The Federal Aviation Administration (FAA) is implementing stricter regulations for the air transport of lithium batteries, with new rules taking effect in phases starting January 1, 2025, and becoming fully mandatory by January 1, 2026. These changes, based on the International Air Transport Association's (IATA) 66th edition Dangerous Goods Regulations (DGR) with FAA supplements, will significantly impact cross-border e-commerce sellers shipping battery-powered products to the United States.
State of Charge Restrictions: Phased Implementation
The new regulations introduce strict limitations on battery charge levels during transport:
- 2025 Transition Period (January 1 - December 31): Lithium-ion cells and batteries should ideally be shipped at no more than 30% of rated capacity (or showing ≤25% charge). For cells/batteries exceeding 2.7Wh, this becomes mandatory unless granted dual approval from originating country and U.S. operators.
- 2026 Full Enforcement (from January 1): All lithium-ion cells/batteries must ship at ≤30% charge. Batteries exceeding 100Wh that violate this rule may only transport under special conditions with written approval from the Department of Transportation (DOT) and airlines.
Packaging Requirements: New Stacking Test
Packaging types PI966, PI967, PI969, and PI970 must now withstand a 3-meter stacking test equivalent to 24 hours of pressure from identical packages without compromising battery integrity or protective function. Notably, compliance can be demonstrated through technical evaluation or industry experience rather than mandatory physical testing.
Labeling Updates: Inclusion of Sodium-Ion Batteries
The regulations expand to cover sodium-ion batteries and modify labeling requirements:
- "Lithium Battery" labels will be renamed "Battery" labels (retaining the same design but requiring updated UN numbers)
- Class 9 hazard labels will specify "Lithium Ion and Sodium Ion Batteries"
- Effective March 31, 2025, battery-powered vehicles must use UN3556 (lithium-ion) or UN3557 (lithium metal) instead of UN3171, with the same 30% charge limit applying to vehicle batteries.
Testing and Documentation Changes
The rules streamline requirements for button cells while strengthening UN38.3 testing mandates:
- Test summary exemptions for installed button cells reduce documentation burdens
- UN38.3 testing (including altitude simulation, thermal cycling, and short circuit tests) becomes mandatory for all lithium batteries
- Packages containing >24 cells or >12 batteries require additional 1.2-meter free-fall testing
FAA's Damaged Battery Ban
Starting September 2025, the FAA will prohibit air transport (including air express) of damaged, defective, or recalled lithium batteries/devices - even with insulated packaging. Violations may result in cargo seizure and substantial fines.
Implications for E-Commerce Sellers
Cross-border sellers should take proactive measures to ensure compliance:
- Thoroughly review IATA DGR 66th edition and FAA supplements
- Adjust inventory management to accommodate charge limitations
- Redesign packaging to meet stacking requirements
- Update all labeling and UN number references
- Ensure UN38.3 testing completion for all battery products
- Enhance quality control to prevent shipping damaged units
- Partner with logistics providers experienced in hazardous materials transport
These regulatory changes represent significant operational adjustments for businesses shipping battery-powered goods to the U.S. market. Early preparation will be crucial to avoid shipping disruptions and potential penalties.