IATA DGR 67th Edition 2026: New Packaging Requirements for Lithium Batteries

The International Air Transport Association (IATA) 67th Edition of the Dangerous Goods Regulations (DGR) took full effect on January 1, 2026, introducing the most significant tightening of lithium battery air transport rules in years. The most critical change: the 30% State of Charge (SoC) limit, previously a recommendation for batteries packed with equipment, is now a mandatory requirement. Additionally, UN38.3 testing has been upgraded to Revision 8, sodium-ion batteries are now fully integrated into the regulatory framework, and labeling requirements have been updated with a December 31, 2026 deadline for phasing out old mark designs. For manufacturers, exporters, and freight forwarders shipping lithium batteries, power banks, or battery-powered devices by air, understanding these new packaging requirements for lithium batteries is essential to avoid airport rejections, customs holds, and costly logistics disruptions. This guide provides a comprehensive breakdown of all 2026 changes and a practical compliance roadmap.

1. Core Change: Mandatory 30% State of Charge (SoC) for Batteries Packed with Equipment

The most operationally significant update in DGR 67th Edition is the expansion of the 30% State of Charge (SoC) requirement. Previously, the 30% SoC limit applied only to loose lithium-ion batteries (UN 3480, PI 965). Batteries packed with equipment (UN 3481, PI 966) were only “recommended” to be shipped at ≤30% SoC, not mandatory. From January 1, 2026, this has changed.

For UN 3481 – Lithium-ion batteries packed with equipment – Packaging Instruction 966, the 30% SoC limit is now mandatory for all batteries or cells exceeding 2.7 Wh. Batteries packed with equipment that exceed 30% SoC may only be shipped with prior approval from both the state of origin and the operator under Special Provision A331, which is difficult to obtain for routine shipments. For UN 3480 – Lithium-ion batteries shipped alone – PI 965, the 30% SoC requirement remains in force and is now more strictly enforced. For UN 3482 – Lithium-ion batteries contained in equipment – PI 967, a reduced SoC is not mandatory, but IATA strongly recommends shipping at ≤30% SoC or ≤25% indicated battery capacity to maintain consistent safety practices across all battery shipment types.

⚠️ Critical note: The 30% SoC requirement applies to lithium-ion cells and batteries with rated energy exceeding 2.7 Wh. For cells or batteries ≤2.7 Wh (e.g., small coin cells), the 30% SoC rule is recommended but not mandatory, though best practices still favor low SoC shipment.

2. Packaging Instructions at a Glance: PI 965, PI 966, and PI 967

To understand which rules apply to your product, it is essential to distinguish between the three primary packaging instructions for lithium-ion batteries under DGR 67th Edition.

UN 3480 – Lithium-ion batteries alone (PI 965)

  • Applies to: Standalone batteries, power banks, battery packs not installed in any device.
  • SoC requirement: ≤30% of rated capacity (mandatory).
  • Packaging: Must meet UN specification packaging; each package net weight ≤35 kg (Section I) or ≤2.5 kg for small cells (Section II).
  • 3-meter stack test required: Packaging must withstand stacking of 3 meters without damage.
  • Labeling: Class 9 hazard label, lithium battery mark (with UN number), “Cargo Aircraft Only” label (unless passenger aircraft permitted).

UN 3481 – Lithium-ion batteries packed with equipment (PI 966)

  • Applies to: Batteries shipped in the same package as equipment but not installed inside the equipment (e.g., electric drill with a separate spare battery in the same carton).
  • SoC requirement: ≤30% of rated capacity (mandatory for any cell/battery >2.7 Wh). This is the biggest change from prior editions.
  • Packaging: Batteries must be protected from short circuit and secured against movement; outer packaging must be strong enough to withstand normal transport conditions.
  • 3-meter stack test required: Packaging must be tested to withstand 3 meters of stacking pressure.
  • Labeling: Lithium battery mark (without Class 9 hazard label for Section II; Section I shipments require Class 9 label).

