The Short Answer: Start with Five Shipment Facts

Before selecting a packing instruction, label or route, identify:

1. Chemistry — lithium ion or lithium metal.
2. Configuration — shipped alone, packed with equipment or contained in equipment.
3. Technical rating — Watt-hour rating for lithium-ion cells and batteries, or lithium content for lithium-metal cells and batteries.
4. Condition — new and tested, prototype, used, damaged, defective, recalled, waste or intended for recycling.
5. Mode and route — air, sea, road, rail or a multimodal combination, including the origin, transit and destination countries.

These facts determine the likely UN number and the regulatory layers that must be checked. A product sales name such as “battery pack,” “portable charger” or “smart device” is not enough.

What Changed for Lithium Battery Transport in 2026?

Air: reduced charge for batteries packed with equipment

The IATA 2026 battery guidance document reflects the 2025–2026 ICAO Technical Instructions and the 67th edition of the IATA Dangerous Goods Regulations.

From 1 January 2026, lithium-ion cells and batteries prepared under PI 966 Section I must be offered for air transport at no more than 30% of their rated capacity unless the State of Origin and State of the Operator approve a higher state of charge under written conditions.

For PI 966 Section II, the same 30% maximum applies when a cell or battery exceeds 2.7 Wh. A higher state of charge moves the shipment into the Section I approval pathway described by the guidance.

This change concerns lithium-ion batteries packed with equipment. Do not automatically extend it to every battery installed inside a product.

Air: contained-in-equipment treatment is different

For lithium-ion cells and batteries contained in equipment under PI 967, the IATA 2026 guidance recommends offering them at:

• no more than 30% state of charge; or
• no more than 25% indicated battery capacity.

The same guidance explicitly states that this reduced-charge treatment is not mandatory for PI 967 shipments. Airlines, States or other operating parties may still apply variations or stricter acceptance policies, so the actual route must be checked.

Sea: IMDG Amendment 42-24 is mandatory

The International Maritime Organization states that the IMDG Code 2024 Edition, including Amendment 42-24, became mandatory on 1 January 2026. The previous 2022 edition is obsolete.

That change means a 2026 sea shipment should be reviewed against IMDG 42-24, not against an old checklist or an air packing instruction copied into an ocean booking.

Road and rail: current land-mode editions still matter

For international road movements in ADR contracting countries, ADR 2025 contains the amendments applicable from 1 January 2025 and remains the current biennial edition during 2026. International rail movements within the RID system use RID 2025, also effective from 1 January 2025.

Land-mode requirements must still be matched to the actual route, countries, vehicle or wagon operation, quantity, packing and any national provisions.

Identify the Battery Before Applying a Regulation

The four main lithium-battery entries for ordinary cargo are:

“Packed with equipment” and “contained in equipment” are not interchangeable.

• Packed with equipment means the battery is in the same package as the equipment it is intended to power but is not installed in that equipment.
• Contained in equipment means the battery is installed in the device or machinery.
• Shipped alone means the battery is not packed with or installed in the equipment it will power.

A power bank is designed primarily to provide power to another device. The IATA guidance therefore treats a power bank as a battery—normally UN 3480 for a lithium-ion design or UN 3090 for a lithium-metal design—not as ordinary equipment containing a battery.

For a more detailed lithium-ion configuration workflow, see UN3480 vs UN3481.

Scope note: sodium-ion batteries

Sodium-ion batteries with organic electrolyte now have separate entries and air packing instructions: UN 3551 for batteries shipped alone and UN 3552 for batteries packed with or contained in equipment. They should not be declared under a lithium-battery UN number merely because the product format is similar. This article does not provide a full sodium-ion shipping workflow; check the current mode code and the actual chemistry before transport.

Understand the Four Regulatory Layers

International battery shipments often pass through four layers of control.

1. The UN foundation

The UN Model Regulations provide a harmonized framework for classification, dangerous-goods entries, packing concepts, hazard communication and special provisions. The UN Manual of Tests and Criteria contains the subsection 38.3 transport-test framework for applicable lithium cell and battery designs.

These UN publications form the foundation, but they are not a complete booking instruction for every mode or country.

