As we reach the end of the year, we need to start planning for the changes that await us in 2022. And if you ship lithium batteries by air, there’s a big one coming.

Lithium batteries have, for the past few years, been divided into high and low-powered types. High-powered lithium batteries must be transported as normal dangerous goods, in Class 9. On the other hand, low-powered lithium batteries are excepted from many of the requirements of the regulations. In most regulations, such as the US Title 49 of the Code of Federal Regulations (49 CFR) Canada’s “Transportation of Dangerous Goods Regulations” (TDGR), this two-pronged approach is pretty straightforward. However, by air under the ICAO Technical Instructions for the Safe Transport of Dangerous Goods by Air and the IATA Dangerous Goods Regulations (IATA DGR), it’s been a little more complicated, particularly when dealing with standalone batteries not installed in or accompanied by equipment in the same package.

Figure 1 – Low-powered Standalone Lithium Batteries

Section IA, IB, and II – What Do They Mean?

Air transport has, unfortunately, been plagued with a number of serious accidents involving lithium batteries becoming involved in fires. Not only do lithium batteries have an unfortunate habit of self-igniting if damaged or packaged improperly, but they can be quite difficult to extinguish in flight. This has particularly been a problem with large amounts of lithium batteries (even smaller consumer batteries) packaged in large quantities, such as skids shipped by manufacturers. Fires from batteries installed in equipment (or packed with equipment) tend not to be as serious since fewer batteries would be in proximity, leading to less heat generated and less tendency to spread. 

Therefore, the International Civil Aviation Authority (ICAO) decided to set some very strict limits on how many standalone lithium batteries could be packaged together. For lithium metal batteries in UN3090, these limits can be found in Packing Instruction 968, while for lithium-ion batteries in UN3480, you can find the information in Packing Instruction 965.

The regulators created one standard for high-powered lithium batteries and two options for low-powered shipping batteries. First, for high-powered batteries, they created what they called the IA option. This is for the following power ratings:

  • Lithium-ion cells, over 20 Watt-hours
  • Lithium-ion batteries (two or more cells connected together), over 100 Watt-hours
  • Lithium metal cells, more than 1.0 gram of lithium metal per cell
  • Lithium metal batteries, more than 2.0 grams of lithium metal total per battery unit

The IA option allows you to ship up to 35 kilograms net weight of high-powered batteries or cells per package in UN specification packaging such as 4G fibreboard boxes. Alternatively, batteries exceeding 12 kilograms with strong, impact-resistant outer casings may be shipped in outer packagings that are not UN specification, but strong enough that, in combination with the casing, the batteries should not be damaged by normal handling incident to air transport.

However, most consumer batteries will qualify as low-powered. This classification includes typical consumer batteries sold in packs, such as the AA or AAA size cells, and spare or replacement batteries for electronic devices such as laptop computers and power tools. The original concept was to ship them as what are called Section II batteries. These would require no other package markings than the “Lithium Battery Handling Mark,” would not require UN specification packaging, and would not require a Shipper’s Declaration for Dangerous Goods for documentation. They would merely have to be noted on the Air Waybill. 

Figure 2 – Lithium Battery Handling Mark

However, as a response to fires involving large pallets of small batteries, the air regulations set an extremely low number per package when using Section II. If the batteries did not exceed 0.3 grams of lithium or 2.7 Watt-hour per cell, you could ship up to 2.5 kilograms net per package. This would cover very small batteries such as button (“coin”) cells or AAA cells. For larger batteries that are still in the low-powered range, such as AA cells or replacement batteries for laptop computers, you would be restricted to no more than eight cells or two batteries per box. This would mean, for example, that it would not be possible to ship a 16-cell blister pack of AA cells by air under Section II. Also, you could not ship more than one such package per overpack, such as a skid. In the eyes of the air industry, this would prevent high concentrations of lithium batteries from being shipped with reduced transport requirements in a way that would contribute to a severe risk of fire.

To allow slightly larger packages of low-powered standalone batteries, a third option was created, called Section IB. This option would allow you to ship up to 2.5 kg of lithium metal batteries or 10 kg of lithium-ion batteries that met the power rating limits of Section II. However, the package would have to display both the Lithium Battery Handling Mark and all the requirements for a fully-regulated IA package, such as a Class 9 label, shipping name, UN number, and addresses. In addition, the shipment would have to be documented on the Shipper’s Declaration for Dangerous Goods. The main benefit was that the package would not have to be a UN specification package.

