Start With the Shipment, Not the CAO Label

The words Cargo Aircraft Only answer a downstream question: which aircraft limitation applies after the dangerous goods have been identified and prepared under the correct pathway?

They do not answer the upstream questions:

• Is the battery lithium ion, lithium metal, sodium ion or another chemistry?
• Is it a cell, battery, battery-powered vehicle, cargo transport unit or another article?
• Has the applicable battery design completed the required UN 38.3 testing pathway?
• Is the battery shipped alone, packed with compatible equipment or installed in equipment?
• What is the verified Watt-hour rating or lithium content?
• Is the battery new and undamaged, or is it damaged, defective, recalled, prototype, low-production, used, waste or intended for recycling?
• Which UN entry, packing instruction and section apply?
• What is the battery count and net quantity in each completed transport package?
• Which origin, transit, destination and operator are proposed?

If those facts are incomplete, the aircraft limitation is not ready to be selected. Placing a CAO label on an incorrectly classified, over-limit or unsuitable package does not make it acceptable for air transport.

A controlled shipment record should identify the exact battery model, product model, configuration and final package. Commercial descriptions such as “battery pack,” “electronics,” “spare battery” or “machine parts” are not precise enough to select an aircraft column.

Use the wider lithium battery shipping regulations guide when the basic chemistry, UN entry or transport-mode framework is still uncertain.

What Does Cargo Aircraft Only Mean?

In practical air-cargo terms, CAO means the package is restricted from passenger aircraft under the applicable dangerous-goods pathway and must be evaluated for carriage on a cargo aircraft.

That statement has four important limits.

CAO is an aircraft limitation

It does not replace the UN number, proper shipping name, packing instruction or section. Two packages can both be restricted to cargo aircraft while requiring different packaging, quantity, hazard communication and documentation.

CAO is not permission for any freighter

A cargo airline may prohibit a battery category, apply a lower quantity, require additional evidence, restrict particular stations or decline the cargo for operational reasons. The proposed route must have a suitable operator, aircraft service and handling capability.

CAO is not the same as space availability

A shipment may have a regulatory pathway but no commercially available service for the required date, route, package size or handling arrangement. Regulatory eligibility and cargo capacity are different decisions.

CAO does not replace shipper responsibilities

Classification, package preparation, marks, labels and documentation must still be correct. The FAA's public shipper guidance makes the same distinction in the U.S. context: the shipper must prepare the dangerous goods correctly, while carriers may impose limitations or prohibitions beyond the baseline rules.

Passenger Aircraft vs Cargo Aircraft at a Glance

The following table is a 2026 public-guidance orientation. It is not a shipment classification, complete quantity table or carrier acceptance result.

The table deliberately omits package-limit figures. Passenger-aircraft and CAO quantities are section-specific and can be misused when separated from the battery and package facts. Use the dedicated lithium battery air-shipping quantity limits guide for the current numerical matrix and worked examples.

Why Standalone UN 3480 and UN 3090 Use the CAO Pathway

Standalone batteries receive the clearest CAO treatment in the public 2026 guidance.

UN 3480 lithium-ion batteries shipped alone

UN 3480 applies to lithium-ion cells and batteries shipped without the equipment they are intended to power. For air transport, the starting instruction is PI 965.

The IATA 2026 guidance states that all UN 3480 cells and batteries shipped by themselves are forbidden as cargo on passenger aircraft under the baseline framework. It also states that packages prepared under PI 965 Section IA or Section IB must bear the Cargo Aircraft Only label in addition to the other required marks or labels.

PI 965 still has more than one branch. The verified Wh rating, package quantity and other conditions determine whether Section IA or Section IB can be considered. Both branches remain regulated dangerous-goods pathways. A lower-Wh battery is not exempt merely because it falls within the smaller-rating range.

Standalone lithium-ion batteries are also subject to the applicable state-of-charge restriction. Correct SoC does not make them passenger-aircraft eligible under the ordinary baseline. SoC, section, quantity and aircraft limitation are separate checks.

Use the dedicated guide to compare PI 965, PI 966 and PI 967 before treating a lithium-ion package as standalone.

UN 3090 lithium-metal batteries shipped alone

UN 3090 applies to lithium-metal cells and batteries shipped without the equipment they are intended to power. For air transport, the starting instruction is PI 968.

