As sodium-ion batteries and lithium-sodium hybrid batteries gradually achieve industrialization and commercialization, the international aviation dangerous goods regulations have also undergone significant iterations. The IATA "Dangerous Goods Regulations" (DGR) version 68 (2027 edition) was officially released, incorporating all the revisions from the ICAO "Technical Instructions" 2027-2028 and the IATA Dangerous Goods Committee. The new regulations not only complete the air transportation compliance framework for new types of batteries but also significantly tighten the provisions regarding passengers' carrying of batteries, having a direct impact on battery manufacturing, foreign trade exports, cross-border logistics, and airlines. This version is scheduled to be officially implemented on January 1, 2027.
一. New batteries officially included in the aviation dangerous goods regulatory system
For the emerging sodium-ion batteries and lithium-sodium hybrid batteries in the industry, the 68th edition DGR added classification rules, United Nations numbers, and corresponding packaging requirements, filling the previous regulatory gaps.
1. Two new UN numbers for batteries were added
• UN 3563: Lithium-metal batteries integrated and installed inside the freight unit
• UN 3564: Sodium-ion batteries integrated and installed inside the freight unit
2. Lithium-sodium hybrid batteries clearly classified
New clause 3.9.2.6.1 (h) and special regulation A235 specifically provide classification determination logic for mixed batteries that contain both lithium-ion cells and sodium-ion cells, addressing the previous lack of clear regulatory guidance for mixed chemical systems batteries.
3. Expanded scope of exception clauses
The transportation exemption range for onboard data recorders has been expanded, and sodium-ion batteries that meet the conditions can enjoy the exception clause and do not need to follow the full dangerous goods transportation process.
4. Several special regulations adapted to sodium/n lithium batteries
Existing special regulations A107, A185, A213, A225, and A228 were revised, adding applicable explanations for sodium-ion batteries.
二. Rules significantly tightened for passengers and crew carrying batteries
2.3 chapter made structural adjustments for passengers and crew carrying dangerous goods, with significant changes for chargers, backup batteries, and battery-powered walkers.
1. Establishment of a hard line for charger management
• Lithium-ion chargers with a rated energy greater than 100Wh are prohibited for passengers and crew to carry, and this control requirement also applies to equipment issued by law enforcement agencies.
• The carrying limit for chargers is fixed at 2, and this restriction cannot be relaxed by the carrier; the carrying limit for backup batteries has been reduced from the original 20 to 18, and airlines can relax the number of backup batteries based on actual circumstances.
Note: The count of chargers and backup batteries is independent, and while carrying 2 chargers, one can also carry up to 18 backup batteries.
2. Adjustment of calculation logic for battery-powered walkers
Lithium batteries for wheelchairs and walkers are no longer based on a single battery as the limit, but instead, a total energy of 300Wh for a single device is the threshold for determination; if the total energy exceeds 300Wh, additional transportation conditions must be met, and approval from the carrier must be obtained in advance.
The limit for built-in batteries in portable consumer electronic devices is clearly calculated based on "a single device".
3. Reconstruction and splitting of the passenger carrying form
The old form 2.3.A was split into three independent forms:
a. Form 2.3.A: Items that require approval from the airline to be carried
b. Form 2.3.B: Items that can be carried directly without approval
c. Form 2.3.C: Prohibited items, a transitional form that will be deleted in DGR version 70.
4. Updates for other personnel carrying
• New clause 2.3.0.9 establishes control for safety risks brought by isolated electrical batteries;
• The management requirements for chargers used for flight duties must be written in the operation manual; For personal use charging batteries, they shall follow the rules for ordinary passengers.
三. Key Compliance Points for Packaging, Marking Labels
This update has revised over twenty packaging instructions documents, and updated the battery marking and practical requirements for collective packaging. Enterprises need to pay special attention to these points when implementing the labels and packaging.
1. Multiple Updates to Packaging Instructions
Twenty or more packaging documents including 130, 200, 967, 970, and 978 have been revised. Mainly, the transportation constraints for sodium-ion batteries and the text adjustments for prototype batteries have been supplemented.
Practical Exemption: In the rules of Part II of 967, 970, and 978, the button cells built into the device body are not included in the quantity limit of "up to 4 cells / 2 batteries".
2. Version Iteration of Battery Marking
The old version of battery marking with a phone number field has been officially phased out. In practice, if the goods are labeled with the old version of the marking, they will not be directly rejected, but it is recommended that all shipping enterprises switch to the current version of the marking.
If the packaging box also has battery marking and other dangerous labels (except for the 9th class battery label), the battery marking and other dangerous labels must be arranged on the same surface of the box.
3. Simplification of Collective Packaging Marking
Collective packaging no longer requires replicating all the labels of each contained item. Only the total quantity of dangerous goods inside the collective packaging needs to be marked. The official also provides marking examples.
四. Other Key Revisions that Cannot Be Ignored
1. The exception quantity rules only apply to substances and cannot be used for product categories;
2. A214 adds guidance, clearly distinguishing the classification boundary between battery-driven vehicles and battery-driven equipment; A236 provides regulatory support for the transportation of MRI magnetic resonance imaging equipment; A808 clause is added to manage the two-year transitional period for the deactivation of UN numbers;
3. Strengthening the safety responsibility of carriers: Airlines need to continuously maintain the latest version of operation manuals, establish a special approval process for passengers carrying special dangerous goods, and assess the risk of in-flight dangerous goods fire and emergency response capabilities before forced landing;
4. Cleaning up and optimizing differences between countries and carriers. IATA plans to continue cleaning up non-compliant carrier differences clauses in the 69th edition of the DGR.
五. Action List for Enterprises
1. Product Classification Review: Sodium-ion batteries use a new UN number; Lithium-sodium mixed batteries are classified based on 3.9.2.6.1 (h) + A235.
2. Packaging Scheme Upgrade: Verify the applicable packaging instructions for the product, implement the constraints for sodium-ion batteries, and make good use of the exemption rule for button cell count.
3. Label Marking Update: Eliminate the old battery marking with a phone number and strictly adhere to the requirement of sticking the labels on the same surface.
4. Update of Consumer End Prompt: For charging battery products, update the flight carry instructions in the manual.
5. Pre-risk Investigation: Sort out the differences in the destination country and the corresponding airlines' carriers, to avoid cargo being blocked at the port of arrival.
6. Internal Capacity Building: The foreign trade, logistics, and quality control teams organize training and learning on the new DGR rules.
Warm Tips
The 68th edition of the DGR is expected to come into effect on January 1, 2027. Enterprises engaged in the export of lithium-ion batteries, sodium-ion batteries, and energy storage products are recommended to complete UN38.3 testing and dangerous goods classification identification in advance to reserve sufficient time for the transition to the new regulations and achieve a smooth transition in air transportation business.