2. The mode-specific code

• ICAO Technical Instructions and the IATA DGR are used for air transport.
• The IMDG Code applies to international transport of dangerous goods by sea.
• ADR applies to relevant international road transport.
• RID applies to relevant international rail transport.

Each system turns the common classification framework into mode-specific packing, quantity, documentation and operating requirements.

3. National and State requirements

Countries implement international standards through their own laws and may add State variations. In the United States, for example, lithium batteries transported in commerce are regulated under the Department of Transportation Hazardous Materials Regulations in 49 CFR Parts 171–180. PHMSA’s shipper guide organizes those requirements by chemistry, size, configuration and mode.

4. Carrier and operator acceptance

An airline, shipping line, courier, terminal, railway operator or trucking provider may impose conditions that are stricter than the baseline code. Capacity, aircraft type, vessel policy, port restrictions, destination arrangements and the operator’s dangerous-goods approval process all affect acceptance.

Regulatory eligibility is therefore not the same as a confirmed booking.

Air Transport Rules for Lithium Batteries in 2026

Air transport uses configuration-specific packing instructions.

The applicable section, package limit, performance-tested packaging requirement, marks, labels and documents depend on cell or battery size, quantity and configuration. Do not select a section from the UN number alone.

Passenger-aircraft prohibitions

Under the IATA 2026 guidance:

• UN 3480 lithium-ion cells and batteries shipped alone are forbidden as cargo on passenger aircraft.
• UN 3090 lithium-metal cells and batteries shipped alone are forbidden as cargo on passenger aircraft.

Applicable packages must move under cargo-aircraft conditions and display the required Cargo Aircraft Only label in addition to other required marks or labels.

UN 3481 and UN 3091 are not governed by that same blanket statement. Their passenger- or cargo-aircraft eligibility depends on the applicable packing instruction, section, quantity limits, State variations and operator acceptance.

State-of-charge matrix

The ICAO revision summary is important because it shows that the 2026 changes are tied to defined packing instructions and configurations—not to the word “lithium” alone.

Air marks, labels and documents

Depending on the applicable section and package, the shipment may require:

• the correct UN number and proper shipping name;
• a lithium-battery mark;
• a Class 9 lithium-battery hazard label;
• a Cargo Aircraft Only label;
• a Shipper’s Declaration for Dangerous Goods;
• an air-waybill compliance statement; and
• trained personnel or documented “adequate instruction.”

Not every item in this list applies to every shipment. The preparation decision must be made from the current packing instruction, State and operator variations.

Sea Transport Rules for Lithium Batteries in 2026

International sea transport in 2026 should be assessed under IMDG Code Amendment 42-24.

A sea review normally considers:

• the correct UN number, proper shipping name and Class 9 classification;
• whether a small-battery or other special provision applies;
• authorized inner and outer packaging;
• protection against short circuit, movement and damage;
• the required marks and hazard labels;
• the dangerous-goods transport document and container/vehicle packing certificate where applicable;
• stowage, segregation and container-loading conditions; and
• shipping-line, port, terminal and destination restrictions.

Air and sea rules are not interchangeable

The 30% air state-of-charge rule should not be presented as a universal sea-freight rule. Likewise, an IATA packing instruction is not the sea packing instruction.

A multimodal shipment may have to satisfy more than one system. For example, a factory-to-port truck movement, an international ocean leg and destination road delivery can involve national law, ADR-like land requirements where applicable, IMDG requirements and individual operating-party conditions.

The most restrictive handoff can determine whether the planned route is workable.

Road and Rail Regulations Require a Route-Specific Check

ADR and RID are closely harmonized, but they apply within defined legal and geographic systems. Other countries use their own dangerous-goods laws, often based on the UN framework.

A land-transport assessment can depend on:

• battery entry and condition;
• package type and quantity;
• whether an exemption or special provision applies;
• transport documentation;
• vehicle, wagon, equipment and loading requirements;
• driver, crew or employee training;
• tunnel, border, terminal or national restrictions; and
• emergency instructions and carrier procedures.

