Introduction: Why is Air Transport of Batteries the Most Stringently Regulated Logistics Sector in the World?
High-Risk Warning: The Catastrophic Consequences of In-Flight Thermal Runaway from Historical Air Crash Accidents (e.g., the 2010 UPS Cargo Plane Accident)
The high risks associated with air transport of batteries have long been highlighted by historical accidents. In 2010, a UPS cargo plane crashed over Dubai due to a lithium – battery fire, resulting in the tragic loss of lives on board. In recent years, similar lithium – battery safety incidents still occur from time to time. On October 18, 2025, during the flight of Air China’s CA139, a lithium battery in a passenger’s hand luggage stored in the overhead compartment caught fire. The crew followed the procedures to handle the situation immediately, and the plane made an emergency landing at Shanghai Pudong Airport. Fortunately, no one was injured. According to data released by the U.S. Federal Aviation Administration (FAA), since 2015, the number of fires caused by lithium batteries in air transport has increased by 388%, and 32 serious accidents were recorded in 2024. These data fully demonstrate the huge safety hazards that lithium batteries pose in air transport. Once thermal runaway occurs, the consequences can be disastrous, and great attention must be paid to the safety of their transport.
Regulatory Specificity: The Extreme Challenges of the Closed Environment, Pressure, and Temperature Changes in Air Transport on Battery Safety
The air transport environment has its own characteristics, which pose extremely high requirements for battery safety. The aircraft cabin is a relatively closed space. In the event of a battery fire, smoke and toxic gases are difficult to disperse quickly. The fire spreads rapidly, and it is very difficult to extinguish. At the same time, the pressure changes (such as the low – pressure environment at high altitudes) and temperature fluctuations (extreme high or low temperatures) during flight may affect the performance and stability of lithium batteries. In addition, the vibration and impact during take – off, landing, and flight may also affect the structural integrity of the batteries. These factors make the regulation of air transport of batteries more stringent than other modes of transport.
The Goal of This Article: To Provide a Panoramic and Practical Export Transport Roadmap from the Factory to the End for Exporters, Freight Forwarders, and Airline Operators
This article aims to provide exporters, freight forwarders, and airline operators with a comprehensive and detailed compliance guide on the air transport of batteries. By in – depth interpretation of the relevant regulations and requirements of the IATA Dangerous Goods Regulations (DGR), combined with practical operation cases, this article provides readers with a clear and operable compliance roadmap to help enterprises reduce compliance risks, improve transport efficiency, and ensure the safety, compliance, and smooth progress of air transport of batteries.
Understanding the Highest Standard: IATA DGR and the Regulatory Framework for Lithium – Battery Transport
What is IATA DGR: The Authority and Mandatory Compliance of the IATA Dangerous Goods Regulations by Global Airlines
The IATA Dangerous Goods Regulations (DGR) is a core standard for global air transport of dangerous goods formulated by the International Air Transport Association. It has high authority and mandatory compliance. All airlines, freight forwarders, and exporters involved in international air transport must comply with the relevant provisions of the IATA DGR, otherwise they will face severe penalties.
Regulatory Update Rhythm: Emphasizing the Annual Update Mechanism of IATA DGR (e.g., Changes in the Latest 2025 Version) and the Decisive Impact of Timeliness on Operations
The IATA DGR is updated every year to adapt to the ever – changing air transport safety requirements. In 2025, IATA released the 66th edition of the DGR, which comprehensively and meticulously updated the relevant provisions on lithium – battery transport. The main changes include the addition of UN numbers and packing instructions, power limitations and packaging requirements, label and marking changes, etc. These updates have a decisive impact on the operation of air transport of batteries. Practitioners must keep abreast of the latest regulatory requirements to ensure compliance with transport regulations.
