What is the relationship between UN 38.3 and the IATA, IMDG, ADR and DOT regulations?

UN 38.3 is a test programme, not a transport regulation. It sits in sub-section 38.3 of the UN Manual of Tests and Criteria, and every lithium cell and battery design type must pass it before it can be shipped under the ordinary entries. The binding transport rules come from the modal texts: the ICAO Technical Instructions and the IATA Dangerous Goods Regulations for air, the IMDG Code for sea, ADR and RID for road and rail in Europe, and 49 CFR for the United States. All of them are built on the UN Model Regulations, and all of them require UN 38.3, then add their own packing instructions, quantity limits, marks, labels and documents.

Which UN numbers apply to lithium and sodium-ion batteries?

Lithium-ion batteries shipped alone are UN 3480; packed with or contained in equipment, UN 3481. Lithium metal batteries shipped alone are UN 3090; packed with or contained in equipment, UN 3091. Sodium-ion batteries with organic electrolyte have their own pair, UN 3551 alone and UN 3552 with equipment. Vehicles have separate entries: UN 3556 (lithium-ion powered), UN 3557 (lithium metal powered) and UN 3558 (sodium-ion powered), next to UN 3171 for other battery-powered vehicles. Batteries installed in a cargo transport unit, such as a containerised energy storage system, are UN 3536.

Is there still a Section II for lithium-ion batteries shipped alone by air?

No. IATA removed Section II from Packing Instruction 965 (UN 3480) and Packing Instruction 968 (UN 3090) in the 2022 edition of the Dangerous Goods Regulations, with a transition that ended on 31 March 2022. Small stand-alone batteries now travel under Section IB: forbidden on passenger aircraft, Cargo Aircraft Only label, Class 9 lithium battery label, and a limit of 10 kg per package for lithium-ion (2.5 kg for lithium metal). Section II still exists for batteries packed with equipment (PI 966, PI 969) and contained in equipment (PI 967, PI 970).

What changed for the 30 percent state of charge rule on 1 January 2026?

Lithium-ion batteries shipped alone (UN 3480, PI 965) have been capped at 30 percent state of charge since 2016. From 1 January 2026, under the 2025-2026 ICAO Technical Instructions, the cap also applies to lithium-ion batteries packed with equipment (PI 966): all Section I batteries, and Section II batteries above 2.7 Wh. Exceeding it needs an approval from the State of Origin and the State of the Operator (special provision A331). For batteries contained in equipment (PI 967), 30 percent, or an indicated battery capacity of 25 percent or less, is recommended but not mandatory. Vehicles powered by batteries above 100 Wh must also be shipped at 30 percent or 25 percent indicated.

Must the UN 38.3 Test Summary travel with every shipment?

No. Manufacturers and subsequent distributors of cells and batteries made after 30 June 2003 must make the Test Summary defined in paragraph 38.3.5 of the Manual available, and anyone in the supply chain may ask for it. The IATA 2026 lithium battery guidance states that a website link or QR code on the battery, its packaging or the transport documents satisfies the requirement, and that IATA does not support requiring a paper copy with each consignment. Button cells installed in equipment are exempt.

How are damaged, defective or waste lithium batteries shipped?

Batteries identified as damaged or defective under special provision 376 move under packing instruction P908, or P911 when they are liable to react dangerously under normal transport conditions. Batteries sent for disposal or recycling under special provision 377 use packing instruction P909. By air, damaged or defective batteries and those recalled for safety reasons are forbidden (special provision A154), and waste or recycling shipments need a State approval (A183). In practice that leaves road, rail and sea for returns.

What will change for lithium battery marks on 1 January 2027?

The lithium battery mark no longer needs a telephone number. Marks that still show the phone number were allowed under a transitional measure that ends on 31 December 2026. From 1 January 2027 the accepted mark carries the battery symbol and the UN numbers only, so label stock printed with a telephone field should be used up or replaced before the end of 2026.

