The International Air Transport Association (IATA) issues regulations on the transport of Dangerous Goods by air, the DGR. The current edition — number 58 — has introduced stricter restrictions on transport and packaging of Lithium-Ion batteries after an increasing amount of incidents. It is imperative to develop and use packaging that is compliant with IATA Dangerous Goods Regulations (DGR) and to follow all other aspects of the regulations. In this blog, I therefore describe how to define the required packaging.
IATA Dangerous Goods Regulations for the shipment of lithium-ion batteries by air
As the intro stated, in case of air transportation of your LiBs, you are required to meet the Dangerous Goods Regulations (DGR) issued by The International Air Transport Association, (IATA).
In order to summarize the regulations specifically for Lithium Batteries, IATA sells some good tools like the Lithium Battery Shipping Guidelines (LBSG) guide . The guide will take you through the shipping process step by step. You can also consult their Lithium Battery Guidance Document; it’s free of charge.
Below, I detail some of the requirements stated in the guidance document.
According to the register of Dangerous Goods in the DGR, Lithium-ion batteries are classified in Class 9 – Miscellaneous dangerous goods as either of:
- UN 3480, Lithium-ion batteries
- UN 3481, Lithium ion batteries contained in equipment; or
- UN 3481, Lithium ion batteries packed with equipment.
This article focuses solely on shipping LiBs that are packed by themselves, therefore defined as UN3480. If we check out UN3480 in the register of dangerous goods in the DGR 58, we find that for this category, 8 special provisions and 1 packing instruction apply;
Special Provisions applicable to UN3480
- A88: this provision details air shipment of lithium-ion battery prototypes
A99: lithium-ion batteries over 35 kilograms; these are to be approved by a national authority.
- A154: lithium-ion batteries that are identified as defective for safety reasons or have been damaged, are forbidden for air transport
- A164: an electrical battery that has the potential of dangerous evolution of heat, must be prepared for transport so that short circuit is prevented
- A183: waste batteries (shipped for recycling) are forbidden from air transport unless approved by an appropriate national authority of the State of Origin of the transport, and the State of the operator responsible for transportation: the airline. So if you want to fly a waste battery from Germany on a Chinese aircraft, you need the approval of authorities in both states.
- A201: As transportation of lithium-ion batteries on passenger aircrafts is basically prohibited, only cargo aircrafts may be used. This Special Provision regulates how a state — through its competent authority — can approve a deviation.
- A206: this provision details the use of new and old version of hazard labels
- A331: According to UN3480, “lithium-ion cells and batteries must be shipped at a state of charge (SoC) not exceeding 30% of their rated design capacity.” Exceptions can be made, however, according to special Provision A331. It states that with the approval of the State of Origin and the State of the Operator under the written conditions established by those authorities, deviating from the 30% maximum charge SoC can be allowed.
To compliantly ship LiBs by air, all packages must also be prepared in accordance with Packing Instruction 965.
So what exactly entails Packing Instruction 965? Let’s go over the specifics.
Packing Instruction 965 (PI965) to ship lithium-ion batteries by air
PI965 is divided into 3 sections, but also list some general requirements.
Largely seen this is — apart from the special provisions above — a demand to protect the batteries against any short circuit. There also is a general requirement that states that batteries are not to be over 30% SoC.
In each section, there are regulations about how a lithium-ion battery is supposed to be designed, tested and manufactured in order to use PI965. These can be found in a separate clause within IATA’s DGR: 18.104.22.168.
The 3 sections of Packing Instruction 965
- Section IA; this is the regular requirement — it applies unless you can use one of the other sections with reduced requirements
- Section IB; medium and fairly strict requirements for limited volumes of small LiBs
- Section II; the lowest and less strict requirements for very small quantities of small LiBs
As you can see, section IA entails the most stringent requirements. If you want to ship just a couple of LiBs or smaller ones, you can work with Section IB and II, which have simplified regulations. In some cases, the regulations demand that you use UN-certified packaging. You can read more on testing and certification in our previous blog.
Important: If any of the regulations state that you need the approval by a national competent authority, I advise you to make early contact with your national competent authority to make sure that you comply with any additional regulations they might have.
You see, a national competent authority will not accept anything less than the mandatory packing instructions, but they may have additional packing requirements they want you to meet. The earlier you’re familiar with those requirements, the easier you can adapt and comply.
Developing packaging to compliantly ship lithium-ion batteries by air
I’ve said it before, and I will say it again: the hard thing about regulations is they will never tell you how to make a packaging — they just tell you what requirements you need to meet . So you will need to make an assumption about the design; a design you expect will fulfill the requirements.
You come up with a first concept — based on either your experience or the experience of your packaging supplier — and proofread it against all the regulations. It’s comparable to a law text with clauses you have to pass.
If you would like to know how you can come up with this concept — and ultimately ship lithium-ion batteries by air while meeting DGR battery transportation regulations — you can always schedule a non-binding talk with a dangerous goods packaging specialist to receive free advice on your specific case.
For more information about our solutions for Lithium-ion Batteries please contact us and we get in touch.