Huizhou batteries: which cell lot faces this module pallet, who owns UN38.3

A Dutch buyer sent a module-pallet photo back to a Huicheng assembly door. The pallet side showed a module type; the cell-bag lot was inked over. WhatsApp, verbatim: “UN38.3 cover shows a CELL plant. This pallet is MODULES. Who owns THIS test summary? Which cell lot faces THIS pallet — not Zhongkai gate. Do not send a park brochure. HK invoice OK.” Sales returned a Zhongkai aerial, a Hong Kong company PI, and a test-summary scan that copied the cell plant into the module manufacturer box. The buyer asked again: the cover is a cell plant, the cargo is an assembler — which paper faces this pallet? Sales typed “Huizhou new-energy battery” into the dangerous-goods booking remark.

The cell plant said the can supplier changed this week and the old report could take a new capacity title. Assembly said a module only parallels cells and needs no new test. The forwarder said the airline only wants the four characters “lithium UN38.3.” Finance wanted a “cluster certification fee” inside the unit price as if a city levied it. Membership wired to ALIBABA.COM HONG KONG LIMITED does not buy a test-summary holder, and it does not buy proof that this cell lot already entered this pallet.

Split who does what. The local cell plant owns the design type and this cell lot and writes the lot on the outgoing paper. The local assembler owns the module design type and this pallet and cannot retitle a cell cover. The testing lab owns that submitted-sample run, not the lot you swapped later. The export seller, including a Hong Kong company, owns the invoice and booking pack and does not become the report manufacturer by invoicing. The importer owns destination acceptance and local DG rules and cannot use a Huizhou industry name in place of receiving checks. Corpable Marketing Limited is a Hong Kong Alibaba.com service provider, not a regulator, and does not hold reports. How Shenzhen quotes counter goods is on the Shenzhen white paper — a counter photo will not fill a cell-lot box. How Dongguan quotes OEM towns is on the Dongguan white paper — a town name will not fill a test-summary cover. How Cixi reads a SKU line board is on the Cixi white paper — a line number will not fill a module pallet. Origin is on China goods are not Hong Kong origin. Read an ownership chain below, not a counter, and not a line board.

Which cell lot faces this module pallet — not a park short name

Hong Kong-channel sellers quoting cells, modules, or packs in Huizhou get asked first which cell lot sits in this pallet. The cell lot writes on the cell outgoing paper and the module incoming row. It faces this pallet, not the two characters “Zhongkai.” Copying a neighbour pallet’s lot onto this outgoing paper to make the count will make opening day ask which bag counts.

The municipal work report writes new-energy batteries as a strength — see the 2026 work report. The industry name sits in the background. The name does not prove this cell lot entered this pallet. Do not stamp “new-energy batteries already listed” on the pallet side.

The industry-and-IT plan names new-energy batteries — see the openHarmony action plan. A plan is policy text. Policy text is not this pallet’s incoming row. Finance must not write an “action-plan certification fee” into the unit price. There is no site-wide official Huizhou battery levy, and do not invent an official cell price.

If cells sit in Daya Bay and assembly sits in Huicheng, write both rows. The itinerary writes both licence full names and door plates, not “one Huizhou house.” Two characters will not open two gates. Each gate checks its own incoming paper.

Do not pour leftover cells from a neighbour pallet into this bag to make the count. The neighbour may be another capacity. Treat a pour as a mixed lot and do not close this pallet. A mixed lot must not keep this pallet’s cell-lot number.

If a cell bag tears and the lot sticker is solvent-wiped, treat it as unclear origin. A reprint must face the original outgoing paper. Do not fill “the usual lot” from memory. Memory will not face a lab submission record.

A Hong Kong company as contract seller does not become the cell-lot holder. Titles sit on document titles. Split the seller box from the cell-lot box. If the inquiry only says “Huizhou battery,” ask first whether they want cells, modules, or both legs. Quoting “one pallet price” before that ask will start a number fight on opening day.

Count incoming by cell-lot rows, not “a batch of cells.” Two characters will not face opening day. One lot, one row, with piece count and capacity name. If the count misses the outgoing paper, assembly stops first.