Lithium battery shipping in 2026: IATA, IMDG, ADR, DOT

Hugues Orgitello updated 7 Oct 2026 16 min read

Moving a lithium battery legally comes down to four decisions: which UN number applies, whether the design passed UN 38.3, which packing instruction and section the energy rating and quantity put the package in, and which marks, labels and documents the chosen mode demands. Two of those answers changed recently. On 1 January 2026 the 30 percent state-of-charge cap, until then limited to batteries shipped alone, became mandatory by air for lithium-ion batteries packed with equipment. And on 31 December 2026 the last lithium battery marks printed with a telephone number stop being accepted. This guide rebuilds the whole chain from the texts themselves, the IATA 2026 guidance, the US Code of Federal Regulations and the UN Model Regulations, and lists the claims about these rules that still circulate and that the texts contradict.

TL;DR: Lithium-ion is UN 3480 alone and UN 3481 with equipment; lithium metal is UN 3090 and UN 3091; sodium-ion is UN 3551 and UN 3552. Batteries shipped alone can no longer go by air on passenger aircraft and have had no Section II since 2022. From 1 January 2026, lithium-ion packed with equipment (PI 966) must also be at 30 percent state of charge or less. Every design needs UN 38.3, and its Test Summary must be available on request, by link or QR code if you like. Phone numbers on the lithium battery mark are allowed only until 31 December 2026.

What changed, and what is about to

Date	Change	Text
1 April 2022	Section II deleted from PI 965 (UN 3480) and PI 968 (UN 3090); small stand-alone batteries move to Section IB	IATA DGR 63rd edition
1 January 2026	IMDG Code Amendment 42-24 mandatory (voluntary from 1 January 2025)	IMO resolution MSC.556(108)
1 January 2026	30 percent state of charge mandatory for PI 966 Section I, and for PI 966 Section II batteries above 2.7 Wh	ICAO Technical Instructions 2025-2026, IATA DGR 67th edition
1 January 2026	Battery-powered vehicles above 100 Wh by air: 30 percent state of charge, or indicated battery capacity of 25 percent or less	ICAO Technical Instructions 2025-2026, PI 952
1 January 2026	PI 967 (contained in equipment): 30 percent, or 25 percent indicated, recommended, not mandatory	IATA 2026 guidance
31 December 2026	End of the transition for lithium battery marks showing a telephone number	IATA DGR, ADR, IMDG Code, 49 CFR
2025	UN Model Regulations 24th revised edition published, with revised provisions for hybrid lithium-ion and sodium-ion batteries and new entries for batteries in equipment and in cargo transport units	UN Model Regulations Rev. 24

The modal texts follow the UN Model Regulations with a delay: the Model Regulations are revised every two years, ADR, RID and the IMDG Code follow on a two-year cycle, and the IATA DGR is reissued every year (the 67th edition applies in 2026). Check the edition in force on the date of shipment, not the one your template was written against.

Regulatory architecture

Layer	Text	What it sets
Base, classification	UN Model Regulations, 24th revised edition (2025)	UN numbers, special provisions, packing instructions P903 to P911, labels and marks
Base, testing	UN Manual of Tests and Criteria, 8th revised edition and its Amendment 1, sub-section 38.3	Tests T.1 to T.8, design-change rules, the Test Summary
Air	ICAO Technical Instructions 2025-2026, operationalised by the IATA DGR 67th edition (2026)	PI 965 to PI 970, passenger and cargo aircraft limits, state of charge, State and operator variations
Sea	IMDG Code Amendment 42-24	Special provision 188, stowage and segregation, container packing certificate
Road and rail, Europe	ADR 2025 and RID 2025	Special provisions 188, 230, 310, 376, 377, 636, 666, 670; vehicle and driver requirements
United States, all modes	49 CFR Parts 171 to 180, lithium rules in 173.185	Small-battery exception, highway and rail-only limits, damaged and recalled batteries