Do not assume that a shipment accepted for an ocean leg can automatically travel by road or rail at origin or destination. Confirm every regulated handoff.

UN 38.3, SDS and Shipment Documents

What the UN 38.3 test summary does

Applicable lithium cell and battery designs must have completed the tests required by subsection 38.3 of the UN Manual of Tests and Criteria before ordinary transport. Manufacturers and subsequent distributors must make the prescribed test summary available for applicable designs.

The summary identifies information such as the manufacturer, test laboratory, report identification, test date, battery type, mass, Watt-hour rating or lithium content, physical description, model numbers and test results.

The IATA guidance explains that the summary does not normally need to travel as a paper copy with every air shipment unless a State or operator requires it. It must, however, be available quickly and correspond to the actual model being shipped.

What the test summary does not do

A UN 38.3 test summary does not:

• classify the complete shipment by itself;
• prove that the packing is correct;
• replace marks, labels or transport documentation;
• approve a damaged, defective or recalled battery;
• guarantee airline, shipping-line, terminal or customs acceptance; or
• serve as a booking confirmation.

SDS or MSDS

An SDS—often still called an MSDS—can help operating parties review chemistry, hazards and emergency information. It does not replace the test summary, correct dangerous-goods classification, packing requirements or mode-specific documentation.

Quote-ready shipment information

For an initial route and regulation review, prepare:

• manufacturer and exact model;
• battery chemistry;
• cell or battery status;
• Watt-hour rating or lithium content;
• quantity and batteries per package;
• gross weight, battery net weight and package dimensions;
• whether batteries are alone, packed with equipment or installed;
• state of charge where relevant;
• condition, including any damage, defect, recall or prior use;
• UN 38.3 test-summary access;
• SDS/MSDS and available transport reports;
• packing photographs and package specification;
• pickup city, destination, intended mode and ready date; and
• required airport, seaport, rail, road, door or DDP scope.

Packaging, Marks and Labels Depend on the Actual Shipment

Across modes, the safety objective includes preventing short circuits, accidental activation, movement and damage during normal transport. The exact method is not universal.

The packing decision may change with:

• cell or battery size;
• net quantity per package;
• UN specification packaging requirements;
• equipment strength and protection;
• whether batteries are spare, installed or packed beside equipment;
• whether multiple dangerous goods are in one package or overpack;
• pallet, crate or container arrangement; and
• the battery’s condition.

A generic online picture of a lithium-battery mark is not a packing plan. Confirm the current code, dimensions, placement, wording and required hazard labels for the actual shipment.

Special-Condition Batteries Need a Separate Route

Damaged, defective or recalled batteries

Batteries that may produce heat, fire or short circuit under normal transport conditions cannot be tendered as ordinary new cargo. Many damaged or safety-recalled batteries are prohibited by air under standard provisions. Other modes may require special packing, competent-authority conditions or a specialized operating chain.

Disclose the condition before pickup or booking. Do not hide it inside a general product description.

Prototype and low-production-run batteries

A design that has not completed the normal UN 38.3 pathway may require competent-authority approval and special packing. The IATA guidance identifies Special Provision A88 as an air approval route for certain pre-production prototypes and low-production runs; this is not automatic acceptance.

Used, waste and recycling shipments

Used does not necessarily mean damaged, but the history and present condition must be known. Waste or recycling shipments can trigger separate provisions, environmental controls and destination restrictions. Air transport is particularly restrictive and should be assessed before any commercial promise is made.

Who Is Responsible for Lithium Battery Compliance?

The IATA guidance describes these responsibilities as a connected supply chain. Hiring a freight forwarder does not transfer every legal duty away from the manufacturer or shipper, and a forwarder’s review does not bind an airline or shipping line to accept the cargo.

BAT Logistics reviews the shipment information supplied by the customer or factory and coordinates the agreed freight process. BAT does not perform UN 38.3 testing, issue regulatory approvals or guarantee carrier acceptance.