If the buyer wants inbound cell photos, the lens faces the outgoing lot, the same string on the bag, and this pallet’s module work-order number beside it. Do not shoot the park gate. A gate does not prove this bag.

The cell store issues by pallet number, not “how many pallets we assemble today.” Issuing by headcount will send bags to the wrong pallet. The issue slip copies this incoming row.

If the protection board is another house, add a row. Writing “electronics count as the cell” so the board can merge into the cell lot will make opening day ask about the board. A merge is two number sets. An empty board row means this pallet does not close.

Incoming cells: pull one for voltage or resistance. If it misses the spec, isolate the bag. The isolation ticket writes the measured value and the incoming-row spec. Do not write “feels the same.” Two characters will not face opening day.

Night shift changing capacity: clear the old tote until you see the floor. If it will not clear, treat the tote as mixed capacity. Mixed capacity must not keep the last cell lot.

If the cell plant changes the can on night shift, the outgoing paper opens another lot. Writing “only the can changed” so the old lot can stay will empty the outline on the test summary. A can change is another lot.

The module work order signs the cell lot and the pallet number, not a park short name. If it is unsigned, treat this pallet as incomplete and do not go to a transport identification.

Zhongkai High-tech Zone guards check the licence on this pallet’s incoming paper, not the five characters “new-energy battery.” Five characters will not open the gate. The itinerary writes the licence full name and the seat.

If the destination is short one bag, face the incoming-row count and the bill of lading first. Do not change the cell lot to “make up a bag.” A make-up bag opens another pallet number and re-staples the cell lot. Mixing it into the original pallet as the original lot will make the buyer ask about two bags.

If the outgoing paper gives a storage-temperature band, inbound writes the measured value. Do not write “room temperature.” Two characters will not fill a storage row. If you cannot lock a band, this bag does not go on the line.

If the RFQ writes capacity as “around,” reply that this pallet only recognises the outgoing paper and the module work-order band. “Around” will not fill a cell-lot row. Quote the band you can lock. If you cannot lock it, do not write “approximately” on the PI.

If the buyer sends Shenzhen counter goods as a sample, park the sample. Do not strip the bag into a Huizhou module. The counter is another city’s path. A Huizhou module still faces a Huizhou cell lot and this pallet’s work order.

Does the UN38.3 cover name the cell plant or the assembler

UN38.3 is subsection 38.3 of the UN Manual of Tests and Criteria, Part III, for lithium cells and batteries. IATA’s batteries page writes the tests and the test summary into air-transport preparation — see IATA Batteries. That page is industry guidance. It is not proof that this Zhongkai pallet already passed, and it is not an administrative order naming who must sit on the cover.

The manufacturer box on the cover names the party that submitted and declared the design type. A cell type faces the cell plant. If the module is a new series-parallel or can, the assembler is another design type and submits separately. Retitling a cell cover as a module will make the forwarder ask whether the sample was a cell or a module.

CNCA Announcement No. 9 of 2023 designates CCC laboratories for lithium-ion batteries and power banks — see CNCA 2023 No. 9. The designation proves CCC laboratory status. It does not prove CNCA issues UN38.3, and it does not prove a listed lab automatically holds this pallet. CCC and transport tests are two paths. Do not merge them into one “official lithium certificate.”

The lab owns that submitted-sample run. Report number, type, capacity, and outline sit on the cover and the test summary. A later cell-lot, board, or can swap is first another type. Do not correct-fluid the cover. A correction is a number that was changed.

The test summary is made available by the manufacturer and subsequent distributors under the Manual. A Hong Kong company as distributor may forward the summary. It cannot rewrite itself as manufacturer. The manufacturer on the forwarded copy remains the plant name. The seller box sits on document titles.

If the buyer wants the test summary, first face the cover type against this pallet’s module work-order type. If they miss, this pallet does not book. Writing “all 18650” so one paper can be shared will make the airline ask for the type string.

The importer receiving at destination may ask to see the test summary. That is a receiving check, not a Huizhou industry-and-IT stand-in. The export seller prepares the booking pack and cannot treat the lab as its own plant. The local plant prepares the submission and cannot write the forwarder’s mailbox as manufacturer.

