2021 Lithium Battery Guidance

Document
Transport of Lithium Metal and
Lithium Ion Batteries
Revised for the 2021 Regulations
Introduction
 This document is based on the provisions set out in the 2021-2022 Edition of the ICAO Technical
Instructions for the Safe Transport of Dangerous Goods by Air (Technical Instructions) and the 62nd
Edition of the IATA Dangerous Goods Regulations (DGR).
The provisions of the DGR with respect to lithium batteries may also be found in the IATA lithium
Battery Shipping Guidelines (LBSG) 8th Edition. In addition to the content from the DGR, the LBSG also
has additional classification flowcharts and detailed packing and documentation examples for lithium
batteries.
Information on the DGR and LBSG can be found here:
http://www.iata.org/dgr
http://www.iata.org/lbsg
The purpose of this document is to provide guidance for complying with provisions applicable to the
transport by air of lithium batteries as set out in the DGR. Specifically, the document provides
information on:
• Definitions;
• Classification (including classification flowcharts);
• Prohibitions;
• Restrictions;
• Frequently Asked Questions
• Additional Information
• Abbreviations, Acronyms, Symbols

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Definitions
Lithium Battery – The term “lithium battery” refers to a family of batteries with different chemistries,
comprising many types of cathodes and electrolytes. For the purposes of the DGR they are
separated into:
Lithium metal batteries. Are generally primary (non-rechargeable) batteries that have lithium metal
or lithium compounds as an anode. Also included within lithium metal are lithium alloy batteries.
Lithium metal batteries are generally used to power devices such as watches, calculators, cameras,
temperature data loggers, car key fobs and defibrillators.
 Note:
Lithium metal batteries packed by themselves (not contained in or packed with equipment) (Packing
Instruction 968) are forbidden for transport as cargo on passenger aircraft). In accordance with
Special Provision A201, lithium metal cells or batteries that meet the quantity limits of Section II of
PI 968 may be shipped on a passenger aircraft under an approval issued by the authority of the State
of Origin, State of Destination and State of the Operator. Or in the case of urgent medical need, one
consignment of lithium batteries may be transported as Class 9 (UN 3090) on passenger aircraft with
the prior approval of the authority of the State of origin and with the approval of the operator, see
Special Provision A201. All other lithium metal cells and batteries can only be shipped on a passenger
aircraft under exemption issued by all States concerned.

Figure 1 - Example of Lithium Metal Cells and Batteries

Lithium-ion batteries (sometimes abbreviated Li-ion batteries) are a secondary (rechargeable)
battery where the lithium is only present in an ionic form in the electrolyte. Also included within the
category of lithium-ion batteries are lithium polymer batteries. Lithium-ion batteries are generally
used to power devices such as mobile telephones, laptop computers, tablets, power tools and e-
bikes.

Figure 2 - Example of Lithium Ion Cells and Batteries

 Note:
Lithium ion batteries packed by themselves (Packing Instruction 965) (not contained in or packed
with equipment):
(a) must be shipped at a state of charge (SoC) not exceeding 30% of their rated capacity. Cells
and/or batteries at a SoC of greater than 30% may only be shipped with the approval of the State

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of Origin and the State of the Operator under the written conditions established by those
authorities, see Special Provision A331; and
(b) may be shipped as cargo on a passenger aircraft under an approval issued by the authority of the
State of Origin, State of Destination and State of the Operator where the lithium ion cells or
batteries that meet the quantity limits of Section II of PI 965, or in the case of urgent medical
need, one consignment of lithium batteries may be transported as Class 9 (UN 3480) on
passenger aircraft with the prior approval of the authority of the State of origin and with the
approval of the operator, see Special Provision A201. All other lithium ion cells and batteries can
only be shipped as cargo on a passenger aircraft under exemption issued by all States
concerned.
Aggregate lithium content means the sum of the grams of lithium content contained by the cells
comprising a battery.
The technical definition of a battery and cell, as indicated in the UN Manual of Tests and Criteria, is as
follows:
Battery means two or more cells or batteries which are electrically connected together and fitted
with devices necessary for use, for example, case, terminals, marking and protective devices. Units
which have two or more cells that are commonly referred to as "battery packs", "modules" or "battery
assemblies" having the primary function of providing a source of power to another piece of
equipment are for the purposes of the UN Model Regulations and this guidance document treated as
batteries. See definitions for “cell” and “single cell battery”. (See also “Power Banks”)
Button cell or battery means a round small cell or battery when the overall height is less than the
diameter.
Cell means a single encased electrochemical unit (one positive and one negative electrode) which
exhibits a voltage differential across its two terminals. Under the UN Model Regulations, UN Manual of
Tests and Criteria and this guidance, to the extent the encased electrochemical unit meets the
definition of “cell” herein, it is a “cell”, not a “battery”, regardless of whether the unit is termed a
“battery” or a “single cell battery” outside of the UN Model Regulations, the UN Manual of Tests and
Criteria and this guidance.
Consignment, one or more packages of dangerous goods accepted by an operator (airline) from one
shipper at one time and at one address, receipted for in one lot and moving to one consignee at one
destination address.
Net Quantity Either:
(a) the weight or volume of the dangerous goods contained in a package excluding the weight or
volume of any packaging material; or
(b) the weight of an unpackaged article of dangerous goods (e.g. UN 3166).
For the purposes of this definition “dangerous goods” means the substance or article as described
by the proper shipping name shown in Table 4.2, e.g. for “Fire extinguishers”, the net quantity is the
weight of the fire extinguisher. For articles packed with equipment or contained in equipment, the net
quantity is the net weight of the article, e.g. for “Lithium ion batteries contained in equipment”, the net
quantity is the net weight of the lithium ion batteries in the package.
Overpack means an enclosure used by a single shipper to contain one or more packages and to
form one handling unit for convenience of handling and stowage. Dangerous goods packages
contained in the overpack must be properly packed, marked, labelled and in proper condition as
required by the IATA Dangerous Goods Regulations.
The overpack must not contain packages enclosing different substances which might react
dangerously with each other or packages of dangerous goods which require segregation according