UN 3481 – Lithium-ion batteries contained in equipment (PI 967)

  • Applies to: Batteries already installed inside the equipment (e.g., smartphone with internal battery, laptop).
  • SoC requirement: No mandatory limit, but ≤30% SoC or ≤25% indicated capacity strongly recommended.
  • Packaging: Equipment must be protected against accidental activation; outer packaging does not require UN specification but must be adequate for the equipment.
  • Labeling: Generally no lithium battery mark required unless the package contains more than 4 cells or 2 batteries installed in equipment, in which case the mark may be required.

3. UN38.3 Rev. 8: Testing Standards Upgraded

The UN Manual of Tests and Criteria, Revision 8, became mandatory for all lithium battery air transport certifications from January 1, 2026. Any UN38.3 test reports issued prior to 2026 based on Revision 6 or Revision 7 are no longer valid. Key updates in Rev.8 include:

  • New compound test: Temperature cycling (50 cycles from -20°C to +60°C) combined with mechanical shock (150g) – more rigorous than previous separate tests.
  • Enhanced vibration and shock parameters: Testing conditions are now more closely aligned with actual air transport vibration profiles.
  • Stacking test (3 meters): For larger battery packages, packaging must demonstrate the ability to withstand 3 meters of stacking pressure without damage to the batteries or packaging integrity.
  • Tighter documentation requirements: All UN38.3 test reports must now include complete raw test data, traceable to the specific lab, with the lab‘s CNAS or A2LA accreditation visible.

Shippers must ensure their UN38.3 test reports explicitly reference “Rev.8” or the latest edition. Reports based on earlier revisions will be rejected by airlines and ground handlers, resulting in shipment denial. The eight mandatory test procedures under UN38.3 remain: altitude simulation (low pressure), thermal cycling, vibration, shock, external short circuit, impact/crush (as applicable), overcharge (for rechargeable batteries), and forced discharge (for primary batteries). Any single test failure results in immediate prohibition from air transport.

4. Sodium-Ion Batteries: New UN Numbers and Full Integration

DGR 67th Edition formally incorporates sodium-ion batteries (with organic electrolyte) into the dangerous goods framework, reflecting their growing commercial use as alternatives to lithium-ion technology. New UN numbers and packaging instructions have been established:

  • UN 3551 – Sodium-ion batteries (alone) – assigned to Packaging Instruction 977.
  • UN 3552 – Sodium-ion batteries packed with or contained in equipment – assigned to Packaging Instruction 978.

While the ICAO Technical Instructions do not yet mandate specific SoC limits for sodium-ion batteries, IATA recommends aligning with lithium-ion best practices: ≤30% SoC where practicable. The battery mark now requires the appropriate UN number (3551 or 3552) to be displayed. As sodium-ion technology continues to develop, shippers should anticipate further regulatory evolution in upcoming DGR editions.

💡 Pro tip: For shippers currently developing sodium-ion battery products, early adoption of the new packaging instructions and labeling requirements will ensure seamless compliance as the technology scales.

5. Labeling and Marking Updates: 2026 Changes and the December 31, 2026 Deadline

Several labeling and marking changes took effect in 2026, with a key deadline approaching at the end of the year.

5.1 Lithium Battery Mark Renamed to “Battery Mark”

The former “lithium battery mark” is now simply the “battery mark”, reflecting the inclusion of sodium-ion batteries. The mark must now display the appropriate UN number:

  • UN 3090 – Lithium metal batteries (alone)
  • UN 3480 – Lithium-ion batteries (alone)
  • UN 3551 – Sodium-ion batteries (alone)
  • UN 3091, UN 3481, UN 3552 – when packed with or contained in equipment

In addition, the UN number must be displayed on the battery mark, and the mark must be at least 120 mm × 110 mm in size (smaller marks of 74 mm × 105 mm are permitted for smaller packages, but visibility remains a key requirement).

5.2 Class 9 Hazard Label Renamed

The Class 9 hazard label (for miscellaneous dangerous goods) has been renamed from “Lithium battery” to “Lithium-ion and sodium-ion batteries” to clarify that it applies to both battery chemistries. The diamond shape remains the same, but the wording on the label is now updated.

