By Michael Yao    Photo：CANVA

Background: Compliance Challenges for High-Value Cargo

Lithium batteries and chemical products are major categories in international air freight. Smartphones, laptops, power tools, energy storage devices, specialty chemicals and high-value raw materials often move by air because transit time matters. The trade-off is a higher compliance burden. The IATA Dangerous Goods Regulations (DGR) set detailed requirements for classification, packing, marking, documentation and handling.

In practice, classification errors, undeclared dangerous goods, unsuitable packaging or missing marks can lead to rejection, rework or delays at the airline or cargo terminal. More importantly, a declaration error can become a safety event.

In July 2020, an Ethiopian Airlines Boeing 777F caught fire in the main cargo deck at Shanghai Pudong International Airport after loading and while awaiting departure. An investigation made public in 2023 concluded that the most likely cause was self-heating and ignition of undeclared chlorine dioxide disinfectant tablets under hot and humid conditions. Investigators ruled out lithium battery cargo as the ignition source. The aircraft was severely damaged, with no casualties reported.

The lesson is not that every chemical shipment is high risk. It is that dangerous goods classification and declaration must be right at the start, because downstream screening and acceptance cannot be expected to correct every upstream error.

For importers, exporters, procurement teams and factory logistics managers, dangerous goods compliance is now part of routine shipment planning. The following four steps focus on the points most likely to affect acceptance and uplift.

Operational Process: Four Steps to Build a Safe Transport Chain

Step 1: Accurate Identification and Classification

This is the foundation of the entire process and one of the most common sources of mistakes.

Lithium Battery Classification

1. Identify the battery type and configuration

Determine whether the shipment contains lithium-ion or lithium-metal batteries, and whether the batteries are shipped alone, packed with equipment, or contained in equipment.

• UN3480: Lithium ion batteries, shipped alone
• UN3481: Lithium ion batteries packed with equipment
• UN3481: Lithium ion batteries contained in equipment
• UN3090: Lithium metal batteries, shipped alone
• UN3091: Lithium metal batteries packed with equipment
• UN3091: Lithium metal batteries contained in equipment

UN3480 and UN3090 batteries shipped alone are forbidden on passenger aircraft and must move under the applicable Cargo Aircraft Only provisions.

2. Check battery size thresholds

• Lithium-metal cells: 1 g lithium content; batteries: 2 g. These are important regulatory thresholds.
• Lithium-ion cells: 20 Wh; batteries: 100 Wh. These are also key thresholds for determining the applicable Section and packing requirements.

These figures are not absolute “cannot fly above this” limits. Larger batteries may still be transported by air, but they are subject to more stringent packing, declaration and aircraft restrictions.

3. Determine the applicable Packing Instruction

The 67th Edition of the IATA DGR applies in 2026 and took effect on 1 January 2026. Lithium-ion and lithium-metal batteries must be assessed against the applicable UN number, configuration and Packing Instructions, including PI 965 through PI 970.

Packing Instructions and Sections differ in packing, marking, documentation, quantity and aircraft limitations. A UN number alone is not enough to release a shipment.

Chemical Classification

1. Obtain a current Safety Data Sheet (SDS)

Ask the supplier for the current Safety Data Sheet (SDS, still commonly called MSDS in industry). Use it as a primary reference for composition, physical and chemical properties, and hazard classification. Local SDS and hazard communication requirements also apply in the country of manufacture, export, import and use.

2. Determine hazard characteristics

Check whether the product falls within hazards such as Class 3 flammable liquids, Class 6.1 toxic substances, Class 8 corrosives, or has subsidiary risks.

3. Determine Packing Group where applicable

• PG I: high danger
• PG II: medium danger
• PG III: low danger

Final classification must follow the UN number, Proper Shipping Name, hazard class and the IATA DGR Dangerous Goods List.