UN numbers

UN number	Proper shipping name	Typical case
UN 3480	Lithium ion batteries	Cells, battery packs and power banks shipped on their own
UN 3481	Lithium ion batteries contained in equipment / packed with equipment	A laptop; a power tool sold with a spare battery
UN 3090	Lithium metal batteries	Primary cells shipped on their own
UN 3091	Lithium metal batteries contained in equipment / packed with equipment	A data logger or smart meter with its primary cell
UN 3551	Sodium ion batteries with organic electrolyte	Sodium-ion cells and batteries on their own
UN 3552	Sodium ion batteries with organic electrolyte contained in equipment / packed with equipment	Sodium-ion powered equipment
UN 3536	Lithium batteries installed in cargo transport unit	Containerised battery energy storage
UN 3556	Vehicle, lithium ion battery powered	E-bikes, e-scooters, electric cars
UN 3557	Vehicle, lithium metal battery powered	Vehicles powered by lithium metal batteries
UN 3558	Vehicle, sodium ion battery powered	Vehicles powered by sodium-ion batteries
UN 3171	Battery-powered vehicle or battery-powered equipment	Vehicles whose battery is not covered by the three entries above

Two classification traps appear in the IATA guidance itself. A power bank is a battery, not equipment, so it is UN 3480 even if it has a torch. And a charger or cable is not "equipment" for PI 966: a box holding only batteries and a charger is UN 3480 under PI 965. A charging case shipped without its earbuds is also UN 3480.

UN 38.3: the test programme behind every shipment

Each lithium cell and battery design type must pass the tests of sub-section 38.3 of the UN Manual of Tests and Criteria. T.1 to T.5 run in sequence on the same samples; T.6 and T.8 use separate cells, T.7 separate batteries.

Test	What it simulates	Applies to
T.1 Altitude	Low pressure (11.6 kPa or less) for at least 6 hours	Cells and batteries
T.2 Thermal	Rapid cycling between hot and cold extremes	Cells and batteries
T.3 Vibration	Sinusoidal sweep on three axes	Cells and batteries
T.4 Shock	Half-sine shocks on three axes	Cells and batteries
T.5 External short circuit	Short circuit with the sample at elevated temperature	Cells and batteries
T.6 Impact or crush	Mechanical abuse, impact or crush depending on cell geometry	Cells and component cells
T.7 Overcharge	Charge at twice the maximum continuous charge current	Rechargeable batteries
T.8 Forced discharge	Forced discharge of a cell	Primary and rechargeable cells

Exact parameters depend on the size of the cell or battery and must be read in the Manual. The cell and battery safety side, and how UN 38.3 relates to IEC 62133, is covered in IEC 62133 and UN 38.3.

When a design change means retesting

The IATA 2026 guidance quotes paragraph 38.3.2.2 of the Manual (8th revised edition, Amendment 1). A cell or battery is a new type, and must be retested, when it differs from the tested design by:

for primary cells and batteries, a change of more than 0.1 g or 20 percent by mass, whichever is greater, in the cathode, anode or electrolyte;
for rechargeable cells and batteries, a change in watt-hours of more than 20 percent, or a voltage increase of more than 20 percent;
any change that might materially affect the test results, for example a different electrode, separator or electrolyte material, different protective devices including their software, a different number of cells, or a different connection between them.

A new design is tested against the edition of the Manual in force when the design is first tested.

The Test Summary

Manufacturers and later distributors of cells and batteries made after 30 June 2003 must make available the Test Summary defined in paragraph 38.3.5. Anyone in the supply chain can ask for it. The IATA guidance is explicit that a URL or QR code on the battery, the packaging or the transport documents is enough, and that IATA does not support carriers demanding a copy with every consignment. Button cells installed in equipment, including on circuit boards, are exempt.

Watt-hours and lithium content

Lithium-ion limits are set in watt-hours, lithium metal limits in grams of lithium.

Wh = nominal voltage (V) x rated capacity (Ah)
   = nominal voltage (V) x rated capacity (mAh) / 1000

3.6 V x 2 600 mAh / 1000 = 9.36 Wh

Lithium-ion batteries must carry their Wh rating on the outside case. The IATA guidance gives the cut-off dates: batteries manufactured after 1 January 2009 for Section IB and Section II, and after 31 December 2011 for Section I. 49 CFR 173.185(c) requires the marking on batteries shipped under the US small-battery exception after 31 December 2015. Lithium content for lithium metal cells comes from the cell manufacturer.

