SHIPPING

BATTERIES

SAFELY BY AIR

What You Need To Know

Shipper Guide Batteries Air.indd1 1 3/19/2009 2:09:4
Shipper Guide Batteries Air.indd2 2 3/19/2009 2:09:4
SHIPPING BATTERIES SAFELY BY AIR 

This guide is written to help you ship batteries safely by air. It is not a substitute for the 

Hazardous Materials Regulations (HMR; 49 CFR Parts 100-185). Every effort has been 

made to provide a simplified guide consistent with the HMR. However, if there is any 

instance in which this guide is inconsistent with the HMR, the regulations themselves are 

the final authority for proper shipping procedures. If you have questions about a specific 

shipment, please call our Hazardous Materials Info-line at 1-800-467-4922.

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SHIPPING BATTERIES SAFELY BY AIR 

Contents

Why Are Batteries Regulated in Transportation? 2

Lithium Batteries 6

Is Your Lithium Battery Small, Medium, or Large? 8

Examples of Lithium Batteries 9

What requirements apply to “Small” Lithium Batteries? 10

What requirements apply to “Medium” and “Large” Lithium Batteries? 12

Wet Batteries 14

Nonspillable Batteries 16

Dry Batteries (Excluding Lithium) 18

Battery-powered Vehicles and Equipment 20

Batteries Contained in or Packed with Equipment 22

Shipper Guide Batteries Air.indd1 1 3/19/2009 2:09:53 


Why Are Batteries 

Regulated in Transportation?

Batteries are woven into the fabric of modern American life. They power portable 

computers, phones, and audio devices. They make possible motorized wheelchairs and 

cordless tools. We have come to depend on batteries for an increasingly mobile lifestyle. 

Today’s batteries contain more power than ever, making possible a steadily growing 

number of higher-powered devices on the market. But with that increased power comes 

greater risk and the need to manage the risk. Shippers can play an important role in 

reducing this risk and preventing incidents including fires aboard aircraft.

Batteries present both chemical (e.g., corrosive or flammable electrolytes) and electrical

hazards. Dangers associated with batteries include chemical burn, fire, and electrical 

shock. Batteries can be dangerous if not safely packaged and handled when transported. 

Misused, mishandled, improperly packaged, improperly stored, overcharged, or defective 

batteries can short circuit, overheat, and sometimes cause a fire. In addition, some of the 

chemicals in batteries can pose hazards if they are released.

In general, the risks posed by batteries are a function of battery size and chemistry. Certain 

battery types are of greater concern when transported. For example, unlike standard 

alkaline batteries, most lithium batteries manufactured today contain a flammable 

electrolyte and have a higher energy density. They can overheat and ignite under certain 

conditions and, once ignited, can be difficult to extinguish. In addition, although an 

infrequent event, a lithium battery is susceptible to thermal runaway, a chain reaction 

leading to a violent release of its stored energy. Lead-acid and lead-alkali batteries present 

a hazard in transportation if the corrosive electrolyte leaks from a damaged or defective 

battery.

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SHIPPING BATTERIES SAFELY BY AIR 

The Hazardous Materials Regulations (HMR; 49 CFR parts 100-185) include provisions 

for packaging, hazard communication (package marking, labeling, and shipping papers), 

and handling batteries and battery-powered devices. The purpose of these regulations is 

to protect the safety of people and property when batteries and battery-powered devices 

are being shipped. If the applicable minimum regulatory requirements are not followed, 

these shipments may contribute to fires, injuries, or other incidents during transport. 

Failure to comply with the applicable regulations may result in a fine or even jail time.

This document provides guidance on methods of safely transporting batteries and 

battery-powered equipment in compliance with the regulations. There is generalized 

guidance on proper packaging and handling methods and also greater detail where 

necessary for a better understanding of the requirements of the HMR. This guide 

also provides a framework for compliance with international regulations for those 

shippers transporting batteries and battery-powered devices internationally. Most of 

the requirements in the HMR are the same as international regulations and standards. 

