Altor guide · 2026-08-26

Lithium batteries: the rules that moved and the templates that did not

The SKU is the same one you sent last quarter. The Word file still fills the UN number, the packing instruction, and the additional handling notes. The rest of the freight is booked on a passenger aircraft, so the lithium line is booked there too. Then the acceptance desk at the cargo terminal stops the consignment. The current list forbids that entry on passenger aircraft. The packing instruction on the paper belongs to a different lithium line.

That is the lithium pattern. The regulations moved. The saved template did not.

What the regulation actually requires

Lithium cells and batteries are not one dangerous goods line. ICAO TI Table 3-1, implemented in the IATA DGR List of Dangerous Goods in Section 4.2, splits them by chemistry and by how they travel.

UN 3480 is lithium ion batteries shipped on their own, including lithium ion polymer batteries. Class 9. No packing group. Passenger aircraft: forbidden. Cargo aircraft: packing instruction 965. Quantity limits for that entry live inside the packing instruction, not in a single table cell.

UN 3481 is two entries, not one. Lithium ion batteries contained in equipment use packing instruction 967, 5 kg per package on passenger aircraft and 35 kg on cargo aircraft. Lithium ion batteries packed with equipment use packing instruction 966, same 5 kg passenger and 35 kg cargo limits. Packed with is not contained in.

UN 3090 is lithium metal batteries shipped on their own, including lithium alloy batteries. Passenger aircraft: forbidden. Cargo aircraft: packing instruction 968. UN 3091 splits the same way as UN 3481. Contained in equipment is packing instruction 970. Packed with equipment is packing instruction 969. Both carry a 5 kg passenger maximum and a 35 kg cargo maximum.

Those UN numbers, packing instructions, forbidden flags, and quantity limits come from the current ICAO TI Table 3-1 extract. IATA DGR Section 5 is the packing instruction text, including any state of charge statement the current edition requires. IATA DGR 8.1.6.9 is how nature and quantity go onto the Shipper's Declaration. IATA DGR 9.1.3 is the acceptance check the operator will run against the paper and the box.

For a US originating air shipment, 49 CFR 172.202 still governs the basic description. 49 CFR 173.27 is the aircraft packaging and quantity rule. 49 CFR 175.30 is the operator's inspection and acceptance duty. 49 CFR 173.185 is the US lithium cells and batteries packaging section. State variation US 3 is listed against the lithium ion entries. Lithium metal entries also list US 2. Confirm those variations against the current edition for this route before tender.

The IATA DGR 67th Edition, effective 1 January 2026, made the 30 percent state of charge limit mandatory for UN 3480 air shipments, and extended state of charge requirements to certain UN 3481 packed with equipment consignments. The current packing instruction is the controlling text. A template that still treats that statement as optional is not current.

The mistake people make

Desks reuse last year's lithium form.

The SKU went as UN 3481 packing instruction 967, so this consignment does too, even though this time the batteries are packed with the equipment, which is packing instruction 966. Spare packs go out as UN 3480 on the passenger flight the rest of the freight occupies, even though UN 3480 is forbidden on passenger aircraft. The additional handling information still carries notes copied from an older packing instruction. The state of charge line is blank, or it describes last quarter's similar lot.

Section 14 of the safety data sheet is not a substitute. An SDS can say lithium ion batteries and still not tell you whether this consignment is UN 3480, UN 3481 packed with equipment, or UN 3481 contained in equipment. 49 CFR 173.22 still lands on the shipper. The operator is working from the current edition, not from the edition your template was built under.

Marks make it worse. A lithium battery handling label from a previous print run, or a cargo aircraft only mark missing from a UN 3480 package, fails IATA DGR 9.1.3 even when the UN number is right. IATA DGR Section 7 is marks and labels. 49 CFR 172.400 is the US label rule. Disagreement between the box and the paper parks the freight.

How to fix it

Rebuild the lithium template from a blank form against the current list. Do not clone last year's file.

Start with chemistry: lithium ion or lithium metal. Then configuration: batteries alone, packed with equipment, or contained in equipment. Write the UN number and proper shipping name that pair actually maps to on the current IATA DGR Section 4.2 list. Then choose passenger or cargo aircraft, and only then write the packing instruction and the net quantity.

If the entry is UN 3480 or UN 3090, do not book a passenger aircraft. If the entry is packed with equipment, do not use the contained in equipment packing instruction. Read the current packing instruction in IATA DGR Section 5 for the state of charge statement, the part of the instruction that actually applies, and the quantity limit for that part. Enter package count and net quantity per IATA DGR 8.1.6.9.2.

Walk the packages against the paper. Confirm US 3, and US 2 for lithium metal, against the current state variations for this route. If you cannot stand behind a line under 49 CFR 172.204 and IATA DGR 8.1.6.12, fix the line.

A longer walkthrough of the 2026 state of charge change sits at https://altor.consulting/lithium-2026.html.

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