If the lab or the carrier writes a validity condition, read the written condition. This page invents no month count and no official retest price. If you cannot lock a condition, the booking remark writes “pending written confirmation,” not “valid forever.”

Submitted samples must be retained from this design type. A neighbour type that looks the same must not stand in. A stand-in is unclear origin. That report cannot staple onto this pallet.

If one PI holds a cell pallet and a module pallet, split two rows, each with its own cover. Merging “assorted Huizhou lithium” will make the forwarder ask which report was booked. A row without a type should not print a park short name on the booking first.

Treat a peddler selling a CCC lab name as “official UN38.3 authorisation” as unclear source. The CNCA notice only designates CCC laboratories. Transport tests are done by a competent lab to the Manual. CNCA does not sell a holder certificate.

A CE mark does not buy a transport test — see CE is not a bought certificate. If RoHS or energy labelling is another path, open another clip. Do not staple them onto a UN38.3 cover.

Air and sea may still want a transport-condition identification. The type on that paper still equals the cover type. An identification is not a substitute for the test summary. Whichever paper is missing, the forwarder stops on that paper. Do not paste “lithium file complete” over the gap.

Do not print a Hong Kong company in the manufacturer box, and do not print Made in Hong Kong. Origin follows the cell or module working place — see China goods are not Hong Kong origin.

If the buyer names a lab, write it onto this pallet. Spoken “same house as last time” does not lock. A lab change archives the old report and opens a new one. The cover still writes the plant, not the forwarder.

If a scan is too low to read the type, treat it as not provided. A rescan faces the original cover. Do not crop a web image. Two characters will not staple onto a booking.

Corpable can sit with you on whether the cover manufacturer, the type, and this pallet’s work order are the same string. We do not submit, we do not sign, and we do not guarantee airline or steamship acceptance. As of 2026-10-07, this page is not legal advice.

Who issues the MSDS, and does it face this cell lot or this module pallet

An MSDS / SDS is a safety data sheet. GHS sections write hazards, transport, and disposal. The party responsible for the substance or mixture issues the SDS. Cells have a cell SDS. Modules have a module SDS. Do not retitle a sixteen-section cell sheet onto a module pallet.

Which lot the SDS faces writes in section 1 and on this pallet’s incoming row. Writing only “lithium-ion battery” will make the forwarder ask cell or module, and which lot. An empty lot means the SDS does not travel with the pallet.

Who issues. The cell plant issues for cells it ships. The assembler issues for modules it ships. A trading house that only forwards still attributes the original supplier. A Hong Kong company may attach a forwarded copy. It cannot write itself as manufacturer and then fill a blank template.

The importer at destination may be asked for an SDS. That is a receiving check, not a Huizhou industry-and-IT issuance. The export seller stapling an SDS into the booking pack does not become a chemical-registration holder. Labs generally issue test reports, not an SDS in place of the plant.

UN number and proper shipping name on the SDS must match the booking. Cells write the applicable UN number. Modules write the applicable UN number. Writing “all Class 9” so numbers can be shared will make the forwarder ask the packing instruction. This page does not invent which packing instruction applies. If you cannot lock it, stop.

If the SDS date is old, ask the supplier whether it still applies. This page invents no official year-cycle or penalty. If the supplier writes that it still applies, staple the writing onto this pallet. If it does not apply, pull the old SDS.

Language follows the carrier and the destination. Chinese only, airline wants English: add the English file first. Do not machine-translate sixteen sections and sign a Hong Kong company. A machine file that misses the original supplier is treated as not provided.

If a hazard label belongs on the pack, the signal word matches the SDS. Do not borrow a neighbour pallet’s label. A borrow is two sets of statements. Do not print “Huizhou cluster certified” on the label.

Finance must not write an “official SDS registration fee” into the unit price. An SDS is a supplier file. There is no site-wide official Huizhou SDS levy. Membership still goes to ALIBABA.COM HONG KONG LIMITED. Dues do not buy an SDS.

The buyer’s WhatsApp followed: “SDS section 1 must show THIS lot. Cell SDS on a module pallet will be bounced.” Reply that this pallet’s module SDS section 1 copies the module work-order number and the cell-lot row. Do not copy a park brochure.