Air: the IATA packing instruction matrix

The thresholds are per cell and per battery: lithium-ion 20 Wh per cell and 100 Wh per battery, lithium metal 1 g per cell and 2 g per battery. The limits per package below are those of the IATA 2026 guidance flowcharts.

PI	UN	Content	Section	Passenger aircraft	Cargo aircraft only
965	3480	Li-ion, alone, above 20 Wh / 100 Wh	IA	Forbidden	35 kg, UN specification packaging
965	3480	Li-ion, alone, up to 20 Wh / 100 Wh	IB	Forbidden	10 kg, package passing a 1.2 m drop and 3 m stack test
966	3481	Li-ion, packed with equipment, above thresholds	I	5 kg	35 kg, UN specification packaging
966	3481	Li-ion, packed with equipment, up to thresholds	II	5 kg	5 kg
967	3481	Li-ion, contained in equipment, above thresholds	I	5 kg	35 kg
967	3481	Li-ion, contained in equipment, up to thresholds	II	5 kg	5 kg
968	3090	Li metal, alone, above 1 g / 2 g	IA	Forbidden	35 kg, UN specification packaging
968	3090	Li metal, alone, up to 1 g / 2 g	IB	Forbidden	2.5 kg, 1.2 m drop and 3 m stack
969	3091	Li metal, packed with equipment, above thresholds	I	5 kg	35 kg, UN specification packaging
969	3091	Li metal, packed with equipment, up to thresholds	II	5 kg	5 kg
970	3091	Li metal, contained in equipment, above thresholds	I	5 kg	35 kg
970	3091	Li metal, contained in equipment, up to thresholds	II	5 kg	5 kg

All PI 965 and PI 968 packages, Section IA and IB alike, carry the Cargo Aircraft Only label. The IATA guidance also bars UN 3480 (PI 965), UN 3090 (PI 968) and UN 3551 (PI 976) from sharing an outer packaging or overpack with Class 1 other than 1.4S, Division 2.1, Class 3, Division 4.1 or Division 5.1.

State of charge

Shipment	Rule from 1 January 2026
UN 3480 alone (PI 965) and UN 3551 alone	30 percent of rated capacity maximum, mandatory
UN 3481 packed with equipment (PI 966), Section I	30 percent maximum, mandatory
UN 3481 packed with equipment (PI 966), Section II, above 2.7 Wh	30 percent maximum, mandatory; above that, ship under Section I with State approvals
UN 3481 packed with equipment (PI 966), Section II, up to 2.7 Wh	30 percent recommended
UN 3481 contained in equipment (PI 967)	30 percent, or 25 percent indicated battery capacity, recommended
Vehicles (UN 3171, 3556, 3557, 3558) with batteries above 100 Wh	30 percent, or 25 percent indicated battery capacity, mandatory

Shipping above the cap needs approval from the State of Origin and the State of the Operator (special provision A331). The method for determining rated capacity is in paragraph 38.3.2.3 of the Manual. The 25 percent "indicated battery capacity" option exists because the percentage on a device display is what a shipper can actually check; IATA notes it is not equivalent to 30 percent state of charge but gives an equivalent safety margin. In the United States, the same 30 percent cap for UN 3480 is special provision A100 in 49 CFR 172.102.

Approvals and variations

The IATA guidance lists the special provisions under which a State can approve what the base text forbids:

Special provision	What it allows, with approval
A88	Pre-production prototypes and low production runs not yet tested to UN 38.3
A99	Lithium or sodium-ion batteries with a mass above 35 kg
A154	None: it is the ban on damaged, defective or safety-recalled batteries
A183	Waste batteries and batteries shipped for recycling or disposal
A201	Lithium batteries on passenger aircraft (including urgent medical need)
A331	Lithium-ion or sodium-ion above 30 percent state of charge
A334	Batteries on passenger aircraft where packaging mitigation exists

Approvals usually come from the State of Origin and the State of the Operator; some States also require their own approval when they are the destination. An approval does not oblige any airline to accept the shipment, so IATA advises finding a willing operator before applying. State and operator variations, which are often stricter than the base text, are in section 2.8 of the DGR.