However, there are some different requirements and/or different dates for compliance. 

For international shipment of batteries and battery-powered equipment by air, we 

recommend shippers consult the International Civil Aviation Organization (ICAO) 

Technical Instructions for current and up-to-date requirements. Publications and 

regulations issued by ICAO can be found at www.icao.int. For both domestic and 

international shipments, we also recommend checking with your air carrier for any 

additional requirements that it may impose.

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4

Battery ncdent?

Certain types of incidents must be reported to PHMSA. 

Incidents involving batteries and battery powered 

devices including those that result in a fi re, violent 

rupture, explosion, or dangerous evolution of heat must 

be reported. In addition to the written incident report, 

immediate telephonic reporting is required for incidents 

involving batteries and battery-powered devices in air 

transportation. 

You are an crucial part of aviation safety. It is essential that you preserve the batteries and/or 

electronic equipment involved in an incident. We ask you to contact DOT so that any evidence from 

a battery incident can be transferred to the appropriate authorities for analysis and evaluation.

For further information:

See §§ 171.15 and 171.16

PHMSA’s web site at http://www.phmsa.dot.gov/hazmat/incident-report

The Hazardous Materials Information Center at 1-800-467-4922

PHMSA prepared this guide with the help of FAA, and 

with input from experts in the battery, airline, and shipping 

industries, to assist you in safely packaging batteries for 

transport by air. Whether you are shipping a single battery, 

a palletized load of batteries, or a battery-powered device, 

the safety of your package, and of the people who handle 

it along the way, depends 

on compliance with these 

regulations.

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SHIPPING BATTERIES SAFELY BY AIR 5

Enclose batteries in 

plastic blister wrap, 

pasteboard, or other 

inner packaging that 

will protect each 

battery from making 

contact with another 

battery or any item 

that is capable of 

causing a short-circuit.

Batteres and battery-powered devces can 

be a safety rsk when transported by ar.

Batteries may spark, overheat or even catch fire 

if they short-circuit. A short circuit can happen 

any time something which conducts electricity 

touches both terminals on a battery. For example, 

a tool, a set of keys, or wiring could bridge the 

terminals, creating a short circuit. Additionally, 

damaged batteries may lead to short-circuiting 

or contribute to a fire through release of stored 

energy or may release hazardous contents such 

as corrosive battery fluid. Packaging batteries to 

protect terminals, especially from metallic objects, 

reduces risk in transportation and increases safety. 

Implementing measures to prevent inadvertent 

activation of battery powered equipment also 

contributes to increased safety. Proper packaging 

is one of the most critical measures that a shipper 

can take to prevent incidents and enhance safety. 

Batteries should be individually packaged (when 

practical) or separated to prevent damage and 

short circuiting.

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What’s dfferent about lthum batteres?

Rechargeable lithium batteries (also called lithium 

ion (Li-ion), or secondary lithium batteries), and nonrechargeable lithium batteries (also called lithium 

metal, or primary lithium batteries), provide more 

energy and a longer operating life than other battery 

chemistries. They have the potential to generate a 

signifi cant amount of heat or catch fi re if damaged or 

improperly packaged, cared for, or constructed than 

do other batteries. In recognition of these facts, the U.S. 

and international regulations (i.e., ICAO TI) pertaining 

to the transportation of lithium cells and batteries have 

changed signifi cantly in recent years.

Note: The ICAO TI have different shipping names when describing 

lithium batteries. We recommend that shippers consult the ICAO TI 

when shipping internationally.

Lithium Batteries

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SHIPPING BATTERIES SAFELY BY AIR 7

You can safely and easily ship most consumer-type lithium 

batteries, both rechargeable and non-rechargeable varieties, 

if certain precautions are taken to prevent short circuits, 

overheating, and inadvertent operations. These batteries include 

camera batteries, notebook computer batteries, and cell phone 

batteries.

