Identify the Battery’s Real Status Before Choosing a Route

Begin with four questions:

1. Has this exact cell or battery design type completed the applicable UN 38.3 tests?
2. If not, is it a genuine pre-production prototype being transported for testing?
3. If it is not a prototype-for-testing movement, is it part of a qualifying low-production annual run?
4. Is the battery new, stable and otherwise eligible for the proposed mode, or does damage, defect, recall, waste or recycling status create a different pathway?

These questions should be answered before asking for a freight rate. A carrier cannot correct an unsupported prototype claim, and a different mode does not make missing design, condition or production information irrelevant.

Use the following as an orientation framework only:

This table is not a classification, approval or booking decision. The responsible shipper and qualified dangerous-goods parties must confirm the actual shipment under the rules in force.

Prototype, Low Production and Commercial Sample Are Not the Same

Business language is often broader than dangerous-goods terminology. A sales team may call the first ten units “prototypes,” while an engineering team may call a near-final unit a pilot-production sample. Neither description by itself proves eligibility for a transport exception.

Pre-production prototype transported for testing

The air pathway summarized by IATA is tied to purpose: the pre-production prototype is being transported for testing. The shipper should be able to identify the test activity, receiving organization and design revision, and explain why the untested unit must move before completion of the normal design-type testing process.

A unit sent to a distributor for demonstration, to a buyer for routine evaluation or to a customer for sale is not automatically a prototype transported for testing. The words on the invoice do not decide the transport status.

Low-production cell or battery

Low production is a separate category. In its interpretation of the U.S. Hazardous Materials Regulations, PHMSA Interpretation 24-0070 explains that prototype and low-production cells or batteries are not the same. It defines the U.S. low-production limit as an annual production run of no more than 100 lithium cells or batteries. PHMSA also clarifies that this is a production limit, not a limit of 100 units per shipment or per year of air shipments.

That PHMSA interpretation is U.S.-specific and fact-specific. It should not be copied into an international shipment decision without checking the modal and national rules that actually apply. It is useful because it highlights the evidence problem: the shipper must document how many units of the relevant type are produced in the annual run, rather than counting only the units in the package.

Commercial or engineering sample

“Sample” describes a commercial or operational use, not necessarily a regulatory category. A sample could be:

• a tested battery from ordinary production;
• an untested pre-production prototype moving to a laboratory;
• a unit from a limited annual production run;
• a product containing a tested battery but lacking the correct test summary;
• a used evaluation unit; or
• an item with damage or another special condition.

The correct path depends on the facts behind the label. Do not choose an exception because the shipment quantity is small.

Check the UN 38.3 Status Before Looking for an Exception

The ordinary starting point is the exact design type. According to IATA's 2026 guidance, lithium cell and battery design types are generally required to pass the applicable tests in Part III, subsection 38.3 of the UN Manual of Tests and Criteria. The same guidance also describes changes that may create a new design type requiring renewed testing, including material changes, changes in safety or protective systems, changes in the number or connection of component cells, and certain changes in energy or voltage.

Before treating a unit as untested, ask the manufacturer for:

• manufacturer name and contact details;
• exact cell or battery model;
• chemistry, nominal voltage, rated capacity and Watt-hour rating or lithium content;
• mass and physical description;
• design revision and production status;
• the applicable test report and test-summary reference, if testing has been completed;
• details of changes from any tested predecessor; and
• the person responsible for confirming the design/test status.

The missing document and the missing test are different problems.

If the design type has passed the applicable tests but the shipper cannot locate the summary, the first task is to obtain and match the correct evidence. The separate UN 38.3 test summary guide explains what the summary should identify. An SDS, product specification, invoice or old airway bill does not replace the test summary.

If the design type has not completed the applicable testing, the shipper must determine whether a genuine prototype or low-production pathway exists. Do not create an exception claim to compensate for weak document control.

Air Transport: A88 and PI 910 Form an Approval Path, Not a Shortcut

The 2026 IATA guidance is based on the 2025–2026 edition of the ICAO Technical Instructions and the 67th Edition of the IATA Dangerous Goods Regulations. It states that untested pre-production prototypes transported for testing, or qualifying low-production runs, may be transported aboard cargo aircraft if:

• the appropriate authority of the State of Origin approves;
• the appropriate authority of the State of the Operator approves; and
• the requirements of Packing Instruction 910 in the Supplement to the ICAO Technical Instructions are met under Special Provision A88.

The ICAO Technical Instructions page confirms that the 2025–2026 edition applies to operations from 1 January 2025 through 31 December 2026 and provides links to State variations, addenda, corrigenda and errata. These current materials must be checked for the proposed shipment date.

Several consequences follow from this structure.

The route is cargo-aircraft only under the public guidance

The A88 pathway summarized by IATA is described for cargo aircraft. It must not be presented as ordinary passenger-aircraft eligibility. A route search should therefore begin with actual cargo-aircraft options and their handling chain, not with a generic passenger-flight schedule.