Pre-Shipment Regulatory Checklist

Before requesting a booking, confirm that:

• [ ] the chemistry and exact model are known;
• [ ] the correct shipped-alone, packed-with or contained-in configuration is identified;
• [ ] the likely UN number and proper shipping name are established;
• [ ] Watt-hour rating or lithium content is available;
• [ ] the state of charge is known where the air rules or operator policy require it;
• [ ] the battery condition is accurately declared;
• [ ] the test summary matches the model;
• [ ] packaging is designed for the actual code, mode and quantity;
• [ ] marks, labels and documents match the final package;
• [ ] every origin, main-carriage and destination handoff has been checked;
• [ ] State, national and operator variations have been reviewed; and
• [ ] the booking has been accepted before cargo is dispatched to the operating facility.

Frequently Asked Questions

Does every lithium battery need UN 38.3 testing?

Applicable lithium cell and battery designs offered for ordinary transport generally need to meet the subsection 38.3 test requirements. Limited exceptions and special approval pathways exist, including certain prototype or low-production situations, but these must be assessed before transport.

Must the UN 38.3 test summary be placed in every package?

No. The IATA 2026 guidance says the summary does not routinely need to be provided as a paper copy with every air shipment unless a State or operator requires it. The manufacturer and subsequent distributors must make the applicable summary available, and operating parties may request it.

Can UN 3480 lithium-ion batteries travel on a passenger aircraft?

Not as cargo under the standard IATA provisions. UN 3480 batteries shipped alone are prohibited as cargo on passenger aircraft and normally move under cargo-aircraft conditions, subject to the applicable packing instruction and operator acceptance.

Does every lithium-ion shipment have to be at 30% state of charge?

No. The requirement depends on the configuration and packing instruction. UN 3480 under PI 965 is limited to 30% unless the approval pathway applies. From 2026, many PI 966 batteries packed with equipment are also limited to 30%. For PI 967 batteries contained in equipment, reduced charge is strongly recommended in the IATA guidance but is not the same mandatory rule.

Are lithium battery sea regulations the same as air regulations?

No. Sea transport uses the IMDG Code; air transport uses the ICAO Technical Instructions and IATA DGR. The UN classification foundation is related, but packing instructions, quantity limits, documents and operating conditions differ by mode.

Can damaged lithium batteries use the normal shipping channel?

Do not assume so. Damaged, defective or safety-recalled batteries require a separate assessment and may be prohibited by air or require competent-authority conditions and specialized packing for another mode.

Request a Shipment-Specific Regulation and Route Review

Send the battery model, chemistry, rating, configuration, condition, quantity, packing, available UN 38.3 and SDS/MSDS information, pickup city, destination and preferred mode.

BAT Logistics can review the supplied information and coordinate a China-origin air, sea, rail, road, courier or eligible door/DDP option with the relevant operating parties. Final requirements and acceptance depend on the actual cargo, route, current regulations, capacity and carrier.

For the broader operational sequence, read How to Ship Lithium-Ion Batteries Internationally. For commercial shipment planning, visit Battery Shipping from China or contact BAT Logistics.

Editorial Source Notes

• IATA, Guidance Document for Lithium Batteries and Sodium Ion Batteries — 2026, dated 1 January 2026; accessed 2 September 2026.
• ICAO, Revisions Incorporated in the 2025–2026 Edition of the Technical Instructions for the Safe Transport of Dangerous Goods by Air; accessed 2 September 2026.
• IMO, IMDG Code, 2024 Edition including Amendment 42-24; accessed 2 September 2026.
• UNECE, UN Model Regulations, Revision 24 (2025); accessed 2 September 2026.
• UNECE, UN Manual of Tests and Criteria, Revision 8 and Amendment 1; accessed 2 September 2026.
• UNECE, ADR 2025; accessed 2 September 2026.
• OTIF, RID 2025; accessed 2 September 2026.
• PHMSA, Lithium Battery Guide for Shippers, updated October 2024; accessed 2 September 2026.

Items to Recheck Immediately Before Publication

• IATA 67th-edition addenda and current operator variations.
• ICAO State variations or corrigenda.
• IMO corrections or supplements affecting IMDG 42-24.
• ADR/RID corrigenda and route-country requirements.
• The policies of every proposed airline, shipping line, courier, terminal and destination partner.