If SDS section 14 conflicts with the test-summary type, stop first. A conflict is papers that do not face. Do not edit the SDS to “round it.” An edit is a number that was changed.

In the same clip, spread the SDS, the test summary, and the cell outgoing paper and face the type. If they face, staple them into the booking pack. If they miss, replace the missing paper. Do not invent a “Huizhou lithium master sheet” that copies three numbers into one string.

How export documents split rows sits on the export documents checklist. Port and bill of lading do not write into the cell-lot box. FOB Yantian, CIF Rotterdam, EXW Huicheng warehouse: the delivery point writes on the contract, not on the test-summary cover.

If the assembler will not issue a module SDS and only hands over the cell-plant SDS, treat this pallet as missing a module statement. A missing statement does not go to the carrier. Writing “the cell statement is enough” so the cargo can move will make opening day or a rejection ask about the module.

This page writes the SDS as a supplier duty, not a CNCA certificate. The CNCA notice does not govern SDS sections. The industry-and-IT action plan does not issue an SDS.

The assembler swapped the cell lot — does the old UN38.3 still follow

If only the cell lot changed and the module design type did not, first face the cell description on the test summary against the new outgoing paper. If the description faces and capacity, can, and board did not change, the old report may stay in the clip and the cell-lot row reopens. The new row writes the new lot and voids the old lot. A void slip staples into the clip. Do not correct-fluid the old row.

If capacity, can, protection board, or series-parallel changed, treat the old report as not covering. Writing “still lithium” as a retitle will make the carrier ask whether the sample is this pallet. If you cannot lock coverage, submit again or do not quote this pallet for air.

Who decides whether it follows. The lab is not on the floor watching you swap lots and cannot say “it follows” by voice. The assembler owns its design type and must judge in writing whether a key-part swap is still the original design type. The export seller cannot judge for the plant. The importer may ask to see the written judgement and cannot use an industry name in its place.

After a swap, SDS section 1 follows the new lot. Pull the old SDS. If it will not pull, opening day asks which paper counts. If the test summary still applies, the cover type stays and the clip adds a swap note. The note writes the pallet number and the new cell lot, not “Huizhou generic lithium.”

Reworked modules carry a rework mark. Do not pass them off as first-issue cargo. The mark sits beside the pallet number. Mixing them into a first-issue carton will make the buyer ask about two cell lots.

Warranty cell replacements on the move: the waybill writes the pallet number and the new cell lot. Do not write only “one bag of parts.” Two characters will not face which pallet.

If the carrier wants the transport identification reopened after a swap, follow the carrier’s writing. This page invents no identification fee. If you cannot lock the written ask, the booking remark writes pending confirmation.

Old cells go into hold with a hold ticket that writes the old lot and the pallet number. Do not pour old cells into a neighbour pallet to make weight. Making weight is a mis-ship.

If night shift loads a new lot into a tote still hanging an old report photocopy, treat it as papers that do not face. The tote hangs the pallet number and the new cell lot, not “lithium.” Two characters will not split two lots.

If the buyer wants replacement cells and not a whole module pallet, pack from the cell outgoing row. Do not stuff a neighbour module can to make volume. Making volume is a mis-ship.

Swap records face the pallet number, not the carton number. If the carton number changes, the record still recognises the pallet. A record without a pallet number is treated as not swapped. This pallet does not leave.

The type on the instruction sheet must equal the type on the module. If the sheet is still the old capacity and the cargo is the new capacity, treat this pallet as papers that do not face. Reprint the sheet the same day the new cell lot is complete.

If a Dongguan seat only makes the protection board, the board’s incoming paper opens separately. Do not write a Dongguan town onto a Huizhou test-summary cover. A town name is another city’s path.

A Cixi SKU line number from that page will not fill a swap note. A line number is a small-appliance path. A Huizhou swap note only writes the cell lot and the pallet number.

Where an air or sea booking stops when a number does not face

A booking stops on numbers: cell lot misses the module work order, stop; test-summary type misses the module, stop; SDS section 1 misses this pallet, stop; transport-identification type misses the cover, stop. What stops is this pallet, not the four characters “Huizhou lithium.” Four characters will not book space.

