How to ship lithium batteries by air—as of April 1, 2016

Have you seen all the headlines lately about shipping lithium batteries by air? How are you supposed to keep up with what’s compliant, and what isn’t?

Here’s a guide to the lithium battery air transport regulations which will be effective on the 1st of April, along with a preview of what might be expected later in the year.

All standalone lithium batteries will be prohibited as cargo on passenger aircraft

In February, the International Civil Aviation Organization (ICAO)—the United Nations agency that regulates the transport of dangerous goods aboard aircraft —enacted a ban on transporting standalone lithium ion batteries (UN 3480) as cargo on passenger aircraft. The ban goes into effect April 1, 2016.

Since lithium metal batteries (UN 3090) were already prohibited, the new regulation means no standalone lithium batteries, in any quantity or packaging, may be shipped as cargo on passenger aircraft.

Can you still ship lithium batteries by air? Yes.

Batteries packed with or in equipment (UN 3091 and 3481) may still be shipped compliantly, subject to regulations. (Passengers may still transport their battery powered devices and spare batteries in their carry-on bags—for now. See https://www.faa.gov/about/initiatives/hazmat_safety/more_info/?hazmat=7 for FAA’s guidance)

And all lithium batteries may still be transported on cargo-only aircraft, subject to regulations—see below.  However, you need to be aware that airlines may have variations in place even though the regulations don’t prohibit them on cargo aircraft.

How will the new ban affect supply chains? Labelmaster’s Bob Richard predicts the impact will be severe, including severe difficulties in meeting mission critical and medical necessity applications.

New state of charge limitations, consignment and OVERPACK restrictions

ICAO has also mandated that, effective April 1, 2016, standalone lithium ion batteries (UN 3480) can only be shipped by air with a state of charge 30% or less. In addition, shippers will be not be authorized to transport more than one package of standalone lithium ion batteries prepared in accordance with packing instruction 965 or 968 Section II per consignment. “A shipper is not permitted to offer for transport more than one package prepared according to Section II in any single consignment.”  A consignment is defined as: ” One or more packages of dangerous goods accepted by an operator from one shipper at one time and at one address, receipted for in one lot and moving to one consignee at one destination address.”

No more than one Section II lithium battery package may be placed into an overpack.

Section II packages may not be offered in a unit load device and must be offered separately from other non-dangerous cargo.

So, come April 1st, if you have to ship lithium ion batteries by air which are not packed with equipment, you’ll have to:

  • Ship them by cargo aircraft only (if the airline hasn’t filed a variation or implemented an embargo)
  • Ensure they are at a state of charge no more than 30% of capacity
  • Pack them separately from everything else

How will shippers verify the state of charge of prepackaged batteries? How can you manage the more restrictive packing rules? Labelmaster’s Nikki Burgess reports that everything you know about lithium battery shipping may change.

New lithium battery markings and labels

You will need to begin using new markings and Class 9 hazmat labels for all lithium battery shipments—but not until January 1, 2019. (Early adopters are free to use them voluntarily on January 1, 2017.)lithbathandlenewnewhazclass9

Rumors of lithium batteries earning their own hazard Class 10 were thus put to rest, at least for the time being.

Will all air shipment of lithium batteries be banned?

Well let’s hope not because the current restrictions will be devastating enough to supply chains. The societal impacts remain to be fully realized. Each airline will be conducting independent risk assessments based on guidance published in a FAA Safety Alert for Operators (SAFO).  Some airlines may never again accept lithium batteries but only time will tell. Certainly they may be more selective with respect to which shippers they will accept them from. In the interim following the recent ICAO actions many additional airlines will be filing variations. It will be difficult at best to transport lithium batteries by air. The Society of Aeronautical Engineers has started work on a performance standard and it is hoped that once it is completed the lithium battery restrictions will be revisited by ICAO and the airlines.

Questions about shipping lithium batteries by air? We have answers! Call Labelmaster TOLL-FREE at 1-800-621-5808, or contact us.

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