Altor guide · 2026-09-19

Lithium battery state of charge 30 percent UN 3480, explained for shippers

The spare packs are on the dock at 80 percent. The rest of the freight is already booked. Someone searches lithium battery state of charge 30 percent UN 3480 because last quarter's similar lot flew, or because a carrier page mentioned 30 percent and the work instruction still says ship as received. The acceptance desk at the cargo terminal does not grade intent. It grades this consignment against the current packing instruction.

What the regulation actually requires

Lithium ion batteries shipped on their own are UN 3480, Class 9, no packing group. Passenger aircraft: forbidden. Cargo aircraft: packing instruction 965. Those figures come from the current ICAO TI Table 3-1 extract. Quantity limits live inside packing instruction 965, not in a blank cargo cell. Excepted quantity is E0. State variation US 3 is listed. Open the current United States variation in IATA DGR 2.8 for this route.

The 30 percent limit is not a carrier preference. For air, IATA DGR packing instruction 965 is where UN 3480 state of charge lives: cells and batteries offered at a state of charge not exceeding 30 percent of rated capacity. For a US originating air offering, 49 CFR 172.102 special provision A100 is the matching US aircraft rule. Cells above 30 percent move only under the approval path in that provision, not because the booking portal accepted the UN number.

49 CFR 173.185 is the US lithium packaging section. 49 CFR 173.22 still puts classification, description, packaging, marks, and labels on the offeror. 49 CFR 172.202 is the basic description. For air, IATA DGR 8.1 is the Shipper's Declaration, IATA DGR 8.1.6.9 is nature and quantity, and IATA DGR 8.1.6.12 plus 49 CFR 172.204 are the certification. 49 CFR 172.204(c)(3) adds that the applicable air transport requirements have been met, including state of charge when the packing instruction or A100 requires it. 49 CFR 175.30 and IATA DGR 9.1.3 are acceptance.

UN 3481 is a different line. Packed with equipment is packing instruction 966, 5 kg passenger and 35 kg cargo. Contained in equipment is packing instruction 967 at the same mass limits. Writing 967 on a packed with consignment is the wrong instruction. The 67th Edition of the IATA DGR, effective 1 January 2026, made the 30 percent state of charge limit mandatory for certain UN 3481 packed with equipment consignments under packing instruction 966. Section I of that instruction now requires the limit. Section II requires it when the cells or batteries exceed the watt hour rating in the current instruction. That is the 2026 change people keep pinning on UN 3480. UN 3480 already had the limit. Packed with equipment is what moved from recommendation to requirement.

The current packing instruction is the controlling text, including whether the Shipper's Declaration needs a state of charge statement for this consignment. PHMSA has proposed aligning more of the US table with the same 30 percent air limit. Until that change is in 49 CFR, do not assume highway silence equals air silence.

A short landing page on the 2026 change sits at https://altor.consulting/lithium-2026.html.

The mistake people make

They leave the cells on the charger, then fill packing instruction 965 from last year's file.

They book UN 3480 on the passenger aircraft that is carrying the rest of the freight. The passenger column is forbidden before anyone asks about charge. They copy a UN 3481 packing instruction 967 line onto spare packs that are not in the equipment. Packed with is 966. Alone is 3480 and 965.

They write a state of charge sentence that describes last quarter's similar SKU. IATA DGR 9.1.3 walks this consignment. They treat Section 14 of the SDS as the charge record. An SDS can say lithium ion and still not tell you whether these cells are at 30 percent today.

They call 30 percent a 2026 novelty on UN 3480. For batteries shipped alone, packing instruction 965 and A100 already had the limit. They skip US 3. They skip Cargo Aircraft Only on a UN 3480 package. They put the generic miscellaneous Class 9 diamond on fibreboard that wants the lithium batteries Class 9 label.

Lithium battery state of charge 30 percent UN 3480: how to fix the line

Rebuild the lithium line from a blank against the current IATA DGR Section 4.2 list.

Chemistry first: lithium ion or lithium metal. Then configuration: batteries alone, packed with equipment, or contained in equipment. UN 3480 is batteries alone. Do not book a passenger aircraft. Write packing instruction 965. Read the current instruction in IATA DGR Section 5 for the part that applies, the quantity limit in that part, and the state of charge condition. Confirm the cells are actually at or below 30 percent of rated capacity. If the current instruction requires a statement on the Shipper's Declaration, write it for this consignment.

If the batteries are packed with the equipment, that is UN 3481 packing instruction 966, not 967, and not 965. Read packing instruction 966 for the 30 percent condition that became mandatory on 1 January 2026, including the watt hour split between Section I and Section II.

Walk the carton against the paper in IATA DGR 9.1.3 order. Cargo Aircraft Only when passenger carriage is forbidden. Lithium batteries Class 9 label, not the striped miscellaneous Class 9. Confirm US 3 against the current variation for this route. Then sign under 49 CFR 172.204 and IATA DGR 8.1.6.12.

Altor pre-checks completed Dangerous Goods Declarations line by line against the current regulations and returns a written report, with every finding cited, within one business day. You keep the pen. altor.consulting

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Send your completed declaration before you tender it. A line by line advisory report comes back within 24 hours, every finding cited. $95 flat, one click, and you keep the pen.

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