5.3 December 31, 2026 Deadline: Old Lithium Battery Handling Labels Must Be Phased Out

Critical deadline: The older version of the lithium battery handling label (which previously included a telephone number) must be completely phased out by December 31, 2026. After this date, any packages bearing the old label design will be rejected by airlines and freight handlers. The new label design features a clearer, standardized symbol combining a battery icon and a flame symbol to emphasize fire risk. Key features of the new label:

  • No telephone number required: The previous requirement to display an emergency contact telephone number on the handling label has been removed.
  • Larger and more visible: Labels must be placed on the outer packaging where they are easily visible to handlers and emergency responders.
  • Watt-hour rating or lithium content: Packages must include the battery’s watt-hour rating (for lithium-ion) or lithium metal content (for lithium metal).
  • Bilingual text: Labels must include text in English and the local language of the shipping origin or destination, improving clarity for international handlers.

Shippers should immediately review their label inventory and order compliant labels for all 2026 shipments. Use of the older marked labels is prohibited after December 31, 2026, and airline acceptance staff are already being trained to reject non-compliant labels.

6. CAAC MH/T 1086-2026: China‘s New Testing Standard for Large Lithium Batteries

In February 2026, the Civil Aviation Administration of China (CAAC) released industry standard MH/T 1086-2026 – “Specific Requirements for the Transport of Dangerous Goods by Air — Test for Large Lithium Batteries”. This standard applies to large power lithium batteries weighing more than 35 kg, which require special approval from civil aviation authorities before air transport under ICAO Technical Instructions. The MH/T 1086-2026 standard specifies testing requirements from multiple perspectives:

  • Transport conditions testing
  • Thermal safety tests (including thermal runaway and thermal propagation testing)
  • Package integrity tests
  • Test report format and documentation requirements

For manufacturers of large-format lithium batteries (e.g., for electric vehicles or energy storage systems), compliance with MH/T 1086-2026 is now required for securing special approval for air transport. The standard was developed with input from battery manufacturers, testing institutions, airlines, and airports to support the export of domestically produced large power lithium batteries. International shippers of large lithium batteries should engage with CAAC-accredited testing labs to ensure compliance before shipping.

7. 3-Meter Stack Test Requirement

For packages containing lithium batteries under PI 965 (alone), PI 966 (packed with equipment), and the equivalent sodium-ion packaging instructions, a 3-meter stacking test is now mandatory. This test ensures that outer packaging can withstand the pressure of being stacked up to 3 meters high (approximately 6-8 packages depending on weight) without damaging the batteries or compromising packaging integrity. The test must be performed by a UN-certified testing laboratory and documented in the packaging test report. For shippers, this means:

  • Your packaging supplier must provide certified test reports demonstrating compliance with the 3-meter stack test.
  • The packaging design cannot be modified without re-testing.
  • Individual package weight is capped to ensure stacking safety – typical limits are 35 kg per package for PI 965 Section I shipments.

8. New Exception for Data Loggers and Cargo Tracking Devices

A significant clarification in DGR 67th Edition provides relief for certain battery-powered cargo tracking devices. Under Section 1.2.7, data loggers and cargo tracking devices (used to monitor temperature, location, or shipment conditions) that contain lithium batteries are not subject to most IATA DGR requirements if all the following conditions are met:

  • The devices are in use or intended for use during transport.
  • The lithium cells or batteries comply with UN testing standards.
  • Lithium-ion batteries do not exceed 20 Wh per cell or battery.

However, the exception does not apply if the device is shipped as a consignment under Packing Instruction 967, 970, or 978. In those cases, full dangerous goods compliance remains required. This exception is particularly valuable for pharmaceutical cold chain shipments and high-value cargo monitoring where tracking devices must be placed inside temperature-controlled containers.

9. Documentation Requirements: Mandatory Compliance Elements

Under DGR 67th Edition, the following documents are mandatory for lithium battery shipments:

  • UN38.3 Rev.8 Test Report: Must be issued by a CNAS- or A2LA-accredited lab, with full test data and traceable to the specific battery model. Reports from Rev.6 or Rev.7 are invalid after January 1, 2026.
  • Safety Data Sheet (SDS) / Material Safety Data Sheet (MSDS): Must include UN number, proper shipping name, and classification.
  • Air Transport Identification Report (Aviation Condition Certificate): Often called “航空运输鉴定书” – mandatory for air freight, certifying compliance with IATA DGR 67th Edition (e.g., SoC ≤ 30% for high-energy batteries).
  • Shipper‘s Declaration for Dangerous Goods (DGD): Required for Section I shipments (larger batteries). Must be signed by a trained dangerous goods shipper.
  • State of Charge Declaration: Many airlines now require a separate SoC declaration or an annotation on the DGD stating “State of Charge: ≤30%”.