Non-rechargeable (i.e., metal/primary) lithium batteries MAY NOT be transported 

as cargo aboard passenger aircraft and packages containing those batteries must 

be marked*:

“PRIMARY LITHIUM BATTERIES—FORBIDDEN FOR TRANSPORT ABOARD 

PASSENGER AIRCRAFT” 

or

“LITHIUM METAL BATTERIES—FORBIDDEN FOR TRANSPORT ABOARD 

PASSENGER AIRCRAFT”

*Letters must be at least 6mm high for packages with a gross weight of 30 kg or less and 12 mm high for packages with a gross weight of over 30 kg.

Damaged or defective lithium batteries or devices containing lithium batteries 

(including those being returned to the manufacturer as part of a safety recall) 

are forbidden for transportation by aircraft. Such batteries have the potential of 

producing a dangerous evolution of heat, fire, or short circuit. If your battery or 

batteries are part of a recall or are damaged, you need to take extra care when 

preparing these batteries for shipment. Recommended practices for preparing 

recalled batteries for transportation are set forth in “DOT Guidance for the Safe 

Transportation of Recalled Lithium Batteries,” available for download at http://

safetravel.dot.gov/downloads.html.

do NoT SHIP dAmAGEd, dEFECTIVE, oR 

RECALLEd BATTERIES BY AIRCRAFT.

SHIPPING BATTERIES SAFELY BY AIR 7

Shipper Guide Batteries Air.indd7 7 3/19/2009 2:10:03 


 

1.0 g Li

1.0 g 

and 5 g Li

Battery and Cell

Category Definitions

Small

(no more than)

Medium

(between)

Large

(more than)

1.5 g ELC 2.0 g Li 8 g ELC

1.5 g 

and 5 g ELC

2.0 g 

and 25 g Li

8 g 

and 25 g ELC

5 g Li 5 g ELC 25 g Li 25 g ELC

NonRechargeableNonRechargeable Rechargeable Rechargeable

Cells Batteries

is Your Lithium Battery Small, Medium, or Large?

The regulations for shipping lithium batteries are based on the size of the battery or 

cell to be shipped (a battery is made up of one or more connected cells). These size 

categories depend on the lithium metal or alloy (Li) content of a non-rechargeable 

battery or cell, or the equivalent lithium content (ELC)* for rechargeable lithium 

batteries or cells.

*ELC (g)= rated capacity (Ah) X 0.3; assumes a battery or cell with a rated voltage of 3.7v.

 

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SHIPPING BATTERIES SAFELY BY AIR 9

Determining the lithium content or equivalent lithium content of a battery or 

cell can be complex, so examples are also listed, as are watt-hour equivalencies. 

If the information for determining watt-hour rating (Wh)*, lithium content, 

or ELC is not on your battery or in the information provided with the battery, 

contact the manufacturer, distributor, or Hazardous Materials Information Center 

(HMIC)** for more information.

Examples of Lithium Batteries

Small lthum batteres and cells include cell phone batteries, 

camera batteries, and internal batteries for notebook computers. 

The eight gram equivalent lithium content at the top of the “small” 

range of rechargeable batteries provides about 100 watt-hours 

of power.

medum lthum batteres and cells include larger batteries and 

cells a consumer might purchase, but not without noticing their 

larger size — examples include some extended life batteries for 

notebook computers, and batteries used by audiovisual professionals for video and lighting equipment. 

Large lthum batteres and cells are primarily those used in 

industry. A large rechargeable battery provides over 300 watthours of power (over 25 g of equivalent lithium content). Large 

batteries may be found in some electric and hybrid vehicles, as 

well as some mobility devices and scooters.

*Wh= (mAh÷1,000) × Volts.

**The Hazardous Materials Information Center can be reached at 1-800-467-4922.

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0

WHAT REQuIREmENTS APPLY To “SmALL” LITHIum BATTERIES?

A shipper is responsible for ensuring that the batteries and cells offered for transportation 

have passed the tests found in the UN Manual of Tests and Criteria (after October 1, 2009). 

Check with the battery manufacturer or distributor to determine if a battery design has 

passed these tests.