The same IATA guidance states that all UN 3090 cells and batteries shipped by themselves are forbidden as cargo on passenger aircraft under the baseline framework. Packages prepared under PI 968 Section IA or Section IB must bear the Cargo Aircraft Only label together with the other applicable marks or labels.

Lithium-metal batteries use verified lithium content rather than lithium-ion Watt-hours to identify the relevant size branch. The package quantity, packing method, documentation and operator conditions still have to be checked.

Use the dedicated UN 3090 versus UN 3091 guide for the lithium-metal configuration decision and the lithium-content guide for the manufacturer-supplied content data needed in that review.

Approval provisions do not create an ordinary passenger route

The current IATA guidance identifies limited approval or exemption pathways for specified circumstances. Those pathways depend on the effective provision, the appropriate authorities, written conditions and operator involvement. They are not options a shipper can select from an online checklist, and they do not compel an airline to accept the cargo.

Equipment-Related Batteries Are Not Automatically CAO

The passenger-aircraft prohibition for standalone UN 3480 and UN 3090 should not be copied onto every shipment containing lithium batteries.

UN 3481 and UN 3091 cover equipment-related configurations:

• packed with equipment: the battery and the equipment it is intended to power are in the same completed package, but the battery is not installed; and
• contained in equipment: the battery is installed in the equipment during transport.

For lithium-ion batteries, the starting instructions are PI 966 and PI 967. For lithium-metal batteries, they are PI 969 and PI 970.

The public 2026 IATA flowcharts show passenger-aircraft and CAO columns for these equipment-related pathways. That does not mean that every UN 3481 or UN 3091 package may travel on a passenger aircraft. The shipper still has to establish:

• the correct packed-with or contained-in configuration;
• the applicable Section I or Section II branch;
• the verified Wh rating or lithium content;
• the battery count and permitted spare sets where relevant;
• the battery net quantity in the completed package;
• the packaging and equipment protection;
• any SoC condition;
• the required marks, labels and documents; and
• the State, operator and route conditions.

A passenger-aircraft value is a conditional maximum inside a defined pathway, not a general permission. A CAO value is also conditional. If the package does not meet the selected instruction and section, neither column provides a valid shipping plan.

The equipment relationship must be real. Placing a charger, cable or unrelated device next to loose batteries does not automatically make them “packed with equipment.” A power bank is treated as a battery for this classification decision, not as equipment simply because it can charge a phone.

The CAO Label Is Not the Lithium Battery Mark

Several different marks and labels can appear on a lithium-battery package. They communicate different information and should not be treated as interchangeable stickers.

For standalone UN 3480 / PI 965 and UN 3090 / PI 968, the public 2026 guidance expressly requires the CAO label on Section IA and Section IB packages in addition to the other applicable communication. It also explains that Section IB packages can require the lithium battery mark, Class 9 lithium battery hazard label and CAO label together.

That combination is a useful reminder: one correct label does not replace another required mark or label.

Do not copy artwork from an online article or add every familiar battery sticker “to be safe.” Extra, conflicting or inapplicable hazard communication can be as problematic as missing information. First confirm the shipment pathway, then review the final package under the effective rules.

Use the dedicated lithium battery marks and labels guide for the complete package-photo review and current marking boundaries.

Read the Aircraft Column, Section and Net Quantity Together

A common error is finding one large number in a CAO column and treating it as the maximum for every battery package. That skips the decision tree that gives the number meaning.

Review the result in this order:

1. Identify the UN entry and packing instruction. Chemistry and physical configuration come first.
2. Establish the applicable section. Wh or lithium content, package quantity and other conditions affect the branch.
3. Choose the correct aircraft column. Passenger-aircraft and CAO quantities are separate.
4. Apply the quantity to the correct unit. Confirm whether the rule is controlling net battery quantity per package, a battery count, a consignment condition or another measure.
5. Recheck the complete package. Packaging performance, marks, labels, documents and overpack treatment must match the same branch.
6. Check State and operator variations. A lower operational limit or prohibition may apply.

The IATA guidance defines net quantity for batteries packed with or contained in equipment as the net weight of the batteries in the package, excluding the equipment and packaging. Gross carton mass therefore cannot be copied into the battery net-quantity field without separating the components.

Likewise, the quantity limit applies to a completed package under the relevant instruction. An overpack is a handling enclosure containing one or more already prepared packages; it is not a method for increasing an individual package limit.