Shippers should work closely with their freight forwarders to ensure that all required documents are available and consistent before offering cargo to airlines. Inconsistent information (e.g., different battery model numbers on the UN38.3 report and the commercial invoice) is a leading cause of rejection at airport acceptance counters.

10. Compliance Roadmap for Shippers and Manufacturers

To navigate the new requirements successfully, follow this step-by-step compliance plan:

  1. Update UN38.3 testing to Rev.8: Engage a CNAS-accredited lab to re-test your battery models under UN38.3 Rev.8 if you have not already done so. Allow 6-8 weeks for testing.
  2. Implement SoC controls in production and warehousing: For batteries destined for air freight, ensure that final production includes a discharge step to ≤30% SoC. Use calibrated SoC meters to verify. For batteries stored in warehouses, implement a “first-in-first-out” rotation to avoid unnecessary recharging.
  3. Upgrade packaging to meet 3-meter stack test: Request UN-certified packaging test reports from your packaging supplier. If your current packaging has not been tested to 3 meters, you must source compliant packaging.
  4. Procure new labels and phase out old label inventory: Order compliant battery marks and Class 9 hazard labels with updated text. Plan to exhaust your old label stock before December 31, 2026, or be prepared to dispose of it. After December 31, 2026, any shipment bearing the old label design will be rejected.
  5. Update internal SOPs and train staff: Revise your shipping procedures to reflect the new SoC limits, packaging requirements, and labeling standards. Train warehouse and shipping personnel on the new requirements and document training records.
  6. Work with a qualified freight forwarder: Select a forwarder with experience in dangerous goods and specific expertise in lithium battery shipments. Confirm that the forwarder will review your documentation and label compliance before tendering cargo to the airline.
  7. Stay informed on further updates: DGR is updated annually. Subscribe to IATA‘s battery guidance updates and monitor CAAC announcements for additional China-specific requirements.

11. Real-World Case: Power Bank Manufacturer Loses Shipment to SoC Violation

A Chinese power bank manufacturer shipped 20 pallets of 20,000 mAh power banks via air to Europe. The company assumed that because the power banks were packed in retail boxes (not installed in equipment), the 30% SoC rule applied. However, the manufacturer had not implemented any discharge process, and the power banks were shipped at full charge (>90% SoC). Upon arrival at the Hong Kong hub, airline acceptance staff tested random samples and found SoC levels exceeding 50%. The entire shipment was rejected and returned to the factory. The cost of return shipping, storage fees, and lost sales exceeded $150,000. Lesson: SoC compliance must be verified at the production line, not assumed.

🚀 Need help with IATA DGR 67th Edition compliance for your lithium battery shipments? Contact a global regulatory compliance partner for a free compliance assessment. Our experts will review your battery products, UN38.3 reports, packaging, and labeling – and provide a detailed remediation plan. Request your free consultation today.

Summary: IATA DGR 67th Edition (2026) introduces the most significant lithium battery air transport compliance update in years. Core changes include mandatory 30% State of Charge (SoC) for batteries packed with equipment (PI 966), upgraded UN38.3 Rev.8 testing, full integration of sodium-ion batteries (UN 3551/3552), labeling updates with a December 31, 2026 deadline for phasing out old labels, a 3-meter stack test requirement for packaging, and the new CAAC MH/T 1086-2026 standard for large-format batteries. Shippers must update UN38.3 test reports, implement SoC controls in production, upgrade packaging, procure compliant labels, and train staff. Failure to comply results in airport rejections, shipment returns, and significant financial losses. Proactive preparation is the key to maintaining seamless air freight operations for lithium batteries and battery-powered devices.