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to Table 9.3.A. In addition, packages containing UN 3090, lithium metal batteries prepared in
accordance with Section IA or Section IB of PI968 or UN 3480, lithium ion batteries prepared in
accordance with Section IA or Section IB of PI 965 are not permitted in an overpack with packages
containing dangerous goods classified in Class 1 other than Division 1.4S, Division 2.1, Class 3,
Division 4.1 or Division 5.1.
Power Bank (power pack, mobile battery, etc.). These are portable devices designed to be able to
charge consumer devices such as mobile phones and tablets. For the purposes of this guidance
document and the IATA Dangerous Goods Regulations, power banks are to be classified as batteries
and must be assigned to UN 3480, lithium ion batteries, or UN 3090, lithium metal batteries, as
applicable. For carriage by passengers, power banks are considered spare batteries and must be
individually protected from short-circuit and carried in carry-on baggage only.
Rated capacity means the capacity, in ampere-hours or milliampere-hours, of a cell or battery as
measured by subjecting it to a load, temperature and voltage cut-off point specified by the
manufacturer.
Note:
The following IEC standards provide guidance and methodology for determining the rated capacity:
(1) IEC 61960 (First Edition 2003-12): Secondary cells and batteries containing alkaline or other
non-acid electrolytes -Secondary lithium cells and batteries for portable applications;
(2) I EC 62133 (First Edition 2002-10): Secondary cells and batteries containing alkaline or other
non-acid electrolytes - Safety requirements for portable sealed secondary cells, and for
batteries made from them, for use in portable applications;
(3) IEC 62660-1 (First Edition 2011-01): Secondary lithium-ion cells for the propulsion of electric road
vehicles- Part 1: Performance testing.
State of Origin, the country (State) in the territory of which the consignment is to first be loaded on
an aircraft.
State of the Operator, the country (State) in which the operator's principal place of business is
located or, if there is no such place of business, the operator's permanent residence.
Watt-hour Rating, expressed in Watt-hours (Wh), the Watt-hour rating of a lithium cell or battery is
calculated by multiplying the rated capacity in ampere-hours by the nominal voltage.
Classification (DGR 3.9.2.6)
Lithium batteries are classified in Class 9 – Miscellaneous dangerous goods as:
• UN 3090, Lithium metal batteries; or
• UN 3480, Lithium ion batteries
or, if inside a piece of equipment or packed separately with a piece of equipment to power that
equipment as:
• UN 3091, Lithium metal batteries contained in equipment; or
• UN 3091, Lithium metal batteries packed with equipment; and
• UN 3481, Lithium ion batteries contained in equipment; or
• UN 3481, Lithium ion batteries packed with equipment.
Lithium battery test summary –manufacturers and subsequent distributors of cells or batteries and
equipment powered by cells and batteries manufactured after 30 June 2003 must make available the
test summary as specified in the UN Manual of Tests and Criteria, Revision 6 and amend. 1, Part III,
sub-section 38.3, paragraph 38.3.5.

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Note:
The requirement is for the manufacturer and subsequent distributors to make this test summary
available. There are numerous ways this can be achieved, such as by listing the applicable summary
document on the company website. There is no expectation for the shipper/distributor to provide
paper copies with each consignment containing lithium batteries. The supply chain are encouraged
to make use of technology to facilitate the availability of the test summary.
The following table provides details of the information required in the test summary:
Lithium cell or battery test summary in accordance with sub-section 38.3 of Manual of Tests
and Criteria
The following information shall be provided in this test summary:
(a) Name of cell, battery, or product manufacturer, as applicable;
(b) Cell, battery, or product manufacturer's contact information to include address, phone
number, email address and website for more information;
(c) Name of the test laboratory to include address, phone number, email address and
website for more information;
(d) A unique test report identification number;
(e) Date of test report;
(f) Description of cell or battery to include at a minimum:
(i) Lithium ion or lithium metal cell or battery;
(ii) Mass;
(iii) Watt-hour rating, or lithium content;
(iv) Physical description of the cell/battery; and
(v) Model numbers.
(g) List of tests conducted and results (i.e., pass/fail);
(h) Reference to assembled battery testing requirements, if applicable (i.e. 38.3.3 (f) and
38.3.3 (g));
(i) Reference to the revised edition of the Manual of Tests and Criteria used and to
amendments thereto, if any; and
(j) Signature with name and title of signatory as an indication of the validity of information
provided.

Further information on the test summary and FAQ’s is available in Part 4 of this guidance document.

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Classification Flowcharts
The following (2) classification flowcharts are intended to provide guidance on the classification for
lithium ion and lithium metal batteries.

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 Classification Flowchart – Lithium Ion Batteries

All cells and batteries must be tested in accordance

with the UN Manual of Tests and Criteria Part III
Subsection 38.3 (DGR 3.9.2.6)

Passed
No Redesign
UN?

Yes

Lithium Ion Batteries

Lithium Ion (limited to a maximum Lithium Ion
Batteries Contained of 30% SoC) Batteries Packed
in Equipment with Equipment

Cells ≤ 20 Wh; Cells ≤20 Wh;

Cells > 20 Wh;
Batteries ≤100 Wh Batteries ≤100 Wh
Cells >20 Wh; Batteries > 100 Wh Cells > 20 Wh; Cells ≤ 20 Wh;
Batteries > 100 Wh Cells ≤20 Wh; UN3480 UN3480 Batteries ≤100 Wh
UN3480 Batteries > 100 Wh
Batteries ≤100 Wh PI 965 PI: 965
UN3481 UN3481
UN3481 PI 965 Section IB Section II UN3481
PI 967 Section I PI 966
PI 967 Section II * IMP: RBI IMP: EBI PI 966
IMP: RLI Section IA Section II
IMP: ELI Section I
IMP: RLI IMP: ELI
IMP: RBI

(not more than 1

Limit per package: package) Limit per
Limit per package: package: Limit per package:
Pax A/C = 5 kg NOTE: Use “IB” if
Pax A/C = 5 kg ≤ 2.7 Wh = 2.5kg; or Limit per package: Pax A/C = 5 kg
CAO = 35 kg package exceeds Section cells > 2.7 Wh ≤ 20 Wh
CAO = 5 kg II Limits or more than 1 Pax A/C = 5 kg CAO = 5 kg
Limit per package: = 8 cells; or
package.
batteries > 2.7 Wh
CAO = 35 kg
Limit per package:
Pax A/C = Forbidden ≤ 100 Wh = 2 batteries
Pax A/C = Forbidden
* exceptions exist to the marking requirements CAO = 35 kg Pax A/C = Forbidden
CAO = 10 kg
– see PI 967 Section II

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 Classification Flowchart – Lithium Metal Batteries

All cells and batteries must be tested in accordance

with the UN Manual of Tests and Criteria Part III
Subsection 38.3 (DGR 3.9.2.6)

Passed No Redesign
UN?