Coordination with Other Regulations: Clarifying the Relationship between IATA DGR and the UN Recommendations on the Transport of Dangerous Goods, and the Regulations of Civil Aviation Authorities of Various Countries (e.g., CAAC, FAA)
The IATA DGR is closely related to the UN Recommendations on the Transport of Dangerous Goods and the regulations of civil aviation authorities of various countries (such as the Civil Aviation Administration of China (CAAC) and the U.S. Federal Aviation Administration (FAA)). The UN Recommendations on the Transport of Dangerous Goods provide a unified framework and standard for the global transport of dangerous goods, and the IATA DGR refers to the relevant content of this recommendation in its formulation. Civil aviation authorities of various countries, based on their actual national conditions, have refined and supplemented the relevant provisions of the IATA DGR and formulated their own national regulations on air transport of dangerous goods. For example, the Civil Aviation Administration of China has formulated the “Specifications for Air Transport of Lithium Batteries”, which makes specific provisions on the air transport of lithium batteries. Practitioners must comply not only with the relevant provisions of the IATA DGR but also with the regulatory requirements of civil aviation authorities of various countries when transporting batteries by air.
The Core First Step in Compliance with Air Transport of Batteries: Precise Classification and Identification
Two Basic Categories and UN Numbering System
Lithium – ion Batteries (Rechargeable): UN 3480 (Transported Alone), UN 3481 (Packaged with Equipment), PI 965 – 968
Lithium – ion batteries are rechargeable batteries widely used in mobile phones, laptops, electric vehicles, and other fields. According to the provisions of the IATA DGR, when lithium – ion batteries are transported alone, their UN number is UN 3480. When they are packaged with equipment or installed in equipment for transport, their UN number is UN 3481. The corresponding packing instructions are PI 965 – 968.
Lithium – metal Batteries (Non – rechargeable): UN 3090 (Transported Alone), UN 3091 (Packaged with Equipment), PI 968 – 970
Lithium – metal batteries are non – rechargeable batteries, usually used in button batteries, drone batteries, and other fields. When lithium – metal batteries are transported alone, their UN number is UN 3090. When they are packaged with equipment or installed in equipment for transport, their UN number is UN 3091. The corresponding packing instructions are PI 968 – 970.
Key State Determination Criteria
Prohibited Air Transport: Damaged, Recalled Batteries; Lithium – metal Batteries Transported Alone (Except for Specific Exemptions)
Damaged, swollen, leaking, or recalled batteries are prohibited from air transport because they pose serious safety hazards. In addition, lithium – metal batteries transported alone are also prohibited from air transport in most cases, unless they meet specific exemption conditions, such as lithium content and packaging requirements.
Strictly Restricted Transport: Low – power, Small – sized Batteries that Meet the Provisions of Section II (Subject to Relatively Lenient Provisions)
For low – power, small – sized batteries that meet the provisions of Section II, such as lithium – ion batteries with a single – cell energy not exceeding 20Wh and a total package energy not exceeding 100Wh, they can be transported in accordance with relatively lenient transport provisions. For example, they do not need to use UN – specification packaging, but they still need to comply with basic requirements such as anti – short – circuit and independent packaging.
General Dangerous Goods Transport: The Majority of Lithium Batteries that Meet All Standards (Subject to the Full Set of Dangerous Goods Procedures)
The majority of lithium batteries that meet all standards need to be transported as general dangerous goods, subject to the full set of dangerous goods procedures. This includes providing UN38.3 test reports, MSDS (Material Safety Data Sheets), dangerous goods declaration forms, using standardized packaging, and posting corresponding dangerous goods labels.
The Definition of “Equipment”: The Key Differences and Operational Convenience between Batteries Installed in Equipment and Batteries Packaged with Equipment
The definition of “equipment” is of great significance in the air transport of batteries. The transport requirements for batteries installed in equipment are different from those for batteries packaged with equipment. When batteries are installed in equipment for transport, the equipment needs to be fixed to prevent movement in the package, and the packaging method should prevent accidental activation during transport. When batteries are packaged with equipment for transport, it is necessary to ensure that there is sufficient insulation and isolation between the batteries and the equipment to prevent short – circuit and collision.
Operational Guidelines under the Latest IATA Regulations (Core Chapters)
Packaging Compliance: More Than Just the Outer Box
Must Use UN – specification Packaging: Pass the 1.2 – meter Drop Test and Mark the UN Code
Air transport of batteries must use UN – specification packaging. The packaging materials must pass the 1.2 – meter drop test to ensure that the packaging can withstand a certain degree of impact and vibration during transport. The packaging must be marked with the correct UN code for easy identification and management.
