Lithium Battery Shipping by Air: The 30% State of Charge Rules in 2026

The state of charge limit for lithium-ion batteries shipped alone by air is not new. It has been mandatory for UN3480 since 2016. What changed on January 1, 2026 is the rule for batteries packed with equipment. Under the ICAO Technical Instructions (2025-2026 edition), as applied in the 67th edition of the IATA Dangerous Goods Regulations from January 1, 2026, lithium-ion cells and batteries shipped as UN3481 packed with equipment under Packing Instruction 966 must now be at a state of charge not exceeding 30% of rated capacity, and that includes Section II batteries above 2.7 Wh.

The change catches consumer electronics, power tool, medical device and e-mobility shippers who assumed that a battery traveling in the same box as its device was outside the charge rules. It is not. Batteries contained in equipment, and Section II packed-with batteries of 2.7 Wh or less, remain outside the mandatory limit, and for contained-in batteries the 30% figure applies as a recommendation. This guide covers the UN numbers and packing instructions behind lithium battery shipping by air, the January 2026 packed-with rule, the medical device exception, and what forwarders need on file before a booking is accepted.

UN3480, UN3481 and UN3091: The Basic Classifications

Every lithium battery shipment starts with a UN number, and the UN number decides which packing instruction applies. For lithium-ion, UN3480 covers cells and batteries shipped on their own, and UN3481 covers cells and batteries packed with equipment or contained in equipment. For lithium metal, UN3090 covers batteries on their own and UN3091 covers batteries packed with or contained in equipment. Sodium-ion batteries have their own entries in the international air rules, UN3551 and UN3552 (proposed for the US HMR in HM-215R), and should not be shipped under a lithium entry.

Under the IATA Dangerous Goods Regulations, the lithium-ion entries map to three packing instructions. PI 965 covers UN3480, batteries on their own. PI 966 covers UN3481 packed with equipment, meaning the battery travels in the same package as the device but is not installed in it. PI 967 covers UN3481 contained in equipment, meaning the battery is installed in the device it powers.

The distinction between packed with and contained in is where most errors start. A laptop with its battery installed is contained in. A laptop shipped with a spare battery in the same carton is contained in for the installed battery and packed with for the spare. A power tool kit with two batteries in separate compartments of the case and none fitted to the tool is packed with. The classification follows how the battery is physically presented, not how the product is sold.

The January 1, 2026 Packed-With State of Charge Rule

The ICAO Technical Instructions (2025-2026 edition) extended the 30% state of charge limit from standalone batteries to batteries packed with equipment. The IATA Dangerous Goods Regulations introduced it as a recommendation in the 66th edition for 2025 and apply it as mandatory in the 67th edition from January 1, 2026. From January 1, 2026, lithium-ion cells and batteries shipped under PI 966 must be offered for air transport at a state of charge not exceeding 30% of their rated capacity.

The rule reaches Section II shipments as well, specifically batteries above 2.7 Wh. Section II is the lighter regime for smaller cells and batteries shipped within per-package quantity limits, and many shippers treated it as outside the charge rules altogether. For packed-with batteries above 2.7 Wh, that is no longer true. A typical power tool battery or a spare laptop battery is well above that threshold.

State of charge is set at the factory or the last point where the battery is charged, not at the forwarder’s warehouse. Manufacturers who ship devices with spare batteries at full charge for customer convenience need to change the charging step in production or packing for air shipments, or move those shipments to a mode where the air rule does not apply. The forwarder can check the paperwork, but it cannot discharge a pallet of batteries at the airport.

Standalone Batteries: The 30% Limit Since 2016

The limit on UN3480 is ten years old, and it is worth restating because the 2026 coverage has blurred it. Since 2016, lithium-ion cells and batteries shipped on their own under PI 965 have had to be at a state of charge not exceeding 30% of rated capacity. The 2026 change did not introduce this rule or alter it; it extended the same number to a second configuration.

Shippers of replacement batteries, battery packs for assembly, and battery modules sent for repair or recycling are in this category. Their compliance program should already include state of charge records and a factory procedure that sets and records the charge level. If it does not, the gap predates 2026 and is larger than the new rule.

Since January 1, 2026, vehicles powered by lithium-ion or sodium-ion batteries above 100 Wh shipped under PI 952 must be offered at a state of charge not exceeding 30%, or an indicated battery capacity not exceeding 25%. Below 100 Wh the limit is only recommended. E-mobility shippers moving scooters, e-bikes and similar vehicles by air should confirm which packing instruction applies to each product and set the state of charge accordingly.

Contained in Equipment: Still a Recommendation

The one configuration that remains outside the mandatory limit is UN3481 contained in equipment under PI 967. Here the 30% state of charge is a recommendation, not a requirement. A device with its battery installed can still be shipped by air at a higher charge.