Sea: IMDG Code

Amendment 42-24 of the IMDG Code was adopted on 23 May 2024 by resolution MSC.556(108) and has been mandatory since 1 January 2026. It uses the same UN numbers and the same special provisions as the Model Regulations.

Special provision 188 relieves small cells and batteries from most Class 9 requirements when every condition is met, among them: lithium-ion cells up to 20 Wh and batteries up to 100 Wh, lithium metal cells up to 1 g and batteries up to 2 g; packaging that survives a 1.2 m drop; the lithium battery mark on the package unless the exemptions for small consignments apply; and protection against short circuit. Larger consignments go fully regulated, with a dangerous goods declaration and, for a container, a container packing certificate.

Road and rail in Europe: ADR and RID

Since 2021 ADR has been called the Agreement concerning the International Carriage of Dangerous Goods by Road; the word "European" was dropped from the title. ADR 2025 has applied since 1 January 2025, with a transition to 30 June 2025. RID mirrors it for rail.

Special provision	Subject
188	Small cells and batteries, conditions for relief from most of ADR
230	Lithium cells and batteries may be carried under the lithium entries if they meet 2.2.9.1.7
310	Production runs of up to 100 cells or batteries, and pre-production prototypes carried for testing, exempt from UN 38.3 testing if packed to P910
376	Damaged or defective cells and batteries: P908, or P911 where they are liable to react dangerously
377	Cells and batteries carried for disposal or recycling: P909
636	Used cells and batteries collected from consumers, up to the intermediate processing facility
666	Vehicles and battery-powered equipment carried as cargo
670	Cells and batteries in equipment from private households, collected for depollution, dismantling, recycling or disposal

Special provision 670 is the one most often misdescribed. Paragraph (a) exempts batteries that are not the main power source of household equipment, for example the button cell keeping a washing machine's memory. Paragraph (b) covers other household equipment up to the intermediate processing facility, provided it is packed to P909 or in strong outer packagings, a quality assurance system caps lithium and sodium-ion batteries at 333 kg per transport unit, and the packages carry "LITHIUM BATTERIES FOR DISPOSAL" or "LITHIUM BATTERIES FOR RECYCLING" (or the sodium-ion equivalent).

United States: 49 CFR 173.185

Paragraph	Subject
(a)	Classification: each cell and battery type must meet UN 38.3
(b)	Packaging for fully regulated cells and batteries
(c)	Exceptions for smaller cells or batteries
(d)	Cells or batteries shipped for disposal or recycling
(e)	Low production runs and prototypes
(f)	Damaged, defective or recalled cells or batteries
(g)	Limited exceptions for medical device batteries by air
(h)	Approvals

Paragraph (c) contains a limit with no international equivalent. For highway or rail only, the small-battery exception rises from 20 Wh per cell and 100 Wh per battery to 60 Wh per cell and 300 Wh per battery for lithium-ion, and from 1 g and 2 g to 5 g per cell and 25 g per battery for lithium metal, provided the package is marked "LITHIUM BATTERIES" and "FORBIDDEN FOR TRANSPORT ABOARD AIRCRAFT AND VESSEL", joined by a dash in the regulation. Packages under the ordinary exception that can fly must be marked as forbidden on passenger aircraft or carry the Cargo Aircraft Only label, except for batteries packed with or contained in equipment up to 5 kg net. The marking letters must be at least 6 mm high on packages up to 30 kg gross and 12 mm above that.

UN packaging and its marking

Fully regulated lithium batteries are packed to Packing Group II performance under P903 (or the IATA equivalent). The usual outer packaging is a fibreboard box (4G), sometimes plywood (4D) or plastic (4H2).

