State approval is not airline acceptance

A State approval is a written authorization issued by the appropriate authority under a defined regulatory pathway. Its conditions may limit the battery models, packaging, quantities, aircraft, route, operator, dates or other aspects of the movement. It is not a blanket certificate for every future shipment of the same product.

The airline makes a separate operational decision. IATA's 2026 guidance says that a State of Origin approval does not require an operator to transport a consignment. It encourages shippers to identify an operator that has, or is willing to seek, any necessary State of the Operator approval before pursuing the origin-State step. Willingness to evaluate a shipment is still not a confirmed booking or final dangerous-goods acceptance. Source: IATA Battery Guidance Document, “Transport of lithium batteries under State Approvals.”

For planning, keep three records apart: the authority instrument, the operator's written response, and the acceptance evidence for the actual consignment. One cannot stand in for the others.

Approval, exemption and acceptance mean different things

An approval follows a provision that permits an appropriate authority to authorize a defined movement under stated conditions. An exemption is a different mechanism where the governing framework permits an exceptional departure from a requirement. Neither word should be used as a generic synonym for a forwarder's permission or an airline booking.

A State variation may add or modify a requirement for a movement involving that State. An operator variation or airline policy may be more restrictive than the regulatory baseline. Finally, shipment acceptance concerns the actual tendered goods, package, marks, labels and documents under the operator's applicable checks. These are related gates, not one approval chain with an automatic outcome. Check the published ICAO State Variations, current IATA addenda and guidance and the proposed operator's own requirements for the planned movement.

Establish the ordinary pathway before looking for an exception

Begin with the exact article, not the desired flight. Is it a lithium-ion or lithium-metal cell or battery? Is it shipped alone, packed with equipment or contained in equipment? Is it new and tested, a pre-production prototype, used, waste, damaged, defective or recalled? Record the model, manufacturer, watt-hour rating or lithium content as applicable, UN 38.3 evidence, battery mass, quantity and proposed package.

Then validate the UN entry, applicable packing instruction and section, aircraft limitation, quantity and package conditions against the effective rules. Check the State and operator variations for the actual route. A missing test summary, an incomplete product description or an unsuitable package does not by itself create an approval pathway. First determine what is missing and whether a specific provision actually allows the proposed movement under approval or exemption.

For the baseline rules, see our lithium battery shipping regulations guide and air-shipping quantity limits guide. The IATA 2026 guidance is useful orientation, but expressly says it is not a source of regulatory compliance.

Situations that may trigger an approval-path review

The following are screening signals, not a complete permissions table. They identify subjects to check in the current rules; they do not establish that a particular battery, package or flight is eligible.

The named provisions and their high-level subjects come from IATA's 2026 Battery Guidance Document. Their full criteria, current wording and interaction with other rules must be checked by a qualified dangerous-goods practitioner for the shipment. Approval must not be used to relabel damaged or recalled cargo as an ordinary used battery or to bypass a prohibition that has no applicable authorization path.

Which States and authorities may be involved?

There is no single global office that signs every lithium-battery approval. The applicable provision may involve the State of Origin, the State of the Operator, and in certain cases the State of Destination or other States concerned. IATA says the first two are required in many of its listed pathways and notes that some destination States require their own approval. Specific pathways differ: its public explanation of A201, for example, describes particular passenger-aircraft circumstances with different authority combinations. Do not infer the required signatories from a generic two-State diagram. Source: IATA 2026 Battery Guidance Document.

Map the proposed origin, destination, any transfer points, the selected operator and its State before contacting an authority. Then check the effective provision and published ICAO State Variations. A U.S. PHMSA interpretation concerning A99, for instance, illustrates why a shipment touching another jurisdiction cannot be assessed solely from the origin-State approval. That interpretation is fact-specific and dated; it is not a universal application recipe.

The ICAO Technical Instructions portal links to its national-authority directory, which can help locate a starting point. Verify the current contact, application process and authority competence on the national authority's own website before submitting anything.

Map the battery, package, route and aircraft before the enquiry

A useful first enquiry tells the recipient exactly what is proposed. Assemble one controlled fact sheet with:

• the manufacturer, battery model, chemistry, condition and intended use;
• the cell or battery configuration and whether it is alone, packed with equipment or contained in equipment;
• watt-hour rating for lithium-ion batteries or lithium content for lithium-metal batteries, plus individual battery mass where relevant;
• UN 38.3 test status and the available test summary;
• proposed UN entry, packing instruction and section, subject to qualified validation;
• state of charge where the provision makes it relevant;
• number of cells/batteries, battery net quantity, package and overpack design;
• passenger-aircraft or Cargo Aircraft Only limitations;
• origin, transfer points, destination, candidate operator and handling stations; and
• planned tender date, regulatory edition and the exact rule or variation being considered.

“Same battery, different flight” can be a materially different case if the operator or State changes. Conversely, a complete route description without the battery model and package plan is not enough to test eligibility.