That creates a practical temptation to install the battery before shipping to stay out of the packed-with rule. Where installing the battery reflects how the product is actually sold and used, that is a legitimate classification. Where it is done only to change the paperwork, the shipper should consider whether the configuration is stable in transit, and whether it matches the product description on the commercial invoice.

Whether PI 967 will move from recommendation to requirement, and when, has not been confirmed. No mandatory date has been published in the sources we reviewed. Shippers with large contained-in volumes should watch for it rather than plan around a date that does not yet exist.

Medical Device Batteries: The Exception

Medical device shippers operate under a narrower set of exceptions, and in the United States the reference is 49 CFR 173.185, the Hazardous Materials Regulations section on lithium cells and batteries. Batteries contained in devices are classified as UN3481 for lithium-ion and UN3091 for lithium metal, and there are lithium battery mark exemptions for small consignments of batteries in equipment under 173.185(c)(3).

Two provisions matter specifically for medical devices. Under 173.185(g), up to two replacement lithium cells or batteries for a medical device may be carried as cargo on a passenger aircraft, with approval from PHMSA’s Associate Administrator, where the destination does not have daily cargo service. Under the same provision, those replacement lithium-ion cells or batteries are excepted from the Special Provision A100 state of charge limit if each is individually packed in an inner packaging that fully encloses it, placed in a rigid outer packaging and protected against short circuits.

Both provisions are exceptions with conditions, not general exemptions for anything sold as medical equipment. A device manufacturer relying on either should hold the specific approval or the documented basis for the exception with the shipment file. For device importers, these logistics questions sit alongside the regulatory ones covered by our FDA initial importer services.

Documentation Forwarders Need Before Booking

Air carriers and forwarders accept or reject lithium battery shipments on documents, and the documents have to be ready before the booking. For each shipment, the forwarder needs the UN number, the packing instruction, the section (Section I or Section II where applicable), the watt-hour rating for lithium-ion or lithium content for lithium metal, the test summary for the cell and battery type, and confirmation that the batteries meet the 30% state of charge limit for PI 965 and PI 966 shipments (certified on the Shipper’s Declaration for Section I, and often requested in writing by carriers for Section II).

State of charge confirmation is the item most often missing in 2026. IATA does not require a separate state of charge document, but the Shipper’s Declaration certifies that all applicable requirements have been met, and carriers often ask for a written statement on packed-with shipments. Either has to reflect how the batteries were actually prepared. Certifying 30% on batteries that left the factory at full charge is a false dangerous goods declaration, and the consequences of that fall on the shipper.

Getting this right is ordinary work for a forwarder handling import and export services with dangerous goods. The review happens at booking: classify the configuration, confirm the packing instruction, check the state of charge confirmation and the test summary, and reject or reroute anything that does not fit, before cargo reaches the airport.

• UN number and packing instruction for each battery configuration in the shipment.
• Section I or Section II, and watt-hour rating per battery.
• Test summary for each cell and battery type.
• State of charge confirmation (30% or less) for PI 965 and PI 966 shipments.
• Specific approvals or exception basis for medical device batteries.

When Air Stops Making Sense: Routing to Ocean

For some shippers the cheapest compliance answer is a different mode. Changing the factory charging step for air shipments has a cost, and for replenishment stock that is not time-critical, ocean freight removes the air-specific limit from the question. The dangerous goods rules for ocean still apply, but the IATA state of charge requirements are an air transport rule.

The decision should be made on the full cost of each option, not the freight rate alone. Inventory carrying cost, the time value of stock on the water, and the cost of modifying production for air-compliant charge levels all belong in the comparison, alongside the duty and fees in a landed cost model. Battery products also carry their own duty history, set out in our overview of EV and battery tariffs, and that side of the landed cost does not change with the mode.

Mode also affects the regulatory calendar. PHMSA’s HM-215R rulemaking, published in the Federal Register on February 10, 2026, is still only a proposal, so the US domestic rules have not yet been harmonized with every international change. Shippers moving batteries across several modes should check each leg against the rules that apply to it rather than assume one standard covers the whole move.

What Battery Shippers Should Do Now

Map every product line to its battery configuration: on its own, packed with, or contained in. For each packed-with line, confirm that the factory sets the state of charge at 30% or below for air shipments and records it, and that the confirmation travels with the shipment.

Then review the edge cases. Section II packed-with batteries above 2.7 Wh are now inside the rule. Vehicles under PI 952 with batteries over 100 Wh carry the 30% limit (or 25% indicated capacity). Sodium-ion products need their own UN numbers. Medical device shipments relying on an exception need the approval or documented basis in the file.

Finally, align the booking process so that no lithium battery shipment is accepted without the documents listed above. A licensed customs brokerage and forwarding team that sees the battery data at booking can catch the problems that otherwise show up as a rejected pallet at the airport, and a trade compliance management program keeps the configuration and charge data on each SKU so the check is not rebuilt for every shipment.

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