Yes

Lithium Metal
Lithium Metal Batteries Lithium Metal
Batteries Contained Batteries Packed
in Equipment with Equipment

Cells ≤ 1 g; Cells ≤1 g;
Cells >1 g; Batteries ≤ 2 g Batteries ≤ 2 g
Cells >1 g; Batteries Cells ≤ 1 g; Cells >1 g; Cells ≤ 1 g;
>2g Batteries ≤ 2 g Batteries > 2 g UN3090 UN3090 Batteries ≤ 2 g
PI 968 PI 968 Batteries > 2 g
UN3091 UN3091 UN3090 Section IB Section II UN3091
PI 970 PI 970 PI 968 IMP: EBM UN3091
IMP: RBM PI 969
Section I Section II * Section IA PI 969
Section II
IMP: RLM IMP: ELM IMP: RBM Section I
IMP: ELM
IMP: RLM
Limit per package:
(not more than 1
Limit per package: Limit per package: package) Limit per package:
Pax A/C = 5 kg Lithium metal content Limit per package: Pax A/C = 5 kg
Pax A/C = 5 kg Note: Use “IB” if
CAO = 5 kg ≤ 0.3g = 2.5 kg; or
CAO = 35 kg package exceeds Pax A/C = 5 kg CAO = 5 kg
cells > 0.3 g ≤ 1 g
Section II limits or CAO = 35 kg
= 8 cells; or
Limit per package: more than 1 package batteries > 0.3 g ≤ 2 g
Pax A/C = Forbidden Limit per package: = 2 batteries
* exceptions exist to the marking requirements CAO = 35 kg Pax A/C = forbidden Forbidden on PAX
– see PI 970 Section II CAO = 2.5 kg aircraft

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Prohibitions
Lithium ion batteries
All lithium ion cells and batteries shipped by themselves (UN 3480) are forbidden for transport as
cargo on passenger aircraft. All packages prepared in accordance with Packing Instruction 965,
Section IA, IB and II, must bear a Cargo Aircraft Only label, in addition to other required marks and/or
labels.
Lithium metal batteries
All lithium metal cells and batteries shipped by themselves (UN 3090) are forbidden for transport as
cargo on passenger aircraft. All packages prepared in accordance with Packing Instruction 968,
Section IA, IB and II, must bear a Cargo Aircraft Only label, in addition to other required marks and/or
labels.
Restrictions
Lithium ion batteries
All lithium ion cells and batteries (UN 3480 only) must be shipped at a state of charge (SoC) not
exceeding 30% of their rated capacity. Cells and/or batteries at a SoC of greater than 30% may only
be shipped with the approval of the State of Origin and the State of the Operator under the written
conditions established by those authorities, see Special Provision A331.
Packing Restrictions
PI 965 & PI 968 Section IA & IB
UN 3090, lithium metal batteries prepared in accordance with Section IA or Section IB of PI 968 and
UN 3480, lithium ion batteries prepared in accordance with Section IA or Section IB of PI 965 must
not be packed in the same outer packaging with dangerous goods classified in Class 1 (explosives)
other than Division 1.4S, Division 2.1 (flammable gases), Class 3 (flammable liquids), Division 4.1
(flammable solids) or Division 5.1 (oxidizers). Packages containing cells or batteries must not be
placed in an overpack with packages containing dangerous goods classified in Class 1 other than
Division 1.4S, Division 2.1, Class 3, Division 4.1 or Division 5.1.
PI 965 & PI 968 Section II
Cells and batteries must not be packed in the same outer packaging with other dangerous goods.
Shippers are restricted to offering one package per consignment. Packages and overpacks must be
offered to the operator separately from other cargo and must not be loaded into a unit load device
before being offered to the operator.

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Frequently Asked Questions

Part 1 – Questions Related to Definitions

A. What are the various types of lithium batteries?
Lithium batteries fall into two broad classifications; lithium metal batteries and lithium ion batteries.
Lithium metal batteries are generally non-rechargeable and contain metallic lithium. Lithium ion
batteries contain lithium which is only present in an ionic form in the electrolyte and are rechargeable.
Within these two broad classifications there are many different chemistries. For example within
lithium ion batteries there are lithium polymer, lithium iron phosphate (LiFePO4), lithium air to name a
few.
B. What is the difference between a lithium cell and a lithium battery?
A lithium cell is a single encased electrochemical unit consisting of one positive and one negative
electrode that exhibits a voltage differential across the two terminals. A lithium battery is two or more
cells electrically connected. A single cell battery is considered a cell and not a battery for the
purposes of the limitations set out in the DGR.
Note:
Units that are commonly referred to as “battery packs” or “power banks” having the primary function
of providing a source of power to another piece of equipment are for the purposes of these
Regulations treated as batteries. This includes uninterruptible power supply (UPS) fitted with lithium
ion batteries. Refer to the section on Definitions for complete details.
C. How are component cells connected to form a battery?
Cells in batteries may be connected in parallel, in series, or in a combination of the two. When cells
are connected in series, the voltage of the battery increases but the capacity in ampere-hours (Ah)
does not change. By contrast, when cells are connected in parallel the capacity in ampere-hours of
the battery (Ah) increases but the voltage stays the same.
D. How do I determine the watt-hour rating for a particular lithium ion battery?
The Watt-hour (Wh) rating is a measure by which lithium ion batteries are regulated. Section I lithium
ion batteries manufactured after 31 December 2011 and Section IB and Section II lithium ion
batteries manufactured after 1 January 2009 are required to be marked with the Watt-hour rating on
the outside case.
You can also arrive at the number of Watt-hours your battery provides if you know the battery’s
nominal voltage (V) and capacity in ampere-hours (Ah):
Ah x V = Wh
Note:
If only the milliampere-hours (mAh) are marked on the battery then divide that number by 1000 to get
ampere-hours (Ah) (i.e. 4400 mAh / 1000 = 4.4. Ah).
Most lithium ion batteries marketed to consumers are below 100 Watt-hours. If you are unsure of the
Watt-hour rating of your lithium ion battery, contact the manufacturer.
E. What is a button cell battery?
A button cell battery is a round small cell where the overall height is less than the diameter. Button
cells are often referred to as “coin” cells.

