documentation file
The cleanest way to avoid a refused load is to collect the documentation at onboarding, not at tender. When you add a new battery or battery-powered product to your catalog, request and file the following from the supplier:
- The UN 38.3 test summary for that specific model, with all ten required fields complete.
- Confirmation of the Manual edition and amendment the testing was performed against, so you can flag it when the standard updates.
- The watt-hour rating or lithium content in writing, which you will need for classification and marking.
- A point of contact who can produce the full test report if a carrier or regulator escalates.
Keep the file current. When a supplier changes a cell source or revises a design, the old summary may no longer describe what you are shipping, and a summary that does not match the product is as good as missing.
Why a test summary gets a load rejected
Even shippers who have a summary on hand get bounced, and the reasons repeat. A summary that references a superseded edition of the UN Manual invites a challenge, because it may not reflect current test criteria. A summary describing a different model or configuration than what is in the box fails on its face. Incomplete watt-hour or lithium-content data leaves a handler unable to confirm classification. And a missing signatory, element ten, undercuts the entire attestation, because no one has certified the results are accurate. When a carrier or forwarder tightens documentation review, these are the fields they check first, so audit them before you tender rather than after a load sits. The cost of a two-minute check is trivial next to demurrage on held freight, a point our overview of hazmat shipping and load rates reinforces.
How expectations differ by transport mode
The legal requirement to make a test summary available is the same across modes, but the practical scrutiny is not. Air is the strictest link in any chain. Air forwarders and carriers routinely demand the test summary before they will accept lithium battery freight, and many will not quote without it, because aviation carries the least tolerance for a battery failure in flight. Ocean and ground carriers are increasingly asking for it at tender as well, driven by their own risk controls. The rule of thumb: if any leg of a shipment touches air, prepare to the air standard for the whole journey, and have the summary ready to send the moment it is requested. Treating documentation as an air-grade requirement across every mode is the simplest way to keep freight moving regardless of how it routes.
Frequently asked questions
What is a UN 38.3 test summary?
It is a standardized document, mandatory since January 1, 2020, that manufacturers and distributors must make available to prove a lithium cell or battery passed the eight UN 38.3 transport safety tests.
Is a test summary the same as a test report or certificate?
No. The summary is a short attestation of results with defined fields, the full test report is a separate and usually confidential document, and there is no government-issued UN 38.3 certificate.
Who is responsible for providing the UN 38.3 test summary?
Both the manufacturer and every subsequent distributor must be able to make it available under 49 CFR 173.185, so a distributor cannot simply defer to the manufacturer.
What happens if the test summary is missing when a battery ships?
The carrier can lawfully refuse the load, and the shipper faces PHMSA civil penalties plus demurrage, storage, and redelivery costs on the held freight.
Which UN numbers require a test summary?
UN3480 and UN3481 for lithium-ion, and UN3090 and UN3091 for lithium-metal, whether shipped alone, packed with, or contained in equipment.
Does the test summary have to travel with the shipment?
It does not have to be physically attached, but it must be producible on request, and most carriers now require it at tender, so treat it as ship-with documentation.
Is a Safety Data Sheet the same as a UN 38.3 test summary?
No. A Safety Data Sheet describes chemical hazards for workplace safety, while the UN 38.3 test summary proves the battery passed the required transport tests, and one cannot substitute for the other.
How long is a UN 38.3 test summary valid?
The summary does not expire on a fixed date, but it must accurately describe the current product and reference the applicable edition of the UN Manual, so a design change or a superseded edition can make an old summary unusable.
Tendering lithium battery freight and unsure your paperwork will clear? Request a compliance review and we will audit your test summaries and classification before a carrier does it for you.