Note that standalone batteries under UN3090 and UN3480 have been, for many years, banned from passenger aircraft. The section used (IA, IB, or II) would not affect this prohibition against standalone batteries being shipped on passenger aircraft.

Even this compromise didn’t satisfy many airlines. A number of airlines, such as FedEx Express and UPS, adopted operator variations that barred the acceptance of Section II lithium batteries, forcing shippers to use Section IB even when, say, shipping a package of two button cells per box. They would still accept Section II shipments, but only if the batteries were installed in or packed with equipment. This created a great deal of confusion, where a perfectly legal package prepared as a Section II for UN3090 or UN3480 might be delayed or even become undeliverable due to carrier restrictions.

The Solution – Eliminate Section II for Standalone Batteries

ICAO and IATA have eventually resolved this, although not perhaps in a way that satisfies the shippers of large amounts of low-powered batteries. The solution was simply to remove the option of using Section II for standalone batteries. 

So, if you refer to the 2022 edition of the IATA Dangerous Goods Regulations (63rd edition), you will not find Section II in Packing Instructions 965 and 968, as in previous years. Instead, the only options in those instructions are to ship as Section IA (fully regulated) or Section IB (reduced packaging requirements, but full package marks and labels and a Shipper’s Declaration required). There will be a note that the Section II provisions found in the 62nd Edition from 2021 may be used until the 31st of March, 2022. This should give those companies who have been using this provision enough time to reorganize their systems and, if necessary, retrain their staff.

Note that in Canada and the US, national regulations have not yet been amended to reflect the same restrictions. Canada really doesn’t have to amend TDG since that regulation requires the use of the current ICAO regulations as a standard for air transport. The US may allow the shipment of low-powered lithium batteries by air for the next little while until a subsequent harmonization – however, since most commercial airlines follow the IATA DGR, it would be unlikely that such shipments would be accepted by any of the major air carriers.

Keep in mind, this change only applies to standalone batteries shipped as UN3090 or UN3480. Lithium batteries contained in or packed with equipment (UN3091/UN3481) will still be accepted under ICAO/IATA rules as Section II. Also, the change doesn’t affect the provisions for shipping low-powered lithium batteries by ground (49 CFR/TDG) or by ocean (using the IMDG Code).


While there’s no data yet that this change will improve the safety of shipments of standalone lithium batteries, it does at least simplify the rules for how to ship them. Companies who currently use Section II for shipments of UN3090 and UN3480 will need to make new plans for 2022, but will at least have a three-month transition period. Of course, many companies have found the carrier restrictions on shipping these batteries as Section II has already forced them to use Section IB as a standard.

Have questions about how to ship lithium batteries? Need training for your staff in the updated regulations? Contact The Compliance Center, 1-888-442-9628 (U.S.) or 1-888-977-4834 (Canada). We can help you plan for the future.

Associated Press, “Fires involving Lithium Batteries on Planes,”
Federal Aviation Administration, “Lithium Battery Safety Resources,”
ICAO Dangerous Goods Panel, DGP/28-WP/4, “Deletion of Section II of Packing Instructions 965 and 968,”, “Energizer Watt-Hour Battery Specs,”

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Barbara Foster

Barbara Foster

Barbara Foster graduated from Dalhousie University with a Master’s degree in Chemistry and a Bachelor’s degree in Education. As one of ICC Compliance Center’s most senior employees, she has worked in the Toronto office for the past three decades as a Regulatory Affairs Specialist and Trainer. She is fluent in various US, Canadian, and international regulations involving transportation, including TDG, 49 CFR, ICAO, IMDG, and the ADR/RID. She also specializes in the hazard communication standards of OSHA, WHMIS, CCCR, and the Globally Harmonized System for Classification and Labelling (GHS). Barbara is the author of ICC’s TDG Clear Language Driver and Handler’s Guide. Currently, she is a participant on the Canadian General Standards Board committee where she creates training standards for transportation of dangerous goods in Canada and is a past Chair of the Dangerous Goods Advisory Council.

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