Both named State approvals matter

IATA defines the State of Origin as the country in which the consignment is first loaded on an aircraft. The State of the Operator is the country where the operator's principal place of business is located, or its permanent residence if it has no principal place of business.

Those definitions mean that the relevant authorities cannot be inferred only from the battery manufacturer's country or the final destination. The proposed operator and routing must be known before the approval analysis is complete.

PI 910 is not replaced by a web checklist

The applicable packing instruction and written approval conditions control the preparation. A public article should not reconstruct proprietary packaging requirements or encourage an untrained shipper to build a package from a short list.

The responsible parties must work from the current official instructions. Package type, performance, inner protection, restraint, quantity and mass limits, marks, labels, documents and other conditions must match the approved shipment.

Classification and configuration still matter

“Prototype battery” does not identify whether the cell or battery is lithium-ion or lithium metal, or whether it is shipped alone, packed with equipment or contained in equipment. The shipment description must reflect the actual chemistry and configuration. It must also disclose other facts that could change the pathway, including condition, state of charge where applicable, use, waste or recycling status.

State Approval Does Not Equal Airline Acceptance

A State approval answers a regulatory question under a specified provision. Airline acceptance is a separate operational and commercial decision.

Even when both required authorities issue written approvals, the shipment may still require review by:

• the airline or aircraft operator;
• the booking agent or freight forwarder;
• the origin airport and cargo terminal;
• the ground handler;
• transit airports and transfer handlers;
• customs and other national authorities; and
• the destination agent and final-delivery parties.

An operator variation may be stricter than the baseline rule. An airline may also decline the shipment because its network, aircraft, handling capability or internal policy does not support the movement.

To prevent contradictions, the approval request, written decision, packing records, dangerous-goods documents and booking description should identify the same manufacturer, design revision, chemistry, configuration, quantity, package and route. An approval for one prototype, operator or origin should not be assumed to cover a changed design, another route or another shipper.

BAT Logistics can review customer- or manufacturer-supplied information for obvious logistics gaps and coordinate a shipment-specific enquiry with relevant freight and operating parties. BAT does not test the battery, decide exception eligibility for an authority, issue State approvals, compel airline acceptance or guarantee carriage.

Sea Transport Uses a Separate Current IMDG Review

Air provisions do not govern an international ocean shipment. Sea transport uses the International Maritime Dangerous Goods Code together with national implementation and the requirements of the actual port, terminal, vessel operator, carrier and inland legs.

The IMO IMDG Code publication page states that the 2024 Edition incorporating Amendment 42-24 is mandatory from 1 January 2026 and that the 2024 Supplement supersedes the 2022 edition.

For a prototype or low-production battery, a qualified maritime review should identify the applicable special provision and packing instruction in the licensed current Code. This article does not name or reconstruct a maritime packing pathway without verifying that text against the exact battery and sailing.

The maritime review should establish:

• exact battery chemistry and proposed UN entry;
• whether the battery is alone, packed with equipment or contained in equipment;
• design/test status and the supported prototype or low-production basis;
• physical and operating condition;
• cell/battery and package quantities;
• package type, performance and evidence;
• required marks, labels, documents and declarations;
• container loading and stowage information where applicable;
• origin port, transshipment ports and destination port;
• first- and last-mile national requirements; and
• written acceptance from the required operating parties.

A refusal by an airline does not establish that an ocean route is permitted. Conversely, an air A88 approval does not authorize the sea movement. The shipping batteries by sea guide covers the commercial maritime-planning path after eligibility and preparation questions have been resolved.

Road, Rail and Domestic Rules Do Not Transfer Automatically

Prototype and low-production rules are implemented through particular modal and national frameworks. A conclusion under one system should not be carried into another without checking the law that governs the segment.

For example, PHMSA Interpretation 24-0070 explains how the U.S. HMR treats the distinction between prototype and low-production batteries under 49 CFR 173.185(e). It does not decide an international air movement under a different State's law, an ocean shipment under the IMDG Code, or a European road or rail movement.

The first and last mile also require attention. A shipment that has an air or sea pathway may still encounter different conditions for road collection in China, transit handling and delivery in the destination country. The shipment plan should identify each controlled leg rather than assuming that the main-carriage approval covers the whole journey.

Information Needed for a Prototype or Low-Production Review

A strong enquiry begins with one controlled shipment record. It should connect the design, purpose or production basis, condition, package and route.

Battery and product identity

• manufacturer and exact cell or battery model;
• chemistry;
• nominal voltage and rated capacity;
• verified Watt-hour rating for lithium-ion batteries or lithium content for lithium metal batteries;
• battery mass and physical dimensions;
• product manufacturer and model when packed with or contained in equipment;
• standalone, packed-with-equipment or contained-in-equipment configuration;
• design revision, drawing or specification identifier; and
• clear photographs linking the rating plate and battery to the supplied records.