Absolute Requirements for Anti – short – circuit: Independent Insulation of Each Battery/Cell (e.g., Original Packaging, Plastic Bags) and Electrode Protection
Anti – short – circuit is one of the key requirements for air transport of batteries. Each battery/cell must be independently insulated, which can be achieved by using original packaging, plastic bags, or other materials for insulation. At the same time, the electrodes must be protected to prevent short – circuit between the electrodes.
Fire – resistant and External Short – circuit – proof Packaging: Enhanced Requirements for the Fire – resistant and Insulation Properties of Packaging Materials in the Latest Regulations
The latest regulations have put forward higher requirements for the fire – resistant and insulation properties of packaging materials. The packaging materials must have good fire – resistant properties to prevent the spread of fire to a certain extent. At the same time, the insulation properties of the packaging materials must also be guaranteed to prevent external short – circuit.
Marking and Labeling
Lithium – battery Marking: Must Include a Phone Number. Detailed Requirements for Marking Size and Content in the New Version
The lithium – battery marking must include a phone number so that relevant personnel can be contacted in case of an emergency. The new version of the regulations has detailed requirements for the size and content of the marking. The marking must be clear and eye – catching and can be clearly identified in various environments.
Dangerous Goods Label: Correctly Paste the Class 9 Label and Keep It Away from Other Markings
The dangerous goods label must be correctly pasted on the packaging and should be kept away from other markings to ensure the readability and identification of the label. The Class 9 dangerous goods label is a diamond – shaped sign with a white background, a black border, and a number “9” in the middle.
“Cargo Aircraft Only” Label: When Must It Be Used?
When the transport of lithium batteries poses a relatively high safety risk, the “Cargo Aircraft Only” label must be used. For example, lithium – ion batteries with an energy exceeding 100Wh must use the “Cargo Aircraft Only” label to ensure that the lithium batteries are only transported on cargo planes to reduce safety risks.
Document Preparation: The “Passport” for Air Transport
Core Document: Shipper’s Declaration for Dangerous Goods
The Shipper’s Declaration for Dangerous Goods is one of the core documents for air transport of batteries, used to declare the dangerous nature and transport requirements of lithium batteries to airlines and customs. The declaration form must accurately fill in the UN number, proper shipping name, packaging quantity, and other information of the lithium batteries to ensure that the declared information is consistent with the actual goods.
How to Fill It Out Correctly: From UN Number, Proper Shipping Name to Packaging Quantity
When filling out the Shipper’s Declaration for Dangerous Goods, the following points should be noted:
- Accurately fill in the UN number: The UN number is the unique identifier of the lithium battery, and it must be filled in accurately.
- Correctly fill in the proper shipping name: The proper shipping name must be consistent with the actual goods, and abbreviations or acronyms should not be used.
- Fill in the packaging quantity: The packaging quantity must be filled in accurately, including the number of batteries in each package and the total number of packages.
Dual Requirements: Best Practices for Separating Operational Information and Dangerous Goods Information
To ensure the accuracy and readability of the declared information, operational information and dangerous goods information should be filled out separately. Operational information includes transport mode, transport route, transport date, etc., while dangerous goods information includes UN number, proper shipping name, dangerous goods category, etc.
Required Supporting Documents
UN38.3 Test Summary: Must Be in the Latest Format Requirements
The UN38.3 test summary must be in the latest format requirements to ensure the validity and credibility of the test results. The UN38.3 test is a series of safety tests for lithium batteries specified in the UN Recommendations on the Transport of Dangerous Goods, designed to ensure the safety of lithium batteries during transport.
MSDS (Material Safety Data Sheet)
The MSDS is a document that provides detailed information on the physical and chemical properties, hazards, safe operation methods, emergency measures, etc. of lithium batteries. It is a necessary document for air transport, customs clearance, and warehousing transport to ensure that cargo handlers understand the hazards, emergency measures, and safe operation methods.
Responsibilities of Freight Forwarders and Carriers for Document Review
Freight forwarders and carriers have important responsibilities for document review. Freight forwarders need to review the documents provided by shippers to ensure the authenticity, accuracy, and completeness of the documents. Carriers need to review the documents submitted by freight forwarders to ensure that the documents comply with the relevant provisions of the IATA DGR.