Packaged batteries or cells must be separated in a way to prevent 

short circuits and damage to terminals. They must be packed 

in a strong outer packaging or be contained in equipment.

Sample Packaging:

Lithium Batteries

Blister Pack

Cushioning

Divider

Improper Packaging:

DO NOT package batteries:

• Loose

• With metal objects

 such as tools or keys 

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Packaging requirements for “small” lithium batteries are 

found in the HMR in § 172.102, Special Provision 188.

Provisions for airline passengers are found in 

§ 175.10(a)(17).

•

•

A package containing “small” lithium batteries or cells must be:* 

Marked to indicate that it contains lithium batteries and that special 

procedures should be followed in the event the package is damaged;

Accompanied by a document indicating that the package contains lithium 

batteries and special procedures should be followed in the event that the 

package is damaged;

Capable of withstanding a 1.2 meter drop test in any orientation without 

damage to cells or batteries contained in the package, without shifting of 

the contents that would allow short circuits and without release of package 

contents; and

No more than 30 kg (66 pounds).

•

•

•

•

*See § 172.102, Special Provision 188, for batteries or cells contained in or 

packed with equipment.

Primary (non-rechargeable) lithium batteries and cells 

are forbidden for transport aboard passenger carrying 

aircraft as cargo. Secondary (rechargeable) small 

lithium batteries and cells are authorized aboard 

passenger carrying aircraft when properly packaged 

and identified (where applicable). 

Shipper Guide Batteries Air.indd11 11 3/19/2009 2:10:16 


WHAT REQuIREmENTS APPLY To “mEdIum” ANd “LARGE” LITHIum 

BATTERIES?

When transported by aircraft or vessel, “medium” lithium batteries and cells are 

subject to the same requirements as “large” lithium batteries.

Arcraft Quantty Lmts for medum and Large Lthum Batteres:

Primary (non-rechargeable) lithium batteries and cells are forbidden for 

transport aboard passenger carrying aircraft. Secondary (rechargeable) 

lithium batteries and cells are authorized aboard passenger carrying aircraft 

in packages that do not exceed a gross weight of 5 kg (11 pounds).

For requirements and exceptions for 

“medium” batteries shipped by highway or 

rail, see §§ 173.185 and 172.102, Special 

Provision 189.

The shipper must confirm that the manufacturer has performed all the tests and 

the batteries/cells have passed the tests found in the UN Manual of Tests and 

Criteria prior to offering for transportation.

Batteries or cells must be separated so as to prevent short circuits and must be 

packed in a strong outer packaging or be contained in equipment.

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SHIPPING BATTERIES SAFELY BY AIR 

Sample Packaging:

“Medium” and “Large”

lithium batteries shipped by

cargo air

Cushioning 

Lithium Batteries

Individually Packaged

UN Specifi cation Packaging

“Medium” and “Large” lithium batteries and cells must:

Pass the design type tests in the UN Manual of Tests and Criteria.

Be packaged in UN Specification combination packagings.

Shipments of “Medium” and “Large” lithium batteries and cells must be:

Marked and labeled in accordance with the HMR as Class 9.

Accompanied by a hazardous materials shipping paper prepared in 

accordance with the HMR describing the batteries.

When transported by aircraft: accompanied by a shipping 

paper, emergency response information, notification of pilot-incommand, and must meet general packaging requirements and the 

requirements in § 173.27.

•

•

•

•

•

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14

Wet Batteries

Sample Packaging:

Wet Batteries

Terminal Protection

Non-Conductive

Divider

Insulating Caps

Inner Container

Strong Outer

Package

Wet batteries are also called lead-acid or lead-alkali 

batteries. These batteries are used in automobiles, 

forklifts, wheelchairs, uninterruptible power supply 

(UPS) systems, and many other applications. Hazards 

associated with these batteries include burns from the 

corrosive electrolyte fluid and heat caused by short 

circuits. Wet batteries are defined as electric storage 

batteries, containing electrolyte acid or alkaline 

corrosive battery fluid.

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UN2794 – Batteries, wet, filled with acid, electric storage.

