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ICAO Adopts Strictest Rules Ever for Air Transport of Lithium Ion Batteries Including 30% State of Charge Limit, Rejects Passenger Aircraft Ban

The International Civil Aviation Organization (ICAO) Dangerous Goods Panel (DGP) agreed to sweeping changes to the lithium ion and lithium metal battery Packing Instructions in the ICAO Technical Instructions for the Safe Transport of Dangerous Goods by Air during its October 19 – 30 meeting in Montreal. The most significant of these is a 30% state of charge (SOC) limit on lithium ion cells and batteries shipped by air in accordance with Packing Instruction 965 of the ICAO Technical Instructions. Cells and batteries may exceed a 30% SOC if approved by the competent authority in the country of origin and the operator (airline).

The DGP’s SOC limit does not apply to lithium ion cells or batteries packed with or contained in products such as cell phones, power tools, tablets, medical devices, electric vehicles and military equipment.

PRBA voiced concerns at the meeting about the impact of such a low SOC limit on cell quality and safety. Lithium ion cells and batteries require protection from both high and low voltages. For example, prolonged low SOC and low voltage conditions could pose a safety hazard and result in dissolution of metals (principally copper) within a cell.

The 30 percent SOC will require cell and battery manufacturers to undertake massive changes to existing manufacturing processes and business practices. PRBA also questioned the DGP’s recommended SOC effective date of April 1, 2016 instead of January 1, 2017, which would typically be the normal transition date for major changes adopted by ICAO. Our members will make every effort to comply with the new SOC limit. However, PRBA fears the April 2016 deadline is setting the battery industry up to fail.

PRBA supported DGP efforts to address battery transport safety concerns through more stringent packaging and shipping regulations under Section II of Packing Instructions 965 and 968 of the ICAO Technical Instructions. The DGP agreed to a prohibition on overpacking small lithium ion and lithium metal cells and batteries shipped in accordance with Section II of Packing Instructions 965 and 968 of the ICAO Technical Instructions.

ICAO continues to develop a performance-based standard for lithium batteries shipped by air. The Secretary of the DGP announced during the October meeting that ICAO has approached SAE International to facilitate the drafting of the standard, with the effort to begin in early 2016.

Finally, by an 11-7 vote, the DGP rejected a proposal to ban the shipment of lithium ion batteries as cargo on passenger aircraft. The majority of the DGP members believed the changes to the ICAO Technical Instructions (i.e., reducing state of charge and more stringent packaging for Section II cells and batteries) would bring the risks to an acceptable level and that these measures would not have the detrimental effect to world-wide demand and commerce if a ban was implemented. The majority also believed that a ban would result in an increase in undeclared shipments and that this would be a risk to safety. They also believed it should be up to each operator to determine whether they could mitigate the risks to an acceptable level based on their own unique assessment. The majority’s arguments against a ban are consistent with the positions PRBA has taken on the issue.

All decisions reached by the DGP must be reviewed and accepted first by the ICAO Air Navigation Commission and then the ICAO Council, which meets in January 2016. The ANC may modify or even reject the DGP changes. After the ANC accepts the proposed amendment, the group forwards the changes to the ICAO Council for formal acceptance. Only after the ICAO Council acts can the new Technical Instructions be amended.

The International Air Transport Association (IATA) has released a summary of these changes, which can be downloaded here.

For more information on PRBA’s participation in the ICAO DGP meetings and the changes to the lithium battery Packing Instructions in the ICAO Technical Instructions, contact PRBA Executive Director George Kerchner at or 202.719.4986.