Step 2: Compliant Packaging, Marks and Labels

Packaging Requirements

1. Use packaging required by the applicable Packing Instruction

Dangerous goods must be packed in accordance with the applicable UN number and Packing Instruction. Some shipments require UN specification packaging that has passed UN performance tests, while other provisions apply to different shipment types. “Dangerous goods” does not automatically mean every package must be UN specification packaging.

2. Special protection for lithium batteries

• Protect cells and batteries against short circuit.
• Insulate exposed terminals or provide equivalent protection.
• Secure batteries in the package to prevent movement and damage.
• Where the applicable Section or Packing Instruction requires it, the package must meet performance requirements such as a 1.2 m drop test.

3. Liquid chemical packaging

Inner packaging limits and maximum quantity per package cannot be determined from Packing Group alone. The actual limits depend on the UN number, Packing Group, Packing Instruction and passenger-aircraft or cargo-aircraft quantity limits.

• Confirm compatibility and sealing of inner and outer packaging.
• Use absorbent, cushioning or securing material where required.
• Prevent leakage, breakage or packaging failure caused by pressure differentials.

Marks and Labels

• Dangerous goods hazard labels: the standard size is generally 100 x 100 mm, subject to specific permitted exceptions.
• Battery Mark: show the applicable UN number(s). The current mark no longer requires a telephone number. The legacy 2022-style mark with a phone number may continue to be used until 31 December 2026.
• Handling labels: use Cargo Aircraft Only, Package Orientation and other labels where applicable.
• Shipper information: provide complete name and address as required.

Step 3: Documentation and Declaration

Core Document: Shipper's Declaration for Dangerous Goods (DGD)

For shipments that require a Shipper's Declaration for Dangerous Goods (DGD), confirm the following:

1. Preparation and signature by competent personnel

Personnel should receive dangerous goods training and assessment appropriate to their job function. IATA now uses a competency-based training and assessment (CBTA) framework. The key question is whether the person is competent for the function performed, rather than whether every situation can be reduced to a single universal “IATA DG license.”

2. Information accuracy

• UN number and Proper Shipping Name match.
• Hazard class and subsidiary risk are correct.
• Packing Group is correct where applicable.
• Packaging type, number of packages and quantity match the actual shipment.

3. Language

The DGD is completed in English under the IATA format. Other languages may be added where needed.

Not every lithium battery shipment requires a DGD. Certain shipments prepared under the applicable Section II provisions do not require a Shipper's Declaration, but the remaining packing, marking, labelling and air waybill requirements still apply.

Supporting Documents

• SDS, particularly when the airline or cargo terminal needs to confirm chemical hazards.
• UN 38.3 Test Summary for lithium batteries where applicable.
• UN specification packaging test or compliance documentation where applicable.
• Letters of compliance or other technical documents where required by the country, airline or commodity.
• Government approvals or exemptions where a special provision requires them.

Step 4: Booking and Tender

Airline Selection and Booking

1. Confirm carrier acceptance policy early

Airlines may apply different acceptance policies to dangerous goods, specific UN numbers, battery types and packing configurations. Check the IATA DGR as well as applicable State Variations and Operator Variations.

2. Allow enough preparation time

Dangerous goods usually need more preparation time than general cargo. Where DGD review, special packaging, airline pre-screening or approvals are involved, starting 5 to 7 working days ahead is a practical planning buffer, not a universal IATA legal deadline.

3. Provide preliminary shipment information

• UN number
• Proper Shipping Name
• Class / Division
• Packing Group, where applicable
• Number of packages, piece weight and total weight
• Packing method
• Battery Wh rating, lithium content and shipment configuration, where applicable

Early confirmation reduces the risk of discovering after booking that the airline cannot accept the shipment.