UN2795 – Batteries, wet, filled with alkali, electric storage.

•

•

Wet battery requirements are 

found in § 173.159.

•

In general, wet batteries may not be packed with other 

materials (exceptions are provided for battery acid/alkali 

fluid, dry cell batteries, and mechanical equipment such 

as battery chargers). When transported by aircraft, the 

packaging for wet batteries must incorporate an acid- or alkali-proof liner, or include 

an additional packaging of sufficient strength, and be adequately sealed to prevent 

leakage of electrolyte fluid from the packaging in the event of a leak from a battery. 

Batteries must be securely packed to prevent:

Dangerous evolution of heat*,

Damage to the terminals, and

Short circuits - by any of the following methods:

- Fully enclosing each battery or device in inner packagings;

- Separating batteries to prevent contact; or

- Covering exposed terminals with protective caps.

*A “dangerous evolution of heat” is an amount of heat sufficient to be dangerous 

to packaging or personal safety to include charring of the packaging, melting of 

packaging, scorching of packaging, or other evidence.

•

•

•

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A nonspllable battery is a battery that is capable 

of passing the vibration and pressure differential tests as 

provided by § 173.159. Nonspillable batteries must be 

marked:

 “NoNSPILLABLE” or “NoNSPILLABLE BATTERY”

Nonspillable Batteries

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UN2800 – Batteries, wet, 

non-spillable, electric storage

•

A nonspillable wet electric storage battery is not subject to the 

HMR when the battery:

• meets pressure differential and vibration testing standards 

 found in § 173.159;

• (and its outer packaging) are plainly and durably marked,

 “NONSPILLABLE” or “NONSPILLABLE BATTERY”;

• is protected against short circuits (e.g., by the use of

 non-conductive caps that entirely cover the terminals);

• contains no unabsorbed (i.e., free-flowing)

liquid (at 55 °C (131 °F)); and

• is designed so that electrolyte will not flow if the case 

ruptures or cracks (at 55 °C (131 °F)).

Shipper Guide Batteries Air.indd17 17 3/19/2009 2:10:32 
18

Sample Packaging:

Dry Cell Batteries

Blister Pack

Cushioning

Divider

Dry Batteries

(Excluding Lithium)

These are sealed batteries that are normally used 

in flashlights or small appliances. Examples include 

alkaline, nickel metal hydride, nickel cadmium, and 

carbon zinc batteries (e.g., AA, AAA, D-Cell, C-Cell, etc). 

These batteries include both non-rechargeable types 

(sometimes called alkaline batteries) and rechargeable 

types (nickel metal hydride and nickel cadmium). 

Note: Some AA, AAA, and 9-volt batteries are made 

using lithium chemistries. Dry batteries do not include 

lithium batteries.

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SHIPPING BATTERIES SAFELY BY AIR 19

• Dry Batteries Section 172.102, Special Provision 130 provides 

detailed requirements for packaging and 

protecting dry batteries (including examples).

•

Unless covered by an entry found in § 172.101, Hazardous Materials Table, in 

the HMR such as “UN3028, Batteries, dry, containing potassium hydroxide solid, 

electric, storage,” dry batteries are not subject to other requirements in the HMR 

when they are properly packaged and protected as specified in § 172.102, Special 

Provision 130.

Batteries must be securely packed to prevent:

Dangerous evolution of heat*,

Damage to the terminals, and

Short circuits - by any of the following methods:

- Fully enclosing each battery or device in inner packagings;

- Separating batteries to prevent contact; or

- Covering exposed terminals with protective caps.

When you transport batteries by air with an electrical potential

greater than 9 Volts, you must:

Package a device containing the battery in a way that restricts access to 

activation switch, install a switch cap or lock, determine that the device has a 

sufficiently recessed switch, or use other suitable methods to prevent accidental 

activation of a device.

Mark each package “non restricted” or provide a transport document with the 

words “non restricted” entered on it.