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Part 2 – Questions related to Packaging and Transport Provisions

A. How do I safely package lithium batteries for transport?
One of the major risks associated with the transport of batteries and battery-powered equipment is
short-circuit of the battery as a result of the battery terminals coming into contact with other
batteries, metal objects, or conductive surfaces. Packaged batteries or cells must be separated in a
way to prevent short circuits and damage to terminals. They must be packed in a strong rigid outer
packaging unless when contained in equipment, the battery is afforded equivalent protection by the
equipment in which it is contained. Sample packaging meeting these requirements is shown below:

B. How can batteries be effectively protected against short circuit?

Methods to protect against short circuit include, but are not limited to, the following methods:
a. Packing each battery or each battery-powered device when practicable, in fully enclosed inner
packagings made of non-conductive material (such as a plastic bag);
b. Separating or packing batteries in a manner to prevent contact with other batteries, devices or
conductive materials (e.g. metal) in the packagings; and
c. Ensuring exposed terminals or connectors are protected with non-conductive caps, non-
conductive tape, or by other appropriate means.
If not impact resistant, the outer packaging must not be used as the sole means of protecting the
battery terminals from damage or short-circuiting. Batteries should be securely cushioned and
packed to prevent shifting which could loosen terminal caps or reorient the terminals to produce
short circuits.
Terminal protection methods include but are not limited to the following:
a. Securely attaching covers of sufficient strength to protect the terminals;
b. Packaging the battery in a rigid plastic packaging; and
c. Constructing the battery with terminals that are recessed or otherwise protected so that the
terminals will not be subjected to damage if the package is dropped.

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C. I’m shipping using Section II of the packing instructions, what constitutes “adequate
instruction”?
Shippers of lithium batteries prepared in accordance with Section II of the lithium battery packing
instructions are not subject to the formal dangerous goods training requirements set out in DGR 1.5,
however, persons preparing such shipments must be provided with “adequate instruction” as
described in DGR 1.6.
The following is offered as a starting point for an employer on what could be considered as being
adequate instruction:
1. The employer must identify the different configurations of lithium batteries that they ship, i.e.
lithium batteries and/or lithium batteries packed with equipment and/or lithium batteries
contained in equipment; lithium metal batteries and/or lithium ion batteries.
2. The employer must document the procedures that apply to the configurations and battery types
that they ship as determined in 1, above.
3. The procedures should be written up as a clear work instruction or other information that is
available to all employees responsible for the preparation of lithium battery shipments.
4. All employees that are involved in the process of preparing lithium battery shipments must be
taken through the procedure to ensure that they understand and can demonstrate the correct
application of documented procedures for the packing, labelling, marking and documentations
requirements, as applicable to their job function.
5. A record must be maintained that identifies each applicable employee and the date(s) that this
instruction was provided.
6. Employees should be given periodic refresher, or at least demonstrate that they remain
“adequately” instructed on how to perform the task. This should be done at least every two years
or whenever the procedure is revised, or regulations are changed, whichever is sooner.
7. Companies that are involved in reverse logistics, i.e. arranging for returns of lithium batteries,
lithium batteries packed with equipment or lithium batteries contained in equipment must develop
a clear instruction for consumers on the process to be followed for returning products. This
instruction must include packaging materials and lithium battery marks, as necessary. The
instruction must also include the transport method and mode of transport that must be followed;
this must include a clear statement on applicable prohibitions.
 D. What does the lithium battery mark look like and when is it required?
The lithium battery mark is required as specified in the additional requirements of Section II of
Packing Instructions 965, 966, 967, 968, 969 and 970. It is also required as specified in the additional
requirements of Section IB of Packing Instructions 965 and 968 in addition to the Class 9 lithium
battery hazard label and Cargo Aircraft Only label. The mark is as shown in Figure 7.1.C of the IATA
Dangerous Goods Regulations. The border of the mark must have red diagonal hatchings with a
minimum width of 5mm. The symbol (group of batteries, one damaged and emitting flame, above the
UN number for lithium ion or lithium metal batteries or cells) must be black on white or suitable
contrasting background. The lithium battery mark may be printed directly on the outer packaging
provided that there is sufficient contrast between the elements of the lithium battery mark and the
colour of the packaging material. The mark must be in the form of a rectangle or a square with
minimum dimensions of 100 mm x 100 mm. If the size of the package so requires, the dimensions/line
thickness may be reduced to not less than 100 mm wide × 70 mm high.

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* Place for UN number(s), i.e. UN 3090, UN 3091, UN 3480 and/or UN 3481, as applicable. The UN
number(s) indicated on the mark should be at least 12 mm high.
** Place for telephone number
Note:
The telephone number should be of a person knowledgeable about the shipment but is not intended
to be for the purposes of obtaining immediate emergency response guidance and is therefore not
required to be monitored at all times that the package is in transit. It is acceptable for the number to
be monitored during the company’s normal business hours in order to provide product-specific
information relative to the shipment. However, it also is acceptable to use an emergency response,
24-hour phone number on the lithium battery mark.
 E. If I have smaller packages, can I use a smaller lithium battery mark?
Where the packages are of dimensions such that they cannot bear the full-size lithium battery mark,
the mark dimensions may be reduced to 100 mm wide × 70 mm high. The design specifications
remain otherwise the same.
Where any face of a package is large enough to bear the full-size lithium battery mark, the full-size
mark must be used.
F. When is a lithium battery mark not required on the package?
A lithium battery mark must not be affixed to packages prepared in accordance with Section IA of
Packing Instructions 965 and 968 and Section I of Packing Instructions 966, 967, 969 and 970.
A lithium battery mark is not required for packages prepared in accordance with Section II of PI 967
or PI 970 containing only button cell batteries installed in equipment (including circuit boards) or
consignments of two packages or less where each package contains no more than four cells, or two
batteries installed in equipment.
Note:
The Air Waybill is required to contain the statements "Lithium [ion or metal] batteries in compliance
with Section II of PI9XX" when the lithium battery mark is affixed to the package(s).