State of Charge Does Not Decide CAO by Itself

State of charge is a safety and regulatory input for specified rechargeable battery pathways. It is not a universal aircraft-permission switch.

For example, the public 2026 IATA guidance requires standalone UN 3480 lithium-ion cells and batteries under PI 965 to be offered for transport at a state of charge not exceeding 30% of rated capacity unless the specified approval pathway applies. The same guidance still shows UN 3480 as forbidden on passenger aircraft under the baseline framework.

In other words:

• a UN 3480 battery below 30% SoC does not become ordinary passenger-aircraft cargo;
• a battery above a stated SoC limit does not become acceptable merely because a cargo aircraft is requested;
• equipment-related lithium-ion pathways have their own 2026 SoC treatment; and
• lithium-metal batteries use verified lithium content for the relevant size decision rather than applying lithium-ion SoC logic.

Use the dedicated lithium battery state-of-charge guide for the difference between mandatory limits, recommendations and approval-dependent pathways.

Package, Overpack and Shipment Records Must Agree

The aircraft limitation must be consistent across the physical cargo and every applicable shipment record.

Package

The completed transport package must use the marks and labels required by the applicable instruction and section. A CAO label should not appear as an unsupported guess, and it should not be omitted where the current pathway requires it.

Overpack

The IATA 2026 guidance explains that dangerous-goods packages inside an overpack remain individually prepared packages. Required package marks and labels must be visible through the overpack or reproduced on it as required. The overpack also has compatibility and segregation considerations.

Several correctly prepared CAO packages do not merge into one unlimited package when stretch-wrapped on a pallet. Each inner transport package must stay within its own applicable limit and remain correctly prepared.

Use the dedicated lithium battery overpack requirements guide before finalizing an overpack.

Shipper's Declaration

When a Shipper's Declaration for Dangerous Goods is required, its regulated entry, package count, quantity, packing-instruction information, authorizations and prescribed aircraft limitation must describe the cargo actually offered for transport. If the applicable entry requires the words Cargo Aircraft Only, a declaration that omits that limitation cannot be used unchanged for a package labelled and booked as CAO cargo. The package, declaration and booking record must describe the same transport pathway.

Use the lithium battery Shipper's Declaration guide for the field-level consistency review.

Air waybill and booking record

The air waybill is not the Shipper's Declaration. Depending on the applicable pathway, the current rules may require specific handling or compliance information in the air waybill or associated electronic record. The booking request must also identify the dangerous-goods and aircraft limitations accurately enough for the operator to evaluate the shipment.

Use the wider lithium battery shipping documents checklist to reconcile technical, commercial, package and transport records.

Final packing changes

A factory may change the battery count, carton arrangement, package count or gross mass after the first document draft. Any such change can affect the section, net quantity, labels, DGD, air waybill, overpack and booking. Freeze or recheck the final packing before tender.

State Variations, Operator Variations and Route Acceptance

The international baseline is not the only layer affecting a shipment.

The ICAO Technical Instructions establish the detailed international air dangerous-goods framework. ICAO also publishes State variations, which can add jurisdiction-specific conditions. IATA's DGR incorporates State and operator variations used in airline operations.

For a practical CAO plan, check:

• State of Origin: where the consignment is first loaded on an aircraft;
• State of the Operator: the State associated with the operator's principal place of business;
• State of Destination: where the consignment is finally unloaded from an aircraft;
• Transit States and airports: additional requirements or handling restrictions may affect the route;
• operator variation: an airline may prohibit, restrict or require additional information for the cargo;
• station capability: the origin, transfer and destination facilities must be able and willing to handle the shipment; and
• actual aircraft service: a passenger flight and a freighter route are not interchangeable capacity products.

A change of airline, transit airport, battery model, package, quantity or shipping date should trigger another review. An accepted shipment from the previous month is useful history, but it is not automatic approval for new cargo.

The IATA Dangerous Goods Documentation page provides current public addenda and acceptance resources. Those materials complement the effective regulations; they do not replace them.

Approvals and Exemptions Are Not Self-Service Workarounds

Public guidance references special approval or exemption pathways for defined circumstances. These can involve one or more national authorities and the operator, with written conditions tied to the actual battery, shipment and route.

Do not treat an approval number from another company, battery model, country pair or previous shipment as reusable evidence. Questions to verify include:

• Which special provision or legal basis applies?
• Which authorities must issue approval or exemption?
• Which shipper, battery models, quantities, packages, dates and routes are covered?
• What written conditions must appear in the preparation or documents?
• Has the intended operator accepted the approval for the proposed route?