*A “dangerous evolution of heat” is an amount of heat sufficient to be dangerous 

to packaging or personal safety to include charring of the packaging, melting of 

packaging, scorching of packaging, or other evidence.

•

•

•

•

•

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Battery-Powered

Vehicles and Equipment

The HMR include a number of provisions applicable 

to batteries installed in vehicles, machinery, or 

other types of equipment. Section 173.220 includes 

requirements for shipment of internal combustion 

engines, self-propelled vehicles, mechanical equipment containing internal combustion engines, and 

battery-powered vehicles or equipment.

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SHIPPING BATTERIES SAFELY BY AIR 21

Battery-powered vehicle or

Battery-powered equipment

•

Section 173.220 provides regulatory 

exceptions for battery-powered vehicles, 

machinery, and equipment provided they 

meet certain minimal requirements:

Batteries must be securely installed.

Wet batteries must be fastened in an upright position.

Batteries must be protected against short circuits (e.g., by the use of 

non-conductive caps that entirely cover the terminals) and leakage, or 

removed and packaged separately.

When transported by aircraft: shipping papers, emergency response 

information, notification of pilot-in-command, general packaging 

requirements, and compliance with § 173.27 are required.

Lithium batteries contained in battery-powered vehicles are subject to 

most of the restrictions applicable to lithium batteries (see §§ 172.102 

Special Provision 134 and A101, and 173.220(d)).

•

•

•

•

•

Battery-powered wheelchairs and other mobility aids are eligible for exceptions from 

some regulatory requirements on passenger aircraft under certain conditions. These 

conditions can be found in § 175.10 of the HMR.

•

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22

Batteries Contained in or 

Packed with Equipment

Many of the requirements discussed in this guide are accompanied 

by the statement “except when contained in or packed with 

equipment.” This section describes what is required for batteries 

contained in or packed with equipment. Battery-powered 

equipment can be shipped safely if certain precautions are taken 

to prevent short circuits, overheating, and inadvertent operations.

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SHIPPING BATTERIES SAFELY BY AIR 

Batteres, wet, non-spllable, electrc storage

Batteries, wet, fi lled with acid, electric storage

Batteries, wet, fi lled with alkali, electric storage

Life-saving appliances, not self infl ating

Lthum batteres packed wth equpment

Lthum batteres contaned n equpment

dry Batteres

•

•

•

•

•

•

•

All batteries, wet, dry, nonspillable, and lithium, must be securely packaged with the 

equipment in such a way that prevents the dangerous evolution of heat and protects 

against short circuits, or the batteries must be properly installed in the equipment. 

Properly cushion items to prevent shifting.

The equipment must be designed, packaged, and be in proper condition so that no 

dangerous evolution of heat, fumes, gases, or fire will result. Leave devices in the 

“off” position. The device may not operate on its own or short circuit the battery in 

it. This can be achieved by engaging a trigger lock or disabling the power button/

switch. Batteries may not be recharged during transportation.

Batteries packed in equipment may not exceed certain weight limits:

Lithium batteries in equipment: 5kg net (passenger air/rail), 35kg net (cargo air)

Lithium batteries packed with equipment: 5kg net (passenger air/rail), 35kg gross 

(cargo air)

Wet batteries: 30kg gross (passenger air/rail), no limit by cargo air

Dry batteries and Nonspillable batteries: no limit

Important sections pertaining to batteries installed in and packaged with equipment: 

§§ 172.102, (Special Provisions 134, 157, 188, 189, A101, A103, and A104), 

173.185(b) and (c ), and 173.220(d).

•

Batteries, wet, fi lled with alkali, electric storage

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4

For information about other 

Hazmat Publications:

Vst our web ste:

http://www.phmsa.dot.gov/hazmat

E-mail: infocntr@dot.gov

Fax: (202) 366-7342

E-mal: training@dot.gov

Phone: (202) 366-4900

Wrte:

U.S. Department of Transportation 

Ppelne and Hazardous materals

Safety Admnstraton

1200 New Jersey Avenue, SE, PHH-50

Washington, DC 20590-0001

PHH50-0107-0109

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