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G. Section II in Packing Instructions 967 and 970 states that “the lithium battery mark is not
required on consignments of two packages or less where each package contains no more than
four cells, or two batteries installed in equipment.” What is the intent of this provision?
This provision is to require, where there are more than two packages in the consignment, that each
package bears the lithium battery mark, and therefore the air waybill has the compliance statement
e.g. “Lithium [ion or metal] batteries in compliance with Section II of PI 9xx [67 or 70]”.
The provision continues to allow for small consignments of one or two packages containing no more
than four cells or two batteries installed in equipment per package to move without the lithium
battery mark and therefore without the compliance statement on the air waybill.
Note:
A consignment is one or more packages of dangerous goods accepted by an operator (airline) from
one shipper at one time and at one address, receipted for in one lot and moving to one consignee at
one destination address.
H. I have an MP3 player that contains one single-cell lithium ion battery. Do I have to mark the
shipping box that contains each MP3 player? What if I place five MP3 players in a shipping box?
Does this require the lithium battery mark?
For packages of a single MP3 player, no lithium battery mark would be required since you can place
up to 4 of these single-cell batteries in a box without applying the lithium battery mark on the outer
box. In the case where 5 MP3 players are in a shipping package, a lithium battery mark on the
shipping package is required.
I. Can a single lithium battery mark be used to identify that both lithium metal and lithium ion
batteries are contained inside the package?
Yes. The mark may bear all applicable UN numbers, e.g. UN 3091, UN 3481, to identify that the
package contains lithium metal batteries packed with or contained in equipment and lithium ion
batteries packed with, or contained in equipment.
J. What are the requirements for the telephone number on the lithium battery mark?
The telephone number should be of a person knowledgeable about the shipment but is not intended
to be for the purposes of obtaining immediate emergency response guidance and is therefore not
required to be monitored at all times that the package is in transit. It is acceptable for the number to
be monitored during the company’s normal business hours in order to provide product-specific
information relative to the shipment. However, it also is acceptable to use an emergency response,
24-hour phone number on the lithium battery mark.
K. Must the lithium battery mark be placed on the same face of the package with the Class 9
hazard label and/or Cargo Aircraft Only label?
No, the lithium battery mark does not have to be on the same face of the package with these labels. It
may be placed on a different face. However, if the package is of sufficient size all required marks and
labels should be applied to one face of the package.
L. For the purposes of the lithium battery packing instructions, what is considered the
"package"?
The package is the complete product of the packing operation that satisfies the requirements of the
packing instruction and in a manner ready to be presented for transport (shipper/consignee
information, hazard communication, etc.). The package may contain multiple batteries or pieces of
equipment provided the limitations set out in the applicable packing instruction are not exceeded.
The package must be marked and labelled as required by the packing instruction. A single package
may be offered for transport, or one or more packages may then be placed into an overpack for ease
of handling or transport purposes. When an overpack is used, the package marks and labels must be

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duplicated on the overpack unless the marks and labels required on individual packages are visible or
are not required by the packing instruction (i.e. not more than 4 cells or 2 batteries when contained in
equipment and no more than two packages in the consignment).
M. Does the IATA DGR require a MSDS or SDS containing the UN test data?
No. The IATA DGR does not require a safety data sheet (SDS) when offering lithium batteries for
transport.
Notes:
1. A SDS is not a transport document. A SDS is only required for the supply and use of a substance
or mixture meeting the Globally Harmonized System of Classification and Labelling of Chemicals
(GHS) classification criteria. GHS does not include provisions for manufactured articles.
2. Manufacturers and subsequent distributors of lithium cells and batteries and equipment with
installed lithium cells or batteries must make available a test summary that identifies that the cell
and battery types have passed the applicable UN 38.3 tests, see Part 4 of this document.
N. Under Packing Instructions 966 and 969, it states that “The maximum number of batteries in
each package must be the minimum number required to power the equipment, plus two spare
sets. A “set” of cells or batteries is the number of individual cells or batteries that are required to
power each piece of equipment”. If a package contains 4 power tools (each tool contains 1
lithium ion battery), can 2 extra lithium ion batteries be placed in the package for each piece of
equipment for a total of 12 batteries?
Yes, providing you do not exceed the maximum net quantity for the relevant section of the packing
instruction and the chosen aircraft type. The 12 batteries reflect two spare sets (8) for each of the 4
power tools in the outer package plus one each to power the device (4).
O. May lithium battery packages be placed in an overpack in accordance with the IATA
Dangerous Goods Regulations?
Yes, but there are segregation requirements that need to be considered for certain other classes of
dangerous goods. UN 3090, lithium metal batteries prepared in accordance with Section IA or
Section IB of PI 968 and UN 3480, lithium ion batteries prepared in accordance with Section IA or
Section IB of PI 965 are not permitted in the same outer packaging with dangerous goods classified
in Class 1 other than Division 1.4S, Division 2.1, Class 3, Division 4.1 or Division 5.1. The overpack
may also contain goods not subject to the Regulations provided there are no packages enclosing
different substances which might react dangerously with each other. An overpack must be marked
with the word “overpack” and must be labelled with the lithium battery mark (DGR Figure 7.1.C),
unless the mark(s) on the package(s) inside the overpack are visible or not required by the Packing
Instruction.
In addition, the word “overpack” must be marked on overpacks containing packages transported in
accordance with Section I of the applicable Packing Instructions (i.e. bearing the Class 9 lithium
battery hazard label).
Note:
For Section II of PI 965 and PI 968 the shipper is limited to one (1) package per consignment
(shipment) and no more than one (1) package complying with the requirements of Section II may be
placed in an overpack. This overpack may also contain packages of non-dangerous goods and/or
packages prepared in accordance with Section IA and/or IB of PI 965 and/or PI 968 and/or packages
of other dangerous goods, excluding packages containing dangerous goods classified in Class 1
other than Division 1.4S, Division 2.1, Class 3, Division 4.1 or Division 5.1.