A mark such as UN 4G/Y20/S/24/F/AB1234 reads:

Part	Meaning
`UN`	UN packaging symbol
`4G`	Fibreboard box
`Y`	Tested for Packing Group II and III. `X` covers groups I, II and III; `Z` group III only
`20`	Maximum gross mass in kg
`S`	Intended for solids or inner packagings
`24`	Last two digits of the year of manufacture
`F`	State authorising the mark (France here)
`AB1234`	Manufacturer or approval code

The packaging mark certifies the design type that passed the Part 6 tests, not your filled package: an untested battery arrangement inside a certified box can still fail the drop test it never saw.

Labels and marks

Item	Used on	Key facts
Class 9 lithium battery hazard label	Fully regulated shipments (Section I, IA, IB)	Seven black vertical stripes on the top half, a battery group symbol on the bottom half, "9" underlined at the bottom; 100 x 100 mm. Introduced in 2017, mandatory since 1 January 2019
Lithium battery mark	Section II and special provision 188 packages, and Section IB	Battery symbol and UN numbers, red hatched border; 100 x 100 mm, or 100 x 70 mm on small packages. Versions with a telephone number accepted until 31 December 2026
Cargo Aircraft Only label	All PI 965 and PI 968 packages; other packages above passenger aircraft limits	Required in addition to the hazard label
Damaged or defective mark	Special provision 376	"DAMAGED/DEFECTIVE LITHIUM ION BATTERIES" or "...LITHIUM METAL BATTERIES"

Damaged, defective and waste batteries

Situation	Packing instruction	Air
Damaged or defective, not liable to react dangerously (SP 376)	P908	Forbidden (A154)
Damaged or defective, liable to react dangerously (SP 376)	P911, in packaging whose performance during a thermal runaway has been verified	Forbidden (A154)
Waste or recycling (SP 377)	P909	Only with State approval (A183)
Safety recall of devices (phones, laptops)	As damaged or defective	Forbidden, even installed in the device

The classification decides everything here. Shipping a swollen or returned battery as an ordinary UN 3480 or UN 3481 consignment is a breach of the rules, not a paperwork shortcut.

Claims the texts contradict

These five statements still circulate in supplier documents and older guides, including an earlier version of this page.

Claim	What the text says
"Small lithium-ion batteries shipped alone can fly as Section II"	Section II of PI 965 and PI 968 was deleted in 2022; they go as Section IB, cargo aircraft only
"The 30 percent rule only applies to UN 3480"	Since 1 January 2026 it also binds PI 966 by air, and vehicles above 100 Wh
"The Test Summary must be in every box"	It must be available on request; a link or QR code is accepted, and IATA does not support per-shipment copies
"T.8 forced discharge is only for primary cells"	T.8 applies to primary and rechargeable cells
"Sodium-ion batteries are UN 3556 to 3558"	Those are vehicle entries; sodium-ion batteries are UN 3551 and UN 3552

Step-by-step checklist

Classify: battery alone, packed with equipment, or contained in equipment; chemistry; UN number. A power bank is a battery.
Rate it: Wh per cell and per battery (lithium-ion) or grams of lithium (lithium metal), and check the Wh marking on the case.
Confirm UN 38.3 for each cell and battery design, and that no design change since the test crosses 38.3.2.2. Get the Test Summary link.
Pick the mode and the packing instruction, then the section from the matrix above.
Set the state of charge if shipping UN 3480, PI 966 above 2.7 Wh, or a vehicle above 100 Wh by air.
Pack in UN specification packaging where required, or a package passing the 1.2 m drop test where the section asks for it.
Mark and label, and use up phone-number lithium battery marks before 31 December 2026.
Document: dangerous goods declaration for fully regulated consignments, air waybill statements for Section II, container packing certificate at sea, ADR transport document by road.
Check variations: State and operator variations by air, and whether your forwarder has its own stricter rules.
Handle returns separately: anything swollen, damaged or recalled goes under special provision 376, by surface only.

The cost and time of this chain sit within the wider product timeline; see certification timeline.

Transport rules say how a battery moves; they do not say how it is designed or what happens at end of life. In the EU, design, labelling and the battery passport come from the EU Battery Regulation 2023/1542, and collection from WEEE (in France, DEEE). Supply-chain due diligence on cobalt and other minerals is covered in conflict minerals reporting. Transport hazards belong in the product risk file described in risk management, ISO 14971 and IEC 31010.