Check operator willingness before investing in the process

Ask a candidate operator whether it is willing and able to evaluate the proposed battery, aircraft type, package and route, and whether it already has or would seek any necessary State-of-the-Operator authorization. Present the same controlled facts used for the authority enquiry. Record the date, contact, assumptions and limitations in the response.

This preliminary check can prevent work on an origin-State application for which no viable operator has been identified. It is not a way to make the operator responsible for the shipper's classification or to treat an informal conversation as acceptance. IATA explicitly recommends this operator-first enquiry in the context of State approvals. Source: IATA 2026 Battery Guidance Document.

Build a model-specific approval evidence package

An application or pre-enquiry should identify the exact provision and the scope being requested. The authority's own instructions determine the required forms and evidence; the following is a preparation checklist, not an official application form.

1. Battery identity and testing: manufacturer, model, chemistry, design description, ratings/content, mass, UN 38.3 status and available test evidence.
2. Condition and purpose: whether new, prototype, low-production, waste or otherwise exceptional; why the proposed movement is needed.
3. Packaging and controls: package drawings/specifications, terminal protection, prevention of short circuits and activation, securement, relevant mitigation and any testing or engineering evidence requested by the authority.
4. Proposed transport: classification, quantity, aircraft, itinerary, operators, stations and timing.
5. Requested regulatory scope: cited provision, responsible States, requested models, packages, route and validity period.
6. Supporting communications: operator response, previous authority correspondence and any existing instrument, clearly separated from a new request.

Where the final rule or authority calls for additional information, its instructions prevail. A generic safety data sheet alone cannot establish all of these facts. For the ordinary document set, use the lithium battery shipping documents checklist.

Read the written conditions, not just the approval number

If an authority issues a written instrument, compare the actual shipment against its scope line by line. Record the issuing authority, holder, reference, issue and expiry dates, applicable provision, named battery models, condition, package, quantity, aircraft, States, route, operator and any notification, handling or accompanying-document conditions that the instrument specifies.

An approval reference printed on a document is not evidence that another model, package, holder, route or date is covered. The operator may also require its own review and evidence. Keep the instrument, the documents supporting it and the operator record together, but do not merge them into a claim of automatic acceptance.

What changes can invalidate an earlier conclusion?

Reopen the review when a shipment changes in a way that may affect the authority instrument or the baseline rules:

• battery model, chemistry, watt-hour rating, lithium content or mass;
• new, used, waste, damaged, defective or recalled status;
• state of charge, quantity, package or overpack;
• aircraft type, operator, handling station, origin, transfer or destination;
• applicant/holder or another named party;
• expiry date, shipment date, applicable edition, addendum or variation.

The safe question is not “Do we still have an approval number?” It is “Does every material fact in today's consignment still match the written scope and current rules?” The ICAO Technical Instructions portal publishes edition and amendment information; check it again before a later movement.

Keep a defensible approval-path record

For each proposed movement, retain the rule edition and check date, the reason an approval or exemption was considered, the States identified, the authority correspondence and final written instrument, and a versioned index of battery and packaging evidence. Record any change decision and the person who approved the new facts internally.

Store the operator's willingness, booking and shipment-level acceptance separately. This helps a later reviewer see which decision was regulatory, which was commercial or operational, and which applied to the tendered packages. A record of “approved” with no issuing body, scope or date is not enough to support the next shipment.

Common approval mistakes

• Starting with a desired flight instead of the battery facts. The operator cannot assess an unidentified model and package.
• Assuming an SDS is a complete transport classification. Obtain model-specific ratings, condition and test evidence.
• Treating a named special provision as permission. Its full criteria and required authority conditions still apply.
• Calling an exemption an approval. The underlying legal mechanisms and required States may differ.
• Using an earlier approval for a changed shipment. Recheck the written scope before every tender.
• Ignoring State or operator variations. A baseline packing pathway is not the whole route decision.
• Calling an operator's preliminary interest an acceptance. The actual consignment remains subject to its checks.
• Assuming a forwarder issues government approval. Only the competent authority can issue its own instrument.

Pre-enquiry decision checklist

1. Freeze the battery model, chemistry, condition, configuration and evidence.
2. Validate the ordinary classification, packing and aircraft pathway.
3. Identify the exact rule or variation that creates the approval/exemption question.
4. Map the States, operator, route and handling stations.
5. Recheck the effective edition, addenda, State and operator variations.
6. Ask a capable operator if it is willing to evaluate the proposed movement.
7. Assemble the model-specific battery, package and route evidence.
8. Follow the relevant authorities' current instructions for the requested scope.
9. Compare every written condition with the actual shipment.
10. Revalidate changes and the operator's pre-booking requirements before tender; obtain final shipment-specific acceptance when the consignment is presented and checked.

If the exact trigger or authority path cannot be established, stop at an enquiry rather than describing the shipment as approved.