Airport Tender Process

• Document pre-screening: dangerous goods shipments normally require document review before physical tender. At Shanghai Pudong, PACTL currently requires pre-screening information and document pre-approval before cargo can proceed to security screening.
• Timing buffer: the official PACTL process confirms that pre-screening is required, but it does not set one universal 48-hour deadline for every shipment. Forwarders commonly recommend allowing about 1 to 2 days to confirm documentation and tender conditions. Treat this as an operational planning guideline, not a published PACTL rule.
• Tender channel: follow the airline and cargo terminal process for acceptance, on-site checks and security screening.
• Acceptance checks: the airline or terminal reviews documentation, packaging, marks and labels using the applicable Dangerous Goods Acceptance Checklist. Packages may be opened for further verification when necessary.
• Security screening: dangerous goods cargo remains subject to applicable aviation security requirements.

Practical Recommendations and Checklists

Organizational Capability

Personnel

• Train at least two people to handle the relevant dangerous goods functions so one absence does not stop a shipment.
• Maintain reminders for training and competency reassessment.
• Run regular internal regulatory updates and refresher sessions.

Process standardization

• Maintain a written dangerous goods transport procedure.
• Use a complete shipment checklist.
• Build a cross-functional communication process from sales and procurement through factory logistics and shipment.

Pre-Shipment Self-Check

Documents

• DGD, where required, is complete and accurate.
• Personnel meet the required training and competency expectations.
• SDS is current and matches the actual product.
• UN 38.3 Test Summary, packaging tests and other supporting documents match the actual battery or packaging.
• Air waybill information is consistent with the DGD, packaging and actual cargo.

Packaging

• UN specification markings are clear where UN specification packaging is required.
• No damage, deformation or leakage is visible.
• Dangerous goods marks and labels are secure and correctly oriented.
• Battery Mark, where applicable, follows the current format and shows the correct UN number(s).
• Absorbent, cushioning and securing materials are used where appropriate.

Cargo

• Lithium batteries are protected against short circuit and accidental activation.
• State of Charge meets the applicable Packing Instruction and Section.
• Chemical packaging compatibility and sealing have been confirmed.
• Piece weight and quantity comply with the applicable IATA DGR and airline restrictions.

SoC key point: UN3480 lithium-ion batteries shipped alone must generally be offered for transport at no more than 30% State of Charge. From 1 January 2026, the same 30% maximum applies to PI 966 Section I and to PI 966 Section II cells or batteries over 2.7 Wh. For PI 967 batteries contained in equipment, reduction to 30% SoC remains a recommendation rather than a blanket mandatory limit.

Partner Evaluation

When selecting a freight forwarder

• Relevant staff have dangerous goods training and practical capability matched to their functions.
• The forwarder understands airline and cargo terminal acceptance procedures.
• It has practical experience with the same or similar commodity.
• It can advise on classification, documents, packing and tender, not just process paperwork.
• It has a reliable destination network.

When selecting an airline

• Published or confirmable dangerous goods acceptance policy.
• Restrictions on specific UN numbers, Packing Instructions or battery types.
• Destination airport and ground handling capability.
• Flight routing, transfer restrictions and service record.

Emergency Preparedness

Before shipment

• Confirm whether cargo insurance covers the specific dangerous goods and review declaration conditions and exclusions.
• Prepare applicable emergency response and product safety information.
• Train relevant personnel in basic emergency response procedures.

If an incident occurs

• Maintain an emergency contact that can be reached promptly.
• Keep electronic backups of key documents.
• Understand the procedures for rejected, returned or non-compliant dangerous goods at origin and destination.

Conclusion: Compliance Is Competitiveness, Safety Is Value

Lithium battery and chemical air freight compliance may look like a long list of technical requirements, but the practical task is straightforward: get classification, documents, packaging and tender conditions right. Regulations change every year, and airline or terminal acceptance policies can change too. Rechecking before shipment is usually cheaper than fixing a rejected consignment.

A stable dangerous goods process reduces rejection, delay, penalties and safety risk, while keeping suppliers, internal teams, forwarders and airlines aligned on the same shipment data.

In dangerous goods transport, “close enough” is rarely enough. A mismatch in classification, packing, documentation or carrier acceptance can affect the entire shipment.

Appreciate if you could share TGL Blog among your friends who are interested in first-hand market information of supply chain and updated economic incidents.