Frequently asked questions

What is the relationship between UN 38.3 and the IATA, IMDG, ADR and DOT regulations?: UN 38.3 is a test programme, not a transport regulation. It sits in sub-section 38.3 of the UN Manual of Tests and Criteria, and every lithium cell and battery design type must pass it before it can be shipped under the ordinary entries. The binding transport rules come from the modal texts: the ICAO Technical Instructions and the IATA Dangerous Goods Regulations for air, the IMDG Code for sea, ADR and RID for road and rail in Europe, and 49 CFR for the United States. All of them are built on the UN Model Regulations, and all of them require UN 38.3, then add their own packing instructions, quantity limits, marks, labels and documents.
Which UN numbers apply to lithium and sodium-ion batteries?: Lithium-ion batteries shipped alone are UN 3480; packed with or contained in equipment, UN 3481. Lithium metal batteries shipped alone are UN 3090; packed with or contained in equipment, UN 3091. Sodium-ion batteries with organic electrolyte have their own pair, UN 3551 alone and UN 3552 with equipment. Vehicles have separate entries: UN 3556 (lithium-ion powered), UN 3557 (lithium metal powered) and UN 3558 (sodium-ion powered), next to UN 3171 for other battery-powered vehicles. Batteries installed in a cargo transport unit, such as a containerised energy storage system, are UN 3536.
Is there still a Section II for lithium-ion batteries shipped alone by air?: No. IATA removed Section II from Packing Instruction 965 (UN 3480) and Packing Instruction 968 (UN 3090) in the 2022 edition of the Dangerous Goods Regulations, with a transition that ended on 31 March 2022. Small stand-alone batteries now travel under Section IB: forbidden on passenger aircraft, Cargo Aircraft Only label, Class 9 lithium battery label, and a limit of 10 kg per package for lithium-ion (2.5 kg for lithium metal). Section II still exists for batteries packed with equipment (PI 966, PI 969) and contained in equipment (PI 967, PI 970).
What changed for the 30 percent state of charge rule on 1 January 2026?: Lithium-ion batteries shipped alone (UN 3480, PI 965) have been capped at 30 percent state of charge since 2016. From 1 January 2026, under the 2025-2026 ICAO Technical Instructions, the cap also applies to lithium-ion batteries packed with equipment (PI 966): all Section I batteries, and Section II batteries above 2.7 Wh. Exceeding it needs an approval from the State of Origin and the State of the Operator (special provision A331). For batteries contained in equipment (PI 967), 30 percent, or an indicated battery capacity of 25 percent or less, is recommended but not mandatory. Vehicles powered by batteries above 100 Wh must also be shipped at 30 percent or 25 percent indicated.
Must the UN 38.3 Test Summary travel with every shipment?: No. Manufacturers and subsequent distributors of cells and batteries made after 30 June 2003 must make the Test Summary defined in paragraph 38.3.5 of the Manual available, and anyone in the supply chain may ask for it. The IATA 2026 lithium battery guidance states that a website link or QR code on the battery, its packaging or the transport documents satisfies the requirement, and that IATA does not support requiring a paper copy with each consignment. Button cells installed in equipment are exempt.
How are damaged, defective or waste lithium batteries shipped?: Batteries identified as damaged or defective under special provision 376 move under packing instruction P908, or P911 when they are liable to react dangerously under normal transport conditions. Batteries sent for disposal or recycling under special provision 377 use packing instruction P909. By air, damaged or defective batteries and those recalled for safety reasons are forbidden (special provision A154), and waste or recycling shipments need a State approval (A183). In practice that leaves road, rail and sea for returns.
What will change for lithium battery marks on 1 January 2027?: The lithium battery mark no longer needs a telephone number. Marks that still show the phone number were allowed under a transitional measure that ends on 31 December 2026. From 1 January 2027 the accepted mark carries the battery symbol and the UN numbers only, so label stock printed with a telephone field should be used up or replaced before the end of 2026.