As a key partner for battery manufacturing and trading enterprises, Guangdong Energy Storage Testing Technology Co., Ltd. hereby reminds relevant enterprises: For batteries certified under UN38.3 (based on the UN Manual of Tests and Criteria), the transport appraisal certificates (required for air and sea shipping) and MSDS (Material Safety Data Sheet) documents will face a critical update deadline at the end of 2025. This update will directly affect the global transport qualification of battery products in 2026.

I. Background of Regulation Updates & Scope of Impact

According to the update cycle of international transport regulations, transport appraisal certificates and MSDS documents based on existing UN38.3 test reports usually have a clear validity period. The current version of these documents will expire on December 31, 2025, which means:

1. Impact on Transport Qualification

• Air Transport Qualification: Transport appraisal certificates required by the International Air Transport Association (IATA) Dangerous Goods Regulations (DGR) must be updated.
• Sea Transport Qualification: Documents required by the International Maritime Organization (IMO) International Maritime Dangerous Goods (IMDG) Code must be updated simultaneously.
• MSDS Reports: Must comply with the latest regulatory requirements for format and content.

2. Specificity of Timelines

This update coincides with multiple critical time points, creating potential scheduling pressures:

• Current documents expire on December 31, 2025.
• New-version documents must be used starting from January 1, 2026.
• The 2026 Spring Festival falls earlier than in previous years, significantly compressing the effective working period.

II. Urgent Alert: Q4 2025 Work Plan

1. Considerations for Laboratory Work Cycles

Based on past experience, major testing institutions will gradually start update work from October 2025. Enterprises should focus on the following:

Impact Analysis of the Spring Festival

The 2026 Spring Festival is in mid-February, but its impact will emerge earlier:

• From late January 2026, laboratory testing capacity will decline significantly.
• Technical personnel’s Spring Festival holiday arrangements will extend work cycles.
• Logistics efficiency will be affected before the holiday.

Estimated Certification Update Cycles

• Transport appraisal certificate update: 1–2 weeks (normal cycle).
• MSDS report update: 1 week (normal cycle).
• Buffer period recommendation: Allow 3–4 weeks to account for time needed to understand and adapt to new regulations.

2. Forecast of Key Document Update Points

Based on recent regulatory trends, this update may involve the following changes:

• Requirements for transport appraisal certificates (e.g., content verification standards).
• Possible adjustments to packaging marking specifications.
• Potential updates to special provisions for transport conditions.
• Possible changes to document format and content requirements.

Guangdong Energy Storage Testing Technology Co., Ltd. reminds enterprises: The 2026 UN38.3 update work is expected to start in October 2025. This will directly affect the air/sea transport qualification of battery products and MSDS report requirements—sufficient advance preparation is essential.

III. Recommended Enterprise Response Strategies

1. Advance Timeline Planning

Enterprises are advised to arrange work according to the following timeline:

• September 2025: Monitor the release of new regulations and track key changes.
• October 2025: Prepare samples and supporting materials (e.g., technical specifications).
• November 2025: Submit certification update applications to testing institutions.
• December 2025: Complete testing and any necessary product modifications.
• January 2026: Obtain new-version certificates and documents.

2. Key Points for Sample Preparation

• Prepare samples from the latest production batch to ensure consistency with mass-produced products.
• Ensure samples fully represent mass-production quality (avoid using "special" samples).
• Prepare backup samples to address potential retesting needs.

3. Document Preparation Work

• Update product technical specifications to align with new regulatory requirements.
• Prepare data required for the new-version MSDS (e.g., updated hazard classification).
• Organize complete quality management system documents to support certification review.

IV. Risk Alert & Mitigation Measures

1. Main Risk Points

• Tight scheduling at laboratories during the certification peak season (Q4 2025).
• Test failures caused by misunderstandings of new standards.
• Logistics delays before/after the Spring Festival affecting progress.
• Extended certification cycles due to incomplete document preparation.

2. Mitigation Solutions

• Prioritize cooperation with qualified and authoritative testing institutions (e.g., those with CNAS/CMA accreditation for UN38.3).
• Conduct pre-evaluation testing in advance to identify and resolve issues early.
• Establish a backup laboratory plan to avoid delays from a single institution’s capacity constraints.
• Reserve sufficient buffer time (add 1–2 weeks to the normal cycle) to account for uncertainties.

V. Professional Support from Guangdong Energy Storage Testing

To help enterprises smoothly transition to the new standards, Guangdong Energy Storage Testing Technology Co., Ltd. provides the following services:

1. Professional Consulting Services

• Interpretation of new regulations and analysis of differences from old standards.
• Pre-review of technical documents to ensure compliance with new requirements.
• One-on-one expert guidance tailored to enterprise-specific products (e.g., lithium-ion vs. sodium-ion batteries).

2. End-to-End Certification Services

• Sample pre-testing to verify compliance with new UN38.3 transport requirements.
• Assistance with formal certification applications (document collation, submission coordination).
• Emergency expedited channels for enterprises facing tight deadlines.

3. Post-Certification Support & Guarantee

• Certificate maintenance services (e.g., updates for minor product modifications).
• Reminders for future standard updates to avoid missing deadlines.
• Technical training support (e.g., workshops on new MSDS preparation standards).

VI. Reminder from Guangdong Energy Storage Testing

The 2026 UN38.3 update is a critical milestone for traders, battery manufacturers, and battery-related industries. Faced with tight timelines and heavy tasks, advance planning is key to ensuring a smooth transition. Guangdong Energy Storage Testing Technology Co., Ltd. recommends that enterprises immediately launch preparation work, establish detailed timelines, and select suitable partners to jointly address the challenges and opportunities brought by this regulatory update.