Shipping Hazmat and Lithium Batteries by Air in the US
Air is the strictest mode for hazardous materials. Items that ride in a truck with no paperwork can be forbidden on a passenger plane, and undeclared lithium batteries are one of the most common reasons the FAA proposes penalties against shippers.
Which rules apply
In the US, hazardous materials in air transport fall under the Hazardous Materials Regulations (HMR), 49 CFR Parts 171 to 180. Part 175 adds rules specific to aircraft. It applies to shipments to, from or within the United States, and it covers air carriers, indirect carriers, freight forwarders and their employees and contractors (49 CFR 175.1).
Shippers may also use the ICAO Technical Instructions for air shipments within the US, subject to the conditions in 49 CFR 171.22 and 171.24, including US variations. Airlines generally accept dangerous goods prepared under the IATA Dangerous Goods Regulations (DGR), which IATA bases on the UN Recommendations and ICAO's instructions and updates every year. Airlines can add their own stricter variations, so the airline you tender to has the final say on what it will accept.
If the freight moves by truck before or after the flight, that road leg follows Part 177 and the vehicle must be placarded as required by Part 172 (49 CFR 171.24).
What the airline must check (Part 175)
- Acceptance (175.30): before accepting hazmat, the operator confirms it is authorized and within quantity limits, described on a shipping paper, and correctly marked and labeled, including a CARGO AIRCRAFT ONLY label where the material cannot go on passenger aircraft. Each package is inspected for leaks or damage right before loading.
- Pilot notification (175.33): the pilot in command gets written information about each hazmat shipment on board, including the air waybill number, proper shipping name, class, UN number, quantity and location.
- Discrepancies (175.31): anyone who finds a hazmat discrepancy after acceptance, such as undeclared hazmat in a package, must report it to the nearest FAA regional office as soon as practicable.
- Posted notices (175.26): any business that accepts cargo for air transport must post notices explaining the hazmat rules and the penalties for breaking them.
The practical effect is that a discrepancy found at the airline does not stay there. It is reported to the FAA, and the FAA traces it back to the shipper.
Lithium batteries: the main rules
Lithium batteries are classified by chemistry and by how they are packed. The configuration changes the rules completely.
| Configuration | UN number | Passenger aircraft | Cargo aircraft | State of charge |
|---|---|---|---|---|
| Lithium ion batteries shipped alone | UN3480 | Forbidden as cargo (49 CFR 171.24; 2019 PHMSA rule) | Allowed with CARGO AIRCRAFT ONLY label or required marking | Not more than 30% under the US rule and the IATA DGR |
| Lithium metal batteries shipped alone | UN3090 | Forbidden as cargo (49 CFR 171.24) | Allowed with CARGO AIRCRAFT ONLY label or required marking | Not applicable |
| Lithium ion packed with equipment | UN3481 (IATA PI 966) | Allowed within limits | Allowed within limits | Since January 1, 2026, IATA DGR requires 30% or less; under Section II this applies to batteries over 2.7 Wh |
| Lithium ion contained in equipment | UN3481 (IATA PI 967) | Allowed within limits | Allowed within limits | Not mandatory; IATA recommends 30% or less, or 25% indicated capacity |
| Damaged, defective or recalled batteries | Varies | Forbidden | Forbidden; highway, rail or vessel only (49 CFR 173.185(f)) | Not applicable |
The 2019 PHMSA interim final rule (84 FR 8006) also limited the small-battery alternative provisions to one package per consignment or overpack. The IATA 2026 guidance also applies reduced state of charge to vehicles powered by lithium ion batteries over 100 Wh: 30% or less, or an indicated capacity of 25% or less.
Small battery thresholds
Many of the lighter "small battery" provisions in 49 CFR 173.185(c) apply only to cells and batteries at or under these limits:
- Lithium ion: 20 Wh per cell, 100 Wh per battery.
- Lithium metal: 1 g lithium content per cell, 2 g per battery.
Batteries above these ratings are fully regulated Class 9 and need UN specification packaging, a shipping paper and trained staff. The higher highway and rail thresholds in 173.185(c)(1)(iv) (60 Wh per cell and 300 Wh per battery for lithium ion) do not apply to air; packages using them must be marked as forbidden aboard aircraft and vessels.
Equipment limits
For batteries packed with or contained in equipment, 173.185(c)(4) limits each package to the number of batteries needed to power the equipment plus two spare sets, with a 5 kg total for the completed package in that provision.