Special Provisions and Exception Clauses (Key Simplified Procedures)
Section II Exception Clauses: Applicable to Simplified Transport of Small – capacity/Small – weight Batteries (e.g., Consumer Electronics)
The Section II exception clauses are applicable to the simplified transport of small – capacity/small – weight batteries. For example, lithium – ion batteries with a single – cell energy ≤ 20Wh and a total package energy ≤ 100Wh can be transported as non – restricted items, but they still need to comply with packaging, marking, and quantity restrictions.
Watt – hour (Wh) and Lithium Content (g) Limits for Cells/Batteries
The watt – hour (Wh) and lithium content (g) limits are important criteria for determining whether batteries are eligible for exception clauses. For lithium – ion batteries, the single – cell energy ≤ 20Wh and the total package energy ≤ 100Wh; for lithium – metal batteries, the single – cell lithium content ≤ 1g and the total package lithium content ≤ 2g.
Under This Clause, It Can Be Transported as a “Non – restricted Item”, but It Still Needs to Comply with Packaging, Marking, and Quantity Restrictions
Under the Section II exception clauses, eligible lithium batteries can be transported as “non – restricted items”, but they still need to comply with packaging, marking, and quantity restrictions. For example, the batteries must be independently insulated, the packaging must be marked with the correct UN code and dangerous goods labels, and the number of batteries per package must not exceed the specified limit.
Passenger and Crew Carry – on Regulations (Briefly Related Description): Carry – on Requirements for Spare Batteries of Personal Electronic Devices (e.g., Energy Limits, Prohibition of Check – in)
Passengers and crew members must comply with relevant regulations when carrying spare batteries of personal electronic devices. Spare batteries must be carried on board and are prohibited from being checked in. Spare batteries with a rated energy not exceeding 100Wh do not require airline approval; spare batteries with a rated energy between 100Wh and 160Wh can be carried with airline approval (limited to 2 pieces); spare batteries with a rated energy exceeding 160Wh are prohibited from being carried.
Common High – risk Violation Scenarios and Case Analysis
Concealment/Misdeclaration as General Cargo: The Most Serious Compliance Red Line
Concealment or misdeclaration of batteries as general cargo is one of the most serious violations in air transport. Once discovered, enterprises may face huge fines, criminal liability, and be included in the airline blacklist. For example, in 2025, an enterprise concealed lithium batteries as general cargo for air transport. After being detected by customs, it was fined heavily, and the person in charge of the enterprise was held criminally responsible.
Non – compliant Packaging: Using Ordinary Cardboard Boxes, No Fixation of Inner Contents, No Anti – short – circuit Measures
Non – compliant packaging is also a common violation scenario. Using ordinary cardboard boxes to package lithium batteries cannot meet the safety requirements of air transport, which may easily lead to short – circuit, collision, and other accidents of the batteries during transport. In addition, no fixation of inner contents and no anti – short – circuit measures will also increase the safety risks of battery transport. For example, in 2025, an e – commerce seller used ordinary cardboard boxes to package a batch of mobile phone lithium batteries without independent insulation and fixation. During transport, the batteries collided with each other, resulting in short – circuit and fire.
Inconsistent Documents: Discrepancies between Declaration Form Information and Actual Goods, Test Summary Content
Inconsistent documents may lead to misunderstandings by airlines and customs about the hazards and transport requirements of lithium batteries, bringing safety risks and legal risks to enterprises. For example, if the UN number filled in the declaration form is inconsistent with the UN number of the actual goods, or the content of the test summary is inconsistent with the actual test results, it may result in the goods being detained or fined.
Ignoring the “Cargo Aircraft Only” Regulation: Mistakenly Arranging Batteries That Must Be Transported on Cargo Planes on Passenger Flights
Ignoring the “Cargo Aircraft Only” regulation and mistakenly arranging batteries that must be transported on cargo planes on passenger flights will pose a serious threat to the safe operation of passenger planes. The cargo compartment environment of passenger planes is different from that of cargo planes, and it cannot meet the safety transport requirements of lithium batteries. Once a lithium battery catches fire, the consequences will be disastrous. For example, in 2025, an enterprise mistakenly arranged batteries that must be transported on cargo planes on a passenger flight. After being discovered by the airline, the goods were unloaded urgently, and the enterprise was fined.
