Dangerous goods by air: IATA DGR, lithium batteries and the Shipper's Declaration
Air has the strictest dangerous goods rules of any mode, because there's nowhere to go if something catches fire. The legal rules are the ICAO Technical Instructions (TI). Airlines and forwarders work from the IATA Dangerous Goods Regulations (DGR), which include the TI plus the airlines' own extra rules.
Same 9 classes, tighter limits
The classes match sea and road: 1 explosives, 2 gases, 3 flammable liquids, 4 flammable solids, 5 oxidizers and organic peroxides, 6 toxic and infectious, 7 radioactive, 8 corrosives, and 9 miscellaneous (including lithium batteries and dry ice). Every entry in the DGR "List of Dangerous Goods" (section 4.2) gives the UN number, proper shipping name, class, packing group, labels and packing instructions, and the maximum quantity per package for passenger aircraft and for cargo aircraft only.
Passenger aircraft vs cargo aircraft only (CAO)
- Much air freight flies in the hold of passenger aircraft. Some goods are only allowed on freighters, either because the passenger column says "Forbidden" or because the quantity is over the passenger limit.
- These packages carry the orange Cargo Aircraft Only label, and the Shipper's Declaration must say "Cargo Aircraft Only".
- Airlines can be stricter still. Check the operator variations (and state variations) in the DGR before you book.
The Shipper's Declaration for Dangerous Goods
- The shipper fills it in and signs it. It shows the UN number, proper shipping name, class, packing group, quantity and type of packing, packing instruction, and any authorisations. Your forwarder can't sign it for you unless they actually prepared the shipment and are trained to.
- Some shipments don't need one, such as excepted quantities and Section II lithium batteries. They still have to meet every other requirement and carry the right marks.
- The airline does an acceptance check, and any mistake (a missing label, the wrong UN-spec box, a typo on the declaration) means the shipment is rejected.
Lithium batteries: packing instructions 965 to 970
| Battery type | On its own | Packed with equipment | Contained in equipment |
|---|---|---|---|
| Lithium-ion (UN 3480 / 3481) | PI 965, UN 3480. Cargo aircraft only. State of charge (SoC) no more than 30%. | PI 966, UN 3481. SoC no more than 30% is mandatory from 1 January 2026 (Section I, and Section II batteries over 2.7 Wh). | PI 967, UN 3481. SoC no more than 30% (or indicated capacity no more than 25%) is recommended. |
| Lithium metal (UN 3090 / 3091) | PI 968, UN 3090. Cargo aircraft only. | PI 969, UN 3091. | PI 970, UN 3091. |
- Every cell and battery type must have passed UN 38.3 testing. The manufacturer or distributor must make the UN 38.3 test summary available.
- Section I shipments are fully regulated: Class 9 lithium battery label, Shipper's Declaration and UN-spec packaging. Section II shipments, for smaller batteries in limited numbers, use the lithium battery mark and don't need a declaration, but they still have limits and trained staff.
- Shipping lithium-ion batteries at more than 30% state of charge needs approval from both the State of Origin and the State of the Operator (special provision A331).
- Damaged, defective or recalled batteries are forbidden by air unless the authorities give special approval.
- Vehicles powered by lithium-ion or sodium-ion batteries have their own state-of-charge rules under PI 952. Sodium-ion batteries (UN 3551 and 3552) have their own packing instructions.
UN-specification packaging
Most fully regulated DG by air must go in UN-specification packaging that is tested to the right performance level (X, Y or Z) and marked, for example 4G/Y10/S/26/GB/…. Air adds extra rules: liquids need packaging that can withstand the pressure differences of flight (a 95 kPa test for some), the inner packagings must be leak-proof, and closures must be secured. Assemble the packaging exactly as the manufacturer's closing instructions say.
Labels and handling labels
- Use the class hazard labels (100 × 100 mm) and mark each package with the UN number, proper shipping name, and the shipper's and consignee's details.
- Handling labels: Cargo Aircraft Only, orientation arrows (for liquids), Keep Away From Heat, Magnetized Material, Cryogenic Liquid, the lithium battery mark (Section II), and the Class 9 lithium battery label (Section I).
- Remove or cover any old, irrelevant labels on reused boxes.
Forbidden and hidden dangerous goods
- Some items are forbidden in any circumstances, such as unstable or very sensitive explosives. Others are only forbidden on passenger aircraft. Check the passenger and cargo columns in the List of Dangerous Goods.
- Watch for hidden DG in general cargo: spares for vehicles and machines (fuel, airbags, batteries), diagnostic kits, camping gear, tools with batteries, paints, aerosols and perfumes. If you're not sure, ask for the SDS.
Who must be trained?
Since 1 January 2023, ICAO requires competency-based training and assessment (CBTA). Every employer whose staff prepare, offer, accept or handle DG for air must train and assess them before they do the job, keep training records, and refresh the training within 24 months. That includes shippers, freight forwarders, ground handlers and airlines. In the UK, the Air Navigation (Dangerous Goods) Regulations 2002 require shippers and their agents to make sure everyone who prepares a DG consignment is trained. The CAA oversees this, and some training programmes need CAA approval (see CAP 483).
Packaging & labels
- UN-approved fibreboard boxes and combination packs (air-rated)
Including 95 kPa-capable inner packagings for liquids - UN-approved drums and jerricans
1A2, 1H2 and 3H1 drums and jerricans, where the packing instruction allows them - DG hazard labels and handling labels
Class labels, Cargo Aircraft Only, orientation arrows and Keep Away From Heat - Absorbent and cushioning material
For liquids, where the packing instruction requires it - Lithium battery marks and Class 9 lithium battery labels
Section II marks and Section I hazard labels, in the correct sizes
Links marked (Ad) may be affiliate links, which means we may earn a small commission if you buy, at no extra cost to you. Always check that packaging is UN-approved for your substance, packing group and mode of transport.
Sources
- IATA, Dangerous Goods Regulations (DGR): new edition each year, valid 1 January to 31 December, plus addenda (accessed October 2026).
- IATA, Lithium battery guidance: 30% state of charge for PI 966 from 1 January 2026, and special provision A331.
- ICAO, Dangerous Goods: Technical Instructions for the Safe Transport of Dangerous Goods by Air (Doc 9284), 2025–2026 edition.
- UK Civil Aviation Authority, Dangerous goods training requirements and CBTA for dangerous goods.
- legislation.gov.uk, Air Navigation (Dangerous Goods) Regulations 2002, regulation 13: training.
- GOV.UK (DfT), Moving dangerous goods.
Guidance only. This is a simplified summary, not the official text and not legal advice. Always use the current IATA DGR or ICAO TI, check the airline's variations, and have shipments prepared by trained, certified staff.