Dry ice
Dry ice (UN1845, Class 9) is common in air shipments of food, samples and pharmaceuticals. Under 49 CFR 173.217, packages must let carbon dioxide gas escape, the net mass of dry ice must be marked on the package, and the shipper must make arrangements with the operator for each shipment. Up to 2.5 kg (5.5 lb) per package used as a refrigerant qualifies for a lighter exception if the package is marked "Dry ice" or "Carbon dioxide, solid," with the name of the contents being cooled and the net weight of dry ice (or an indication that it is 2.5 kg or less).
Training requirements
| Requirement | HMR (49 CFR 172.704) | IATA DGR |
|---|---|---|
| Who | Every hazmat employee, including people who prepare, package, mark or transport hazmat | Each person who prepares, offers, accepts or handles dangerous goods |
| Content | General awareness, function-specific, safety, security awareness, and in-depth security where a security plan is required | Function-specific, competency-based |
| New employees | Within 90 days of hire or job change; may work under direct supervision of a trained employee until then | See the current DGR and your airline's requirements |
| Recurrent | At least once every three years | Every 24 months |
| Records | Kept for the preceding three years and for 90 days after the employee leaves | Per the employer's program |
If you ship by air under IATA rules, the 24-month cycle is the one to plan around. A driver who only transports packages by highway still needs HMR training for that function.
Penalties
Civil penalties for violating federal hazardous materials law, as published in 49 CFR 107.329 (updated by 89 FR 106293, December 30, 2024):
| Violation | Amount |
|---|---|
| Maximum per violation | $102,348 |
| Maximum if the violation results in death, serious illness, severe injury or substantial property destruction | $238,809 |
| Minimum for training violations | $617 |
The FAA enforces the air side. In September 2025, for example, it proposed a $170,000 civil penalty against a Virginia company that allegedly offered undeclared, improperly packaged mobile phone lithium ion batteries to FedEx on four occasions; in one, the package was found smoking, and three batteries had melted together.
Common mistakes
- Shipping loose lithium ion batteries on a passenger flight. UN3480 batteries shipped alone are forbidden as cargo on passenger aircraft.
- Shipping returns of failed batteries by air. Damaged, defective or recalled batteries cannot fly.
- Treating "packed with equipment" as "contained in equipment." A spare battery in the same box as a device is packed with, and since 2026 it carries a mandatory state-of-charge limit under the IATA DGR.
- Vague descriptions. "Electronics" or "parts" on the air waybill does not declare anything. See the air waybill guide.
- Letting training lapse. The IATA cycle is 24 months, shorter than the HMR's three years.
- Assuming highway rules carry over. Quantities and exceptions that are legal on a truck can be forbidden in the air.
If you run a van or box truck to the airport, you are often the first person to see a suspicious package. If a carton is leaking, smoking, hot, or smells of solvent, do not tender it. Contact the shipper and the forwarder. For free guidance, the FAA's air hazmat office can be reached at hazmatinfo@faa.gov and the DOT Hazardous Materials Information Center at 1-800-467-4922.
Related: TSA cargo security, cargo van freight, and the air cargo overview.
Watch
FAA Tech Center Lithium Battery Testing: Lithium Ion Batteries in a ULD — Federal Aviation Administration. The video loads from YouTube only when you press play.
Questions
Can I ship lithium ion batteries on a passenger plane?
Not as cargo when they are shipped by themselves (UN3480). Batteries packed with or contained in equipment (UN3481) can go on passenger aircraft within the applicable limits.
What is the 30% state-of-charge rule?
Lithium ion batteries shipped alone by air must be at no more than 30% of rated capacity. Since January 1, 2026, the IATA DGR also requires 30% or less for lithium ion batteries packed with equipment, with Section II applying the limit to batteries over 2.7 Wh.
How often is hazmat training required for air shipments?
The HMR requires recurrent training at least every three years. IATA says recurrent dangerous goods training is required every 24 months to keep certification valid.
What is the maximum fine for a hazmat violation?
Under 49 CFR 107.329, up to $102,348 per violation, or $238,809 if the violation results in death, serious illness, severe injury or substantial property destruction. The minimum for training violations is $617.
Can I ship a dead or swollen battery by air?
No. Damaged, defective or recalled lithium batteries may be transported by highway, rail or vessel only, under 49 CFR 173.185(f).
Sources
- 49 CFR Part 175 – Carriage by Aircraft — eCFR.
- 49 CFR 173.185 – Lithium cells and batteries — eCFR.
- Hazardous Materials: Enhanced Safety Provisions for Lithium Batteries Transported by Aircraft (84 FR 8006) — Federal Register / PHMSA.
- Battery Guidance Document (2026) — IATA.
- 49 CFR 107.329 – Maximum penalties — eCFR.
General information, not legal, tax or financial advice. Regulations change; confirm current requirements with the agency before acting.