Packed master cartons staged on a pallet for the customer's freight forwarder

Battery paperwork and customs: why “empty” hardware still needs UN38.3 and an SDS

“Empty” describes the oil, not the device. Every rechargeable device still contains a lithium cell, and a lithium cell is what customs and carriers ask about. So here is exactly what we do provide, and what we do not.

What travels with the shipment

Battery shipments travel with UN38.3 test reports and an MSDS/SDS for the cell actually used. The report belongs to the cell, not to a generic “battery” claim, which is why we say “the cell actually used” deliberately.

Issued against your configuration

Battery paperwork is issued against the exact device and cell combination in your order. Different devices and different cells mean different paperwork; we do not send a single generic file and hope it matches. How the device itself is classified is a separate question, covered in our guide to customs classification for empty vape hardware.

The licence, and who holds it

The factories that build for us include the holder of a China Tobacco Monopoly Production Enterprise Licence (export scope), which formal export declaration requires. Pulse does not hold a licence in its own company name; production is licensed at our partner factories. When you need a copy for your file, we provide the copy the licence holder releases.

What we do not claim

We do not claim any specific lithium battery packing instruction for air transport; the documentation we hold does not support such a statement. We also do not file customs declarations in our own name — formal export declaration requires the licence the producing party holds.

The certificates that sit with the factory

Quality-management, cleanroom and material documentation — ISO 9001, ISO 13485 / GMP, RoHS / CE / FDA food-grade, heavy-metal screening — sits with the individual factories that hold it, and we pass on the copies they release for your file. In practice, day-to-day buyers ask for the licence copy and the battery transport documents, because those are what clearance needs. That paperwork is only one piece of the entry file; our guide to importing empty vape hardware into the US covers the rest.

Sealed master cartons in the packing area of our manufacturing partner's Shenzhen production facility

Third-party inspection

We welcome third-party pre-shipment inspection (SGS, QIMA, V-Trust) and will provide the China Tobacco Monopoly Production Enterprise Licence and the battery transport documents for your verification on request.

Finding out what applies to your configuration

When you send your device and cell configuration through /get-a-quote/, tell us which device and which cell you need, and we will list the documents that travel with that combination.