This question came to me over a year ago (January 14, 2018).  A time when the Class 9 Lithium Battery label was not yet mandatory but the question of its size was still important.  Since January 1st of 2019, when use of the label became mandatory for regulated shipments of lithium batteries, it is more critical still.

Hello Daniel,

I have a query about Class 9 Lithium Battery Label that what is the Size of the label to be printed?

I found somewhere mentioned 100 mm x 100 mm, is this diagonal or edge dimension? What if the box size is smaller to print this size what is the smaller size can be printed?

The mandatory Class 9 label for regulated packages of lithium batteries after 01.01.19.

Thanks & Regards,

My reply the next day (01.14.18):

I believe I have an answer for your question.  The answer depends upon the mode of transportation and the applicable regulations.  Please see below.

USDOT/PHMSA for the transport of HazMat within the U.S. (usually limited to highway or rail):

• The Hazardous Materials Regulations of USDOT/PHMSA at 49 CFR 172.407(c)(1) require the hazmat label to be at least 100 mm (3.9″) on each side.  There are 4 sides to the label, each side must be a minimum of 100 mm (3.9″).
• However, §172.407(c)(1)(i) allows the dimensions of the label and its features to be reduced proportionally if the size of the package so requires.  Symbol and other elements of the label must remain clearly visible.
• Also, §172.406(b)(1) allows for the display of the label on a “securely affixed tag” or other suitable means if the HazMat is not a Class 7 Radioactive and the dimensions of the package are less than those of the required label.

So, per the USDOT/PHMSA regulations a label may be reduced in size as necessary to fit on the package.  There is no minimum size requirement.  The label can be as small as necessary to fit on the package as long as it continues to communicate the necessary information. Or, as an option, a label may be displayed on a tag secured to the package.

International Maritime Organization (IMO) for the international transport of dangerous goods by vessel:

• The IMO Dangerous Goods Code at 5.2.2.2.1.1 mandates the label to be a minimum of 100 mm on a side.  The image at 5.2.2.2.1.1 clearly indicates the 100 mm minimum applies to each diagonal side of the label.
• 5.2.2.2.1.1.3 allows for a proportional reduction in the size of the labels if the package is too small and if the symbols and other elements of the label remain clearly visible.
• Also, 5.2.2.1.6 allows the label to be displayed on a “securely affixed tag” or other suitable means if the package is too small.

Similar to USDOT/PHMSA, the IMDG Code sets a minimum size for the label on a package.  However, the label may be smaller than this minimum if required by the size of the package.  The shipper also has the option to display the label on a tag or by other means if the size of the package hinders display of a full-size label.

International Air Transport Association (IATA) for the international and domestic transport of dangerous goods by air:

• 7.2.2.3.2(a) of the IATA Dangerous Goods Regulations establishes a minimum dimension of 100 mm for each side of a label.
• 7.2.2.3.1 allows for reduced dimensions of a label’s size (labels may have dimensions that are half of the 100 mm minimum, but no less), but only for the following dangerous goods and only when displayed on a package of an infectious substance that is too small to display the full-size label:
  • Class 2.1 Non-flammable, non-toxic gas
  • Class 6 Infectious substance
  • Class 9 Miscellaneous
• 7.2.6.1(d) allows for the display of the label on a “strong tag(s)” but only when the package is of such an irregular shape that a label cannot be attached or printed on its surface.
• 7.2.6.1(e) requires the shipper to ensure the package is of such a size that there is adequate space to affix all required labels.

It should be no surprise the regulations of IATA are more strict than any other agency.  In brief, the IATA Dangerous Goods Regulations do not allow for the reduction in size of the hazard label except in very limited circumstances, and then, a reduction in size of no more than half of the minimum size.  IATA goes further than either of the other agencies in specifying that the shipper must use a packaging that is big enough for all required labels – and package marks.

I hope this helps.  Please contact me with any other questions.

Conclusion:

That seemed to do it!  If the transport of hazardous materials (aka: dangerous goods) is required for your business, make sure you are doing it in compliance with the applicable regulations.  Though similar in many ways, there are significant differences between the regulations of USDOT/PHMSA, IMO, & IATA, even when dealing with something as insignificant as the display of a hazard label on a package.  Contact me to assist you with compliance.