Who signs at the stop. The forwarder stops on the carrier’s missing-paper list. The export seller stops on missing attachments it prepared. The local plant stops on a missing outgoing paper. The importer is not at the load port and cannot lift a stop with “ship first.” Corpable does not sign a booking.

IATA’s batteries page lists air preparation and guidance — see IATA Batteries. That page does not replace this pallet’s face-check and does not order which paper a Huizhou door must paste. Sea follows sea DG rules. Do not copy an air page onto a sea booking as already passed.

The carton mark prints type and pallet count. An in-carton facing slip prints pallet number, cell lot, test-summary number, SDS date, and the assembler’s licence short name. The slip copies the outgoing paper and the cover. Do not hand-write “Huizhou generic lithium.”

If the slip falls off, this carton does not hand over. A replacement still copies the original. Do not fill a report number from memory. Memory will not face the lab on opening day.

Yantian or Shekou only writes as load port. The port does not write into the cell-lot box or the test-summary manufacturer box. How documents split sits on the export checklist. This page only keeps the ownership chain.

If the buyer photographs a blurred lot at destination, first face the outgoing photo and the incoming row. Do not change the number to “round it.” If the photo faces the outgoing day, treat it as transit wear. If it does not, treat it as the wrong lot and recall this pallet. The recall writes pallet number and cell lot, not “those Huizhou pallets.”

Two types in one container: a divider, with pallet numbers on the divider. A fallen divider is a mixed carton and does not hand over. Re-sort by the number on the module and the clip, not by memory that “the left side is storage.”

If the carrier writes a state-of-charge cap, read the writing. This page invents no official percentage. If you cannot lock a cap, do not tick “already complies” on the booking. Spoken “about right” is not enough.

Broken pack or swollen cell: isolate the piece. The isolation ticket writes pallet number and what you see. Do not write “still usable.” Three words will not staple onto a carrier list.

When commercial-invoice fields face 141.86, the description must still let a reader see cell or module. “Huizhou electronics” will not fill a DG proper shipping name.

If the RFQ writes “air or sea,” reply that this pallet only recognises one mode’s complete file. “Or” will not lock an identification. Quote the mode you can lock.

Sales must not quote finance “one pallet price” that pastes cell, assembly, and testing into one lump. Write cell, assembly, and testing as separate rows. A Hong Kong company may issue one invoice. The attachment still follows three rows.

If Daya Bay is only cells on this booking and Huicheng is only assembly, write two seats on the itinerary. The municipal work report writes the industry city-wide. That is city-wide narrative, not a merger on this booking.

Do not mix Huaqiangbei samples into a module carton to make volume. A mix is a mis-ship. Counter goods have their own path and will not copy over.

Count booking-pack pages. One page short, this pallet stops. The handover signs a page count, not “the file is here.” One character will not count pages.

If the buyer wants to see the cell plant and the assembler once each, the itinerary writes two seats, two door plates, and two incoming papers, not “any Huizhou look.” “Any” will not bring back an ownership chain.

As of 2026-10-07, the municipal, industry-and-IT, CNCA, and IATA pages that opened are used only to say what an industry name, a laboratory designation, and air guidance each prove — and what they do not prove. A page revision follows the text that day. This page is not legal or tax advice and is not a guarantee to any airline, steamship, or customs office.

Who: cell plant, assembler, lab, export seller, and importer each own their number. How: staple the cell lot onto the pallet, staple the cover onto the type, staple the SDS onto section 1, and stop the booking if they miss. Why: the carrier recognises this pallet’s numbers, not a park short name. Corpable Marketing Limited can face numbers with you. We do not hold UN38.3, we do not issue an MSDS, and we do not guarantee entry. Membership still goes to ALIBABA.COM HONG KONG LIMITED.

Questions teams actually ask

Related reading

• Hong Kong entity document titles
• China goods are not Hong Kong origin
• Shenzhen: Huaqiangbei is not the plant
• Dongguan: OEM is another set
• Contact Corpable · info@aliad.hk

Written by Corpable Marketing Limited for Alibaba.com Hong Kong-channel sellers. Not legal, tax, or audit advice. Platform, customs, bank, and auditor outcomes follow the latest official notices. Membership fees go to ALIBABA.COM HONG KONG LIMITED. Corpable does not collect them.