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P. Do the quantity limits shown in the lithium battery packing instructions apply to overpacks
containing lithium batteries?
The quantity limits shown in the packing instructions refer to the maximum net weight of the lithium
cells or batteries that is permitted in each package. Provided each package remains within the limit
specified in the packing instruction, there are no limits specified for an overpack.
Note:
For Section II of PI 965 and PI 968 the shipper is limited to one (1) package per consignment
(shipment) and no more than one (1) package complying with the requirements of Section II may be
placed in an overpack. This overpack may also contain packages of non-dangerous goods and/or
packages prepared in accordance with Section IA and/or IB of PI 965 and/or PI 968 and/or packages
of other dangerous goods, excluding packages containing dangerous goods classified in Class 1
other than Division 1.4S, Division 2.1, Class 3, Division 4.1 or Division 5.1.
Q. Packing Instructions 966 and 969 Section II include a requirement for a 1.2 metre drop test.
What portion or portions of the package are subject to this test?
The completed package containing batteries as prepared for transport in accordance with the
relevant packing instruction must be capable of withstanding the 1.2 m drop test. This could apply to
a package solely containing batteries that is packaged in full compliance with the provisions of the
packing instruction (to include the 1.2 m drop test capability requirement) and is then packed with
equipment in a strong rigid outer packaging and offered for transport (see item 2N for additional
information related to overpacks). Or, it could apply to a package that includes batteries properly
packed in inner packaging and equipment or other non-dangerous goods that are placed in a strong
rigid outer packaging. The package that includes both the inner packaging containing batteries and
the equipment must comply with the packing instruction to include meeting the capability to pass the
1.2 m drop test.
 R. How do I transport prototype lithium cells and batteries that have not passed the UN 38.3
Tests?
Pre-production prototypes of lithium batteries or cells, when these prototypes are transported for
testing, or low-production runs (i.e. annual production runs consisting of no more than 100 lithium
cells and batteries) of lithium cells or batteries that have not been tested to the requirements in
subsection 38.3 of the UN Manual of Tests and Criteria may be transported aboard cargo aircraft, if
approved by the appropriate authorities of the State of origin and the State of the operator and the
requirements in Packing Instruction 910 of the Supplement to the Technical Instructions are met (see
Special Provision A88).
The appropriate authority of the State of origin should provide details of PI 910 as part of the
approval process.
S. Can I ship recalled, damaged or non-conforming cells or batteries?
Lithium batteries, identified by the manufacturer as being defective for safety reasons, or that have
been damaged, that have the potential of producing a dangerous evolution of heat, fire or short
circuit are forbidden for transport by air (e.g. those being returned to the manufacturer for safety
reasons). This applies also to lithium cells or batteries installed inside equipment such as mobile
phones, laptops or tablets where the devices are subject to recall due to the safety concerns of the
lithium cell or battery installed in the device, see Special Provision A154 in the DGR.
Batteries which have some other defective feature (e.g. LEDs not showing charge, incorrect model
number on label, or batteries not holding enough charge) could still be shipped by air. Also, laptops
being returned may not have a defective battery, it may not meet the needs of the customer, may be
defective itself (but not the battery), etc. In these situations air transport would be permitted. The

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battery or equipment manufacturer should be contacted to determine the appropriate shipping

method.
T. How do I protect against “inadvertent activation”?
When batteries are contained in equipment, the equipment must be packaged in a manner that
prevents unintentional activation or must have an independent means of preventing unintentional
activation (e.g. packaging restricts access to activation switch, switch caps or locks, recessed
switches, trigger locks, temperature sensitive circuit breakers, etc.). This requirement does not apply
to devices which are intentionally active in transport (RFID transmitters, watches, sensors etc.) and
which are not capable of generating a quantity of heat sufficient to be dangerous to packaging or
personal safety.
U. What is the maximum weight of batteries per package for fully regulated batteries contained
in equipment (Section I)?
The maximum weight is 5 kg of lithium batteries per package for passenger and cargo aircraft and
35 kg of lithium batteries per package for cargo aircraft only. The net quantity shown excludes the
weight of the equipment:
Net Quantity per Net Quantity per
Package Package
Passenger Aircraft Cargo Aircraft Only
Lithium Ion & Lithium
Metal cells and batteries 5 kg 35 kg
contained in equipment

V. Do I need to declare a gross weight or a net weight for lithium batteries (Section I)?
All lithium battery shipments, including when packed with or contained in equipment, must be
declared by the net weight of lithium cells or batteries contained in the package as per the definition
of “net quantity”, see page 3.
W. I have 2 kg of 2.7Wh cells and 2 batteries that meet the Section II limitations; can I place them
in one package?
No. The limits found in Table 965-II and Table 968-II cannot be combined. Shippers are not permitted
to ship more than one package of Section II PI 965 at one time. Therefore quantities of lithium ion
cells or batteries that exceed the limit for one package must be shipped as Section IB of the
applicable packing instruction.
X. I am shipping Section IB lithium [ion or metal] batteries; do I need dangerous goods training?
Yes. All the provisions of the Dangerous Goods Regulations apply to shipments of Section IB
batteries except the references listed in Section IB. Therefore, dangerous goods training as indicated
in Subsection 1.5 of the Dangerous Goods Regulations is required.
Y. What are the additional marking requirements for a package prepared under Section IB of
Packing Instruction 965 and 968?
Because all of the requirements of the dangerous goods regulations apply other than the
requirement to use UN specification packaging, each package must be marked with:
• the UN Number preceded by “UN” and the Proper Shipping Name (DGR 7.1.4.1 (a));
• the shipper and consignee address (DGR 7.1.4.1 (b));
• in addition, the net weight as required by (DGR 7.1.4.1(c)) must be marked on the package; and