An approval can create a controlled regulatory pathway. It does not force an operator to offer service or accept the shipment.

BAT Logistics does not issue competent-authority approvals, battery certifications, UN 38.3 test summaries or regulatory waivers. It can review supplied information for visible logistics inconsistencies and coordinate an enquiry with the relevant freight and operating parties.

A Practical CAO Review Workflow

1. Identify the exact battery and product

Record the cell, battery and product manufacturer and model. Do not combine documents from similar-looking models without evidence that they cover the shipped design.

2. Establish chemistry, condition and test status

Confirm whether the battery is lithium ion or lithium metal and match it to the applicable UN 38.3 test-summary identity. Disclose damaged, defective, recalled, prototype, low-production, used, waste or recycling status before route planning.

3. Freeze the physical configuration

Photograph and describe the completed package. Identify which batteries are shipped alone, packed beside the equipment they power or installed in that equipment. Map each loose spare to the compatible equipment.

4. Identify the likely UN entry, PI and section

Use the chemistry, configuration, Wh or lithium content and package facts to identify the appropriate starting point. Have the responsible shipper and trained dangerous-goods party confirm the applicable current pathway.

5. Read the correct aircraft column and quantity

Confirm whether the selected branch prohibits passenger-aircraft cargo, permits a conditional passenger pathway or requires CAO treatment. Apply the quantity to the correct package and unit.

6. Reconcile package, labels and documents

Compare the battery evidence, invoice, packing list, package, overpack, marks, labels, DGD, air waybill and booking request. Resolve conflicting UN entries, package counts, quantities or aircraft limitations before tender.

7. Confirm the current route and operator

Check the effective edition, addenda, corrigenda, State variations and operator variations. Confirm the origin, transfer and destination stations and recheck if any shipment fact or operating party changes.

Common Cargo Aircraft Only Errors

Choosing CAO from the product name

“Lithium battery” does not identify the chemistry, configuration, UN entry, PI, section or aircraft column.

Assuming every lithium battery is forbidden on passenger aircraft

The baseline prohibition applies clearly to standalone UN 3480 and UN 3090. Equipment-related UN 3481 and UN 3091 must be assessed under their own instructions, sections and aircraft columns.

Copying a CAO quantity into the passenger column

Passenger-aircraft and CAO values are separate. The larger value shown in a CAO branch is not a passenger-aircraft allowance.

Treating reduced SoC as passenger-aircraft permission

SoC is only one condition. It does not override the applicable passenger prohibition or other preparation requirements.

Confusing the CAO label with the battery mark

The CAO label communicates an aircraft limitation. The lithium battery mark and Class 9 battery label communicate different information and may be required in addition.

Placing labels before confirming the pathway

Pre-printing a generic carton with every possible label can create contradictory communication. Confirm the actual shipment before final labelling.

Letting the DGD, air waybill and package disagree

If the package bears CAO communication but the declaration or booking requests passenger aircraft, the shipment record is inconsistent and requires correction.

Ignoring the overpack

Stretch wrap or another enclosure can hide required package communication. Verify visibility and reproduction requirements before tender.

Reusing an old acceptance

Operator variations, routes, station capabilities and editions can change. A previous acceptance does not approve a later shipment.

Assuming CAO means automatically bookable

The operator may still decline the cargo, restrict quantity, require more evidence or have no suitable freighter service.

Pre-Booking CAO Checklist

Before requesting a lithium-battery air-route review, prepare:

• battery and product manufacturer and exact model;
• lithium-ion or lithium-metal chemistry;
• UN 38.3 test-summary reference or status for the exact design;
• battery condition and shipment history;
• verified Wh per lithium-ion cell/battery or lithium content for lithium-metal cells/batteries;
• exact alone, packed-with or contained-in-equipment relationship;
• proposed UN entry, packing instruction and section supplied by the responsible party;
• battery count and net battery quantity per completed package;
• package count, gross mass and dimensions;
• SoC evidence where relevant;
• packaging description and available performance evidence;
• clear battery, package, overpack, mark and label photographs;
• invoice, packing list, DGD, air waybill or other applicable document draft;
• pickup point, transit points and final destination;
• intended operator and requested passenger- or cargo-aircraft pathway; and
• any approval, exemption, State variation or operator-variation question.