Lithium Batteries by Air in 2026: What Changed on 1 January

Which of Six Entries You Are On Decides the Rest

A lithium cell does not become less energetic because you put it inside the product you are selling, and the rulebook knows that. Six entries carry almost everything an exporter ships in this family, and the split between them is not about chemistry marketing — it is about whether the battery, the equipment, or both are on the air waybill.

• UN3480 — lithium ion batteries and cells travelling on their own: replacement packs, packs shipped to a service network, and the item sellers most often mislabel, a power bank, which is judged as a battery rather than as a device.
• UN3481 — the same chemistry contained in equipment, or packed with it: a vacuum cleaner with its cell installed, a tool shipped alongside a spare pack.
• UN3090 and UN3091 — the lithium metal pair, split the same way between loose and in-equipment.
• UN3551 and UN3552 — where the battery rides with a vehicle, contained in it or packed with it.

All six sit in Class 9, the miscellaneous class, which is why a quote that says simply “Class 9 accepted” has answered nothing. The class is the outer wall of the field; the entry, the packing instruction and the section decide whether your carton can be loaded at all.

The 30 Per Cent Rule Stopped Being a Polite Suggestion

State of charge is the change that reached furthest into ordinary shipments when the 2026 edition of the Dangerous Goods Regulations came into force on 1 January. Where a shipment of loose ion cells or batteries goes under packing instruction 965, a charge above 30 per cent of rated capacity has long required something unusual: the written agreement of both the state of origin and the operator performing the flight. That escape hatch is narrow and is not a plan.

What moved in this cycle is instruction 966, which covers batteries packed with or contained in equipment. The 30 per cent ceiling became mandatory on its Section I limb on the same date, and it reaches the Section II limb too for anything above 2.7 watthours — which is to say, effectively every consumer pack worth shipping. Instruction 967 keeps the figure as a recommendation rather than a rule.

Read those three together and the operational consequence is one sentence: the state your cells leave the factory in is now a compliance parameter, not a quality preference. A battery finished at full charge, tested at full charge, and packed at full charge has to be discharged before it can fly, and discharge costs days and a documented step somebody has to own.

Cargo Aircraft Only Is a Shape of Business

Loose cells and batteries are forbidden on passenger aircraft. That prohibition does not soften with a smaller carton or a friendly handler; it moves the goods onto the freighter network, and the freighter network has its own geography — fewer destinations, fewer frequencies, and connections that route through a hub with more handling than the passenger flight would have had.

The handling concept brings a label of its own, the cargo-aircraft-only marking, and per-package ceilings that step down as you move from freighter-only treatment toward limited quantities; the three figures that recur across the instruction set are 35, 10 and 5 kilograms of net battery. Which one applies to your shipment is a property of the instruction and section, not of your preference, and a package that gets the label without the matching weight is exactly the kind of inconsistency a terminal inspection stops.

There is a small, genuine exemption worth knowing because it appears in almost every electronics shipment: certain battery-powered data recorders, provided the energy of the consumable cell is no more than 20 watthours, are handled outside the dangerous-goods provisions. Sellers have stretched that sentence to cover far more than it carries. If your routing plan rests on it, get the wording of the provision in writing rather than a colleague’s recollection.

Watthours, Lithium Content, and the Two Questions in Order

Which limb of which instruction applies is decided by numbers on a datasheet, and the two questions come in a fixed order.

The error pattern is consistent. A buyer states the pack capacity in milliamp-hours because that is what the product page says, and nobody converts it. A shipment that reads as unremarkable at 10,000 mAh becomes a Section I problem at 38.5 Wh, or a Section II opportunity at 9.9 Wh, depending on figures nobody checked.

What the Rulebook Does Not Decide

Three layers sit on top of the regulations and each can veto a shipment the rulebook permits.

1. The operator. An airline may refuse a class, an instruction, or a lane, and the annual edition records operator-specific variations rather than smoothing them away.
2. The state of origin and the state of transit. A routing that changes aircraft in a jurisdiction with its own restrictions inherits them.
3. The edition. This rulebook is superseded every 1 January and does not grandfather what you shipped last year. The edition after the current one is already in preparation, and it reorganises how battery-powered vehicles are described, which is a reminder that forward-dated assurances about a lane age badly.

The practical control is a small one. Ask, in writing, for the UN entry, the packing instruction, the section, the state of charge assumption and the operator acceptance for the specific flight — then re-ask it after each new year rather than assuming the answer transfers.

Four Things to Settle Before a Battery Shipment Is Booked

• Who measures and records the state of charge, and where that record lives once the goods have left the site.
• Who prepares the shipper’s declaration and who checks it — a declaration reviewed after the truck has gone is not a control.
• Which document set proves the cell was tested to the UN Manual of Tests and Criteria, since that summary is what an operator or authority asks for first.
• What the fallback is if the freighter capacity is not there in the week you need it: the slower mode, the split shipment, or the deferred launch, priced before the season rather than during it.

Every transit figure attached to a battery shipment is an estimate; freighter schedules, terminal screening and the acceptance queue all move with capacity and season, and nothing here is a promise about a specific flight. On the desks we run, a shipment of this kind is quoted from the documents rather than from the product name: the entry, the instruction, the section and the owner of each paper first, then the routing, then the days. Send the datasheet and the packing configuration and you get back which limb of which instruction your goods fall under — including the answer that they do not belong on the lane you had planned.