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• the lithium battery mark (see item 2D) in addition to the Class 9 lithium battery hazard label
and Cargo Aircraft Only label.
Note:
When using an overpack, each package must be marked in accordance with the Regulations and
then, when placed in an overpack, marked as required by DGR 7.1.7.
Z. I am shipping perishable cargo with lithium battery powered temperature or data loggers; do
I need to follow the Dangerous Goods Regulations?
Yes. All the applicable provisions for lithium batteries will need to be followed by the shipper of such
devices, including the limitations for devices that are “active” (on) during transport.
Note:
1. The IATA Temperature Control Regulations (TCR) also apply to such shipments.
2. Further information on active devices in the guidance document that is posted on the IATA website
– www.iata.org/pharma
AA. Do I need to include an additional document or statement to certify that my lithium ion
batteries are at no more than 30% SoC?
No. For lithium ion batteries shipped in accordance with Section IA or Section IB of PI 965, which
must be on a Shipper’s Declaration, the Shipper’s Declaration includes a certification statement “I
declare that all of the applicable air transport requirements have been met.”
By signing the Shipper’s Declaration the shipper is making a legal statement that all the applicable
provisions of the DGR have been complied with, which includes that the lithium ion batteries are at no
more than 30% SoC.
For Section II of PI 965, the provision of the compliance statement “lithium ion batteries in
compliance with Section II of PI 965” on the air waybill will be taken by regulatory authorities as a legal
declaration of compliance.
BB. I have lithium ion batteries packed with equipment (PI 966, Section I) where the lithium ion
batteries are packed in a UN specification fibreboard (4G) box and then that box is packed with
the equipment in a fibreboard outer packaging. Is this an overpack?
No, Section I of PI 966 (and also PI 969) allows two methods of having lithium batteries packed with
equipment. Either:
(a) the lithium batteries are packed into a UN specification packaging meeting Packing Group II
performance standards and then packed with the equipment in an outer packaging; or
(b) the lithium batteries and the equipment are packed into a UN specification packaging meeting
Packing Group II performance standards.
In either case what is presented for transport is a “package” and not an overpack.
CC. Does the definition of “consignment” apply to the house air waybill (HAWB) or to the master
air waybill (MAWB)?
The use of HAWB or MAWB has no direct relationship to what is a “consignment”. For example a
MAWB may have multiple consignments where each of the consignments are from separate
shippers, or are from one shipper but to separate consignees, or the MAWB may be just be a single
consignment from one shipper to one consignee.
The following limitations apply to consignments:
1. a shipper is not permitted to consign more than one package of Section II, PI 965 or PI 968; and

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2. a shipper is not permitted to consign more than two packages of lithium batteries contained in
equipment under Section II of PI 967 and PI 970 where there are no more than 4 cells or 2
batteries in the package without the application of the lithium battery mark on the package.
The objective of these two conditions is to:
1. restrict the number of packages of just lithium batteries that are carried by air that are not subject
to the dangerous goods acceptance check and that are not shown on the written information to
the pilot-in-command. The intention here is to force shippers of multiple packages to declare
these on a Shipper’s Declaration for Dangerous Goods and therefore make the consignment
subject to the full checks for air transport.
2. require appropriate hazard communication on packages and on the air waybill where a shipper
has more than two packages of lithium batteries contained in equipment.
Notes:
1. This does not mean that every retail “package” must bear the lithium battery mark. A shipper
may place multiple retail boxes, each containing a lithium battery meeting Section II installed
in equipment, into an outer packaging to form the package for air transport. There is no limit
on the number of individual retail boxes that can be placed into the outer packaging, except
that a “package” must not contain more than 5 kg net weight of lithium batteries. Each such
package must bear the lithium battery mark and when an air waybill is used, the air waybill
must show the applicable compliance statement, e.g. “lithium ion batteries in compliance with
section II of PI 967”.
2. Shippers or freight forwarders should not try to split a consignment across multiple air
waybills to try to avoid the application of the lithium battery mark where there are more than
two packages with lithium batteries contained in equipment under Section II in a consignment.
DD. Can I ship 2 mobile phones in the same package with 2 power banks using the Section II
provisions?
No, the power banks are classified as UN 3480, Lithium ion batteries. Under the provisions of PI965
Section II other dangerous goods are not permitted in the same outer packaging. The power banks
are also not considered as “spares” for the purposes of PI 966 and Lithium ion batteries packed with
equipment.
EE. What is the correct classification for hearing aids or Bluetooth® “earbuds” that are shipped in
a charging case or with a charging case in the same package?
Bluetooth® earbuds or hearing aids that are shipped in or with a charging case should be classified as
“UN3481, Lithium batteries packed with equipment” and packaged in accordance with PI 966. If the
charging case is shipped without the earbuds, the case must be classified as “UN3480, Lithium ion
batteries” and packaged in accordance with PI 965.
 FF. Can a package containing an AC adaptor or charger and lithium ion batteries be classified as
UN 3481, Lithium ion batteries packed with equipment?
No, for the purpose of Packing Instruction 966, “equipment” means the device or apparatus for which
the lithium ion batteries will provide electrical power for its operation. When a package contains only
the AC adaptor or charger and lithium ion batteries, the package must be classified as “UN 3480,
Lithium ion batteries” and packaged in accordance with PI 965.

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Part 3 – Questions Related to Design Type Testing Provisions

A. Where can I find requirements related to testing of battery design types?
The UN Manual of Tests and Criteria sets out specific tests that must be conducted on each lithium
cell or battery design type. Each test is intended to either simulate a common transportation
occurrence such as vibration or changes in altitude or to test the integrity of a cell or battery. You
may obtain a copy of these testing requirements via the following website:
http://www.unece.org/trans/danger/publi/manual/manual_e.html
B. What constitutes a design change requiring renewed design type testing?
The following provisions are taken from the 7th revised edition of the UN Manual of Tests and Criteria,
paragraph 38.3.2.2.
A cell or battery that differs from a tested design by:
(a) For primary cells and batteries, a change of more than 0.1 g or 20% by mass, whichever is
greater, to the cathode, to the anode, or to the electrolyte;
(b) For rechargeable cells and batteries, a change in Watt-hours of more than 20% or an increase in
voltage of more than 20%; or
(c) A change that would materially affect the test results.
shall be considered a new type and shall be subjected to the required tests.
Note: the type of change that might be considered to differ from a tested type, such that it might lead
to a failure of any of the test results, may include, but is not limited to:
(a) A change in the material of the anode, the cathode, the separator or the electrolyte;
(b) A change of protective devices, including the hardware and software;
(c) A change of safety design in cells or batteries, such as a venting valve;
(d) A change in the number of component cells;
(e) A change in connection mode of component cells;
(f) For batteries which are to be tested according to T.4 with a peak acceleration less than
150 gn, a change in the mass which could adversely impact the result of the T.4 test and lead
to a failure.
In the event that a cell or battery type does not meet one or more of the test requirements, steps
shall be taken to correct the deficiency or deficiencies that caused the failure before such a cell or
battery type is retested.
C. What edition of the UN Manual of Tests and Criteria must be used when testing new lithium
cell or battery designs
If a newly produced lithium cell or battery design is being tested for the first time, then the edition of
the UN Manual of Tests and Criteria in effect at the time that the cell or battery designs are first
tested must be used. For example, a new lithium ion battery design is produced for the first time in
March 2019. This battery must be tested in accordance with the provisions of the 6th revised edition
and amendment 1 of the UN Manual of Tests and Criteria as this is the edition in effect, see Note
under DGR 1.1.1 (1.1 of the LBSG).