Building an Enterprise – wide End – to – end Risk Management System
Appoint a Dangerous Goods Compliance Officer: Participate in IATA – recognized DGR Courses and Obtain Certificates
Enterprises should appoint a dangerous goods compliance officer responsible for the compliance management of air transport of batteries. The dangerous goods compliance officer must participate in IATA – recognized DGR courses and obtain certificates to ensure that they have relevant professional knowledge and skills.
Establish an Internal Checklist: Check All Process Nodes from Order Taking to Delivery
Enterprises should establish an internal checklist to check all process nodes of air transport of batteries. The checklist should include document preparation, packaging compliance, marking and labeling, declaration and documentation, etc., to ensure that each link complies with the relevant provisions of the IATA DGR.
Educate Suppliers and Customers: Ensure That Battery Specification Sheets and Test Reports Meet Air Transport Requirements
Enterprises should strengthen the education of suppliers and customers to ensure that battery specification sheets, test reports, and other documents meet air transport requirements. Suppliers should provide battery products that meet the UN38.3 test standards and provide relevant test reports. Customers should understand the relevant regulations on air transport of batteries and cooperate with enterprises to prepare and declare the goods.
Choose Service Partners Carefully: Confirm That the Cooperating Freight Forwarders and Airlines Have Solid DG Operation Qualifications and Experience
When choosing freight forwarders and airlines, enterprises should choose carefully and confirm that they have solid DG (Dangerous Goods) operation qualifications and rich experience. Freight forwarders should hold valid dangerous goods transport qualifications and have a professional operation team and a complete service network. Airlines should have rich experience in lithium – battery transport and be able to strictly implement the relevant provisions of the IATA DGR.
Conclusion: Safety, Compliance, and Reliability – The Logistics Cornerstone for Driving Future Travel
Summary: The Export of Batteries by Air is a Systematic Project, and Technical Preparation, Process Refinement, and Risk Awareness Are Indispensable
The export of batteries by air is a systematic project involving product design, production and manufacturing, transport logistics, regulatory compliance, and other links. In the export process, sufficient technical preparation must be made to ensure that the performance and safety of the batteries meet relevant regulations and standards; all processes must be carefully refined to improve export efficiency and quality; a strong sense of risk must be maintained to identify and deal with various risks in a timely manner. Only by combining technical preparation, process refinement, and risk awareness can we ensure the safety, compliance, and smooth progress of the export of batteries by air.
Appeal: Internalize Transport Safety and Compliance as Part of Product Competitiveness to Achieve Long – term Stable Development
Enterprises should internalize transport safety and compliance as part of product competitiveness. They should not only focus on the performance and quality of products but also attach great importance to the safety and compliance of products during transport. By strengthening transport safety management and improving compliance levels, enterprises can win the trust and recognition of customers and enhance the market competitiveness of their products. At the same time, enterprises should actively participate in the formulation and improvement of industry standards to promote the healthy development of the air transport industry of batteries and provide a safe and reliable logistics guarantee for future travel.
Appendix: Quick Checklist for Air Transport of Lithium Batteries
- Have confirmed the battery type and the correct UN number (e.g., UN3480/3090)
- Have obtained the UN38.3 test summary that meets the format requirements of DGR 67
- All cells/batteries have been independently insulated to prevent short – circuit
- Have used certified UN – specification packaging, and the outer box is not damaged
- Have correctly posted the lithium – battery marking (including the UN number and emergency phone number), the Class 9 dangerous goods label, and the “Cargo Aircraft Only” label if necessary
- Have accurately and completely filled out the Shipper’s Declaration for Dangerous Goods, and the information is consistent with the actual goods and the test summary
- Have completed the dangerous goods booking declaration with the carrier and freight forwarder in advance and proactively
- The operators have received the 2026 IATA DGR training and obtained certificates
The above checklist can help enterprises quickly check the compliance of air transport of lithium batteries, identify and solve compliance problems in a timely manner, and ensure the safety, compliance, and smooth progress of air transport of lithium batteries. Enterprises can adjust and improve the checklist according to their actual business needs and regulatory requirements.