Test and status evidence

• whether the design type has completed the applicable UN 38.3 tests;
• available test report or test-summary reference;
• explanation of any difference from a tested predecessor;
• confirmation that the unit is new, stable and not damaged, defective or safety-recalled;
• used, returned, waste or recycling status, if any; and
• manufacturer contact responsible for the technical information.

Prototype-for-testing evidence

• written purpose of the movement;
• test plan or concise description of the intended testing;
• receiving test organization and delivery location;
• design revision and number of units involved;
• reason transport is required before completion of ordinary design-type testing; and
• responsible manufacturer or shipper statement supporting the category.

Low-production evidence

• exact cell or battery type;
• annual production period;
• documented number produced in that annual run;
• production records or responsible manufacturer statement; and
• confirmation that the claimed threshold is evaluated under the rule that actually applies.

Do not use the number in one package as proof of annual low production.

Package and route information

• cell/battery count per product, package and shipment;
• proposed inner and outer packaging;
• package count, dimensions and gross weights;
• net battery weight where relevant;
• package-performance, closure and packing records;
• current state of charge for air where applicable and the source of that record;
• China pickup point and responsible shipper;
• proposed origin airport or seaport;
• destination airport or seaport, country and final delivery point;
• cargo-ready date and proposed operator or carrier; and
• authority correspondence, approvals or carrier instructions already obtained.

The wider lithium battery shipping documents checklist can help organize the file. Each record still needs to identify the same battery type and shipment.

Packaging Evidence Must Follow the Applicable Written Pathway

Prototype and low-production packaging is not a generic “strong box” exercise. The package must follow the current modal instruction and any written approval conditions for the exact shipment.

At a planning level, the evidence should show how the proposed package addresses:

• protection against short circuit;
• protection of terminals and exposed conductive parts;
• prevention of unintended activation where equipment is involved;
• secure restraint against movement;
• protection against impact, vibration and damage during normal transport;
• separation or inner protection required by the applicable pathway;
• compatible cushioning and containment materials;
• package type, performance standard and permitted limits;
• closure method and preparation responsibility; and
• traceability between the packed unit, photographs, records and approval.

These are review headings, not packing instructions. The approved design, current regulation and qualified packing process control the work. If the battery shows swelling, leakage, overheating, deformation, impact damage or another suspected safety defect, stop the ordinary prototype process and use the damaged, defective and recalled lithium battery guide for condition triage.

Common Prototype-Shipping Mistakes

Calling every early product a prototype

An invoice description or internal product-stage name does not prove that the battery is a pre-production prototype transported for testing.

Confusing the test purpose with commercial evaluation

A demo, sales sample or customer evaluation may have a different purpose. Record what the receiving party will do and why the untested design must move.

Treating 100 as a per-shipment allowance

Under the cited U.S. PHMSA interpretation, low production refers to an annual production run, not the number offered in one shipment. The applicable rule and production evidence must be checked.

Seeking an exception when only the document is missing

If the design type has passed UN 38.3, locate and match the correct test summary. Do not represent a tested type as an untested prototype because the file is disorganized.

Assuming State approval guarantees carriage

Authority approval and airline acceptance are different decisions. Operator, airport, handler and route conditions still apply.

Applying an air decision to sea transport

A88 and PI 910 are air references. Sea transport requires a current IMDG review and separate carrier/port acceptance.

Reusing evidence for a changed design

A change in chemistry, energy, voltage, component cells, connection method, protective systems, software or safety design may affect the relationship to the tested or approved type. Recheck rather than assuming continuity.

Omitting uncomfortable status information

Used, returned, damaged, defective, recalled, waste or recycling status can change the pathway. It should be disclosed before a route is proposed.

Treating an SDS as approval

An SDS may provide useful product and hazard information, but it does not establish prototype eligibility, UN 38.3 status, State approval, correct packaging or operator acceptance.

Assuming last year's shipment proves today's acceptance

Rules, addenda, State variations, operator policies, routes, handling networks and the battery design itself can change. Review the actual shipment date and route.

A Pre-Enquiry Decision Checklist

Before asking a forwarder or carrier for a route, confirm that:

1. the exact cell or battery model, chemistry and configuration are identified;
2. the applicable UN 38.3 status has been checked;
3. the unit is genuinely an untested prototype transported for testing or part of a supported low-production run;
4. the battery is outside the damaged, defective and recalled pathway;
5. the current rule for every proposed transport mode is identified;
6. the authorities named by any approval pathway are known;
7. the proposed operator or carrier has been identified for its separate review;
8. the package proposal and supporting evidence follow the applicable written pathway;
9. all documents describe the same design revision, quantity, package and route; and
10. no booking, transit-time or delivery promise has been made before acceptance.

If one of these items is unknown, mark it as an open issue. A visible gap is safer than an unsupported assumption embedded in a booking request.