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Part 4 – Questions Related to the Lithium Battery Test Summary¹

A. Does the test summary apply to equipment containing lithium cells or batteries?
Yes, the test summary applies to all lithium cells and batteries, including button cells, irrespective of
whether they are shipped alone or contained in equipment.
B. Can multiple batteries/manufacturers/products be listed on one report?
Yes, it is acceptable to have a single document that addresses multiple batteries / manufacturers /
products, provided all required information is stated. For example, a tablet manufacturer may
purchase lithium ion batteries from three different battery manufacturers. The test summary for the
product will therefore list batteries and all related information (e.g. Watt-hours, test labs) from the
three battery manufacturers without naming the manufacturer due to confidentiality issues.
C. Is it acceptable to list the various test houses, tests and range of revisions tested to for the
UN 38.3 revision and amendments?
Yes, it is acceptable to have multiple test houses and their addresses, email information, etc. listed
provided all required information is stated. The test house is not required to be aligned to a specific
battery or product on the test summary when the test summary covers multiple batteries/products. It
is required to have the test report number and date of test for each cell/battery/product listed on the
test summary.
D. What is meant by physical description of cell or battery?
A physical description is intended to provide a check for the person requesting the test summary to
know that it applies to the cell/battery/product covered by the test summary, i.e. if a cellular phone is
the product being shipped, the invoice description or marketing name of the product as the physical
description could be used on the test summary.
E. What does availability of report mean: “When requested?”
The test summary must be made available upon request. Any individual or entity in the supply chain
may request the test summary, e.g. regulator, consumer, or transport provider.
F. Can the test summary provider require a requestor to obtain the document from a website?
Yes, it is acceptable for the provider to require the requestor to obtain a document electronically
from a provider's website. The provider must ensure that the cell/battery/product has appropriate
identifiers to align to the test summary.
G. If a manufacturer considers their suppliers, test house and battery data confidential and
competitive information, how would test summary compliance be achieved?
All 10 data elements and listed subsets of information are required to be on the test summary. As
indicated above, the test house information may be listed to cover a range of products.
H. If a test summary is requested by a dangerous goods enforcement agency, how quickly must
the test summary be made available? For example, would a manufacturer be expected to
immediately produce a test summary or provide it within a certain amount of time (e.g. 72 hours)
Due to the large volume of lithium batteries and lithium battery powered products that are shipped
daily, manufacturers and distributors should not be expected to immediately provide a test summary
for every product they ship. Manufacturers and distributors should be provided a reasonable amount
of time to provide the required test summary.

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I. Would manufacturers and distributors of battery powered vehicles (UN3171) and hybrid
vehicles containing a lithium battery (UN3166) be expected to provide a test summary?
Yes. The test summary requirement applies to manufacturers and distributors of lithium cells and
batteries. Therefore, a test summary must be made available for battery-powered vehicles and other
vehicles containing lithium batteries.
J. Is there a mandated format for the test summary that manufacturers and distributors must
follow?
No. Manufacturers and distributors may compile the information required in the test summary using
any format. Below are 3 examples of a test summary:

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Example 1 of a Lithium Ion Battery Test Summary

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Example 2 of a Lithium Ion Battery Test Summary

UN38.3 Lithium Battery Test Summary for GreenTech
Tablet Model No. T54321
1 Battery Manufacturer
Confidential and Proprietary GreenTech Information
2 Product Manufacturer
GreenTech
123 Main Street
Annapolis, MD 21012
888.111.2345
[email protected]; www1.greentech.com
3 UN38.3 Test Lab
Bob’s Battery Test Lab
1600 Pennsylvania Avenue
Smithfield, VA 12345
Phone: 211.789.2345
[email protected]; www.testlab.org
4 Test Report Number
Liion621345
5 Date of Test Report
April 1, 2017
6 Description of Cell or Battery
7.4 V, 1800 mAh, 13.32 Wh
Li ion battery, Model No. P1789
Small, rectangular plastic case, 100 grams
7 UN38.3 Tests Performed and Successfully Passed
T.1, T.2, T.3, T.4, T.5, and T.7. (Note that T.6 and T.8 are not applicable to
batteries.)
8 Assembled Battery Testing Requirements
Not Applicable
9 Edition of UN Manual of Tests and Criteria Used
Sixth Revised Edition
10 Name and Title of Signatory

Jason Alexander

Jason Alexander
GreenTech Staff Engineer

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Example 3 of a Lithium Metal Cell Test Summary

¹ Information in Part 4 kindly provided by PRBA – The Rechargeable Battery Association, RECHARGE the Advanced
Rechargeable & Lithium Batteries Association and the Medical Device Battery Transport Council

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Additional Information
Further information can be found here:
http://www.iata.org/lithiumbatteries
Information for passengers can be found here:
http://www.iata.org/dgr-guidance
www.faa.gov/go/safecargo
You may also contact the airline of your choice or your national civil aviation authority if you have any
further concerns about travelling with lithium metal or lithium ion batteries.
You can also contact the IATA Dangerous Goods Support team if you have questions or concerns
which may not have been addressed in this document: [email protected].

Abbreviations, Acronyms, Symbols

The following abbreviations, acronyms and symbols are used throughout the document.
Abbreviation Meaning
A/C Aircraft
Li Ion (li-ion) Lithium ion
Li batt. Lithium battery
Pax Passenger
Acronym Meaning
CAO Cargo Aircraft Only
DGD Shipper’s Declaration for Dangerous
Goods
DGR IATA Dangerous Goods Regulations
LBSG IATA Lithium Battery Shipping
Guidelines
Symbol Meaning
≥ Equal to or greater than
≤ Equal to or less than
> Greater than
< Less than
 Addition of an item
 Change to an item
 Deletion of an item

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