Your supplier confirmed the order, everything was on track, and suddenly your freight forwarder writes asking for a UN38.3 and a safety data sheet. Two names you had never heard, and a shipment that will not move until you have them.
It is one of the most common situations when importing dangerous goods, and it almost always arrives late — once the cargo is already paid for, or even ready to leave. This guide explains what these two documents are, who issues them, how to request them and why no shipping line or airline will accept your shipment without them.
In this guide
Why you are asked for them
Once goods are classified as dangerous goods, they stop being ordinary cargo and start moving under international rules: IMDG at sea and IATA DGR by air.
Under those rules, every shipment requires prior approval from the shipping line or the airline. This is not a forwarder formality: it is the carrier who decides whether it accepts those goods, on that route, on that vessel or flight. And it decides by reading documents.
The safety data sheet (MSDS/SDS)
The safety data sheet — known as MSDS under its older name, or SDS in current usage — is the document describing a product's composition and the risks involved in handling it.
It follows a standardised international format of 16 sections, defined by the United Nations Globally Harmonized System (GHS). It covers everything from product identification to physical properties, first-aid measures and exposure controls.
For transport, however, one section matters more than all the others:
Who issues it: the manufacturer or supplier of the product. You do not generate it, and your freight forwarder cannot write it either — it has to be requested from whoever sells you the goods.
Which goods it applies to: any chemical product or hazardous substance. Paints, solvents, aerosols, fertilizers, agrochemicals, industrial cleaning products, refrigerants.
UN38.3, for lithium only
Here is a very common misconception: UN38.3 does not apply to all dangerous goods. It applies exclusively to lithium cells and batteries.
Its name comes from section 38.3 of the United Nations Manual of Tests and Criteria. It is a protocol of eight tests a battery must pass before it can be transported:
| Test | What it simulates |
|---|---|
| T1 — Altitude | Low pressure, as in an aircraft hold |
| T2 — Thermal | Extreme heat and cold cycles |
| T3 — Vibration | The continuous movement of transport |
| T4 — Shock | Knocks and impacts during handling |
| T5 — External short circuit | Accidental contact between terminals |
| T6 — Impact and crush | Physical deformation of the cell |
| T7 — Overcharge | Charging beyond the design limit |
| T8 — Forced discharge | Discharge beyond the safe point |
The document you will be asked for is not the full test reports but the test results summary (Test Summary). Since 1 January 2020, manufacturers and distributors of lithium batteries have been required to make it available on request.
Who issues it: the manufacturer of the cell or battery, based on testing carried out by an accredited laboratory.
Which goods it applies to: lithium batteries shipped alone (UN3480), batteries contained in or packed with equipment (UN3481), and anything that carries them inside — laptops, phones, cordless tools, scooters, electric vehicles, power banks.
The two documents, side by side
| Safety data sheet (MSDS/SDS) | UN38.3 | |
|---|---|---|
| What it is | A sheet with the product's composition and risks | A safety test report |
| What it applies to | Chemical products and hazardous substances | Lithium cells and batteries only |
| Who issues it | Manufacturer or supplier | Manufacturer, via an accredited lab |
| What the carrier looks at | Section 14: UN number, class, packing group | That the battery passed the 8 tests |
| If it is missing | The cargo cannot be classified | The battery is not accepted on board |
If you are importing electronic equipment that also contains chemical substances, it is entirely possible that you need both.
How to get them from your supplier
Both come from the same place: your supplier. And they are documents that already exist — a serious manufacturer has them on file and sends them the same day. If it takes weeks or you get vague answers, that tells you something worth noting about that supplier.
Request them before paying, not after. If the supplier cannot provide them, those goods probably will not be able to move, and it is better to know that before the money is transferred.
What else a hazmat shipment needs
Those two documents are the foundation, but not the whole picture. A dangerous goods shipment is built with:
- Shipper's declaration: the formal document declaring the dangerous goods to the carrier. Your freight forwarder prepares it using the data from your safety data sheet.
- UN-approved packaging: any box will not do. Packaging must be certified for your product's class and packing group. More context in correct cargo packaging for transport.
- Marking and labelling: class labels, a visible UN number and handling marks on every package.
- A correct commercial invoice: with the real description of the goods. See what the commercial invoice must include for customs.
The mode of transport also changes the rules: air freight is considerably more restrictive than ocean freight for dangerous goods, especially with lithium batteries. Cargo that travels without trouble in a container may not be accepted on an aircraft.
Mistakes that stop shipments
- Requesting the documents last. The time to ask for them is when quoting with the supplier, not when the cargo is already at the port of origin.
- Accepting an incomplete safety data sheet. If section 14 comes back empty or says "not applicable" for a product that is clearly hazardous, that sheet is no good.
- Assuming it is not hazardous because it is sold everywhere. Perfumes, aerosols, paints, magnets and batteries are bought in any supermarket and are dangerous goods in international transport.
- Declaring goods by their trade name. The carrier needs the proper shipping name and the UN number, not the product brand.
- Assuming that if it travelled once, it always will. Change the route, the shipping line or the airline, and approval is assessed all over again.
Frequently asked questions
What is UN38.3?
It is section 38.3 of the United Nations Manual of Tests and Criteria: a protocol of eight tests that every lithium cell or battery must pass in order to be transported. The document requested in practice is the test results summary (Test Summary), which manufacturers have been required to make available since 1 January 2020.
Does UN38.3 apply to all dangerous goods?
No. It applies only to lithium cells and batteries. For all other dangerous goods — paints, solvents, aerosols, agrochemicals — the key document is the safety data sheet.
What is the difference between MSDS and SDS?
They are the same document. MSDS is the older name and SDS the current one under the Globally Harmonized System. In practice the terms are used interchangeably; what matters is that it comes in the standard 16-section format and that section 14 is complete.
Who issues these documents?
The manufacturer or supplier of the goods, in both cases. Neither the importer nor the freight forwarder can generate them: they have to be requested from whoever sells the product, ideally before paying.
Can I import without these documents?
If your goods are classified as dangerous, no. Without them the carrier has nothing on which to assess the shipment, and without that prior approval the cargo is not accepted on board. It is far better to find this out before buying than with the goods held at the port of origin.
Written by the VS Logistics team.
Not sure whether your goods are hazardous?
Send us your product's safety data sheet — or simply tell us what you want to bring in — and we will confirm whether it is viable on the route you need, before you buy.