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# Lithium Battery Transport Compliance in Australia: IATA, ADG, and Domestic Rules

Lithium battery transport is one of the most heavily regulated areas in dangerous goods logistics — and Australia adds its own state-level road transport layer on top of the IATA DGR and IMDG Code. Getting the UN number wrong, miscalculating Wh, or missing the 30% SOC requirement for air cargo can get shipments rejected, trigger civil penalties, or in serious cases result in criminal prosecution under state dangerous goods legislation.

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At a glance

Standalone lithium ion (air)

UN 3480

Packed with/in equipment (air)

UN 3481

Air SOC limit (Section II)

≤ 30% (SP A88)

Cell Wh threshold (Section II)

≤ 100 Wh/cell

Battery Wh threshold (Section II)

≤ 300 Wh/pack

Road code

ADG Code 7th Edition

## Key rules and concepts you need to understand

### UN 3480 and UN 3481 — Lithium Ion Classification

UN 3480 covers lithium ion cells and batteries shipped alone (standalone). UN 3481 covers lithium ion batteries packed with equipment or contained in equipment. The distinction drives which packing instruction applies and what Section of the IATA DGR you fall into. Lithium metal equivalents are UN 3090 (standalone) and UN 3091 (packed with/in equipment).

### Wh Thresholds and Section I vs Section II

For lithium ion, the critical thresholds are 100 Wh per cell and 300 Wh per battery. Cells or batteries below these thresholds qualify for Section II treatment under PI 965 and PI 966/967, which carries significantly lighter documentation and quantity limits. Above 100 Wh per cell or 300 Wh per battery, Section I applies — full Class 9 dangerous goods treatment including Shipper's Declaration, specific quantity limits, and cargo aircraft only restrictions in many cases.

### State of Charge (SOC) Limit for Air — 30%

IATA Special Provision A88 requires lithium ion cells and batteries shipped as cargo (UN 3480, Section II) to be at or below 30% state of charge. This applies to standalone battery shipments. Batteries packed with or in equipment (UN 3481) are not subject to the 30% SOC limit under A88, though equipment must be protected against inadvertent activation.

### Packing Instructions PI 965–970

PI 965 governs UN 3480 (lithium ion cells/batteries, standalone). PI 966 governs UN 3481 packed with equipment. PI 967 governs UN 3481 contained in equipment. PI 968, 969, and 970 are the lithium metal equivalents. Each PI specifies Section I and Section II requirements, net quantity limits per package, inner/outer packaging specifications, and applicable special provisions including A88, A99, and A154.

### IATA Special Provisions A88 and A99

A88 restricts standalone lithium ion batteries (Section II, UN 3480) to 30% SOC. A99 applies to lithium batteries in Section IB under PI 965 and limits per-package quantities and requires cargo aircraft only transport. A154 is the newer provision addressing damaged, defective, or recalled batteries — these must be shipped under Class 9 with specific additional packaging requirements regardless of Wh rating.

### Australian Dangerous Goods Code (ADG) — 7th Edition Road Transport

Road transport of lithium batteries within Australia is governed by the Australian Dangerous Goods Code 7th Edition, adopted under state/territory road transport legislation. Lithium batteries are Class 9 (miscellaneous dangerous goods). The ADG incorporates UN Model Regulations and largely mirrors the IATA/IMDG classification system, but consignment note, placard, and load segregation requirements are specific to the ADG and differ from air documentation.

## How to classify and document a lithium battery shipment

01

Classify battery chemistry: lithium ion (rechargeable) or lithium metal (primary/non-rechargeable) — this determines whether you're working under UN 3480/3481 or UN 3090/3091.

02

Calculate Wh rating for each cell and the total battery pack: Wh = Ah × nominal voltage. For multi-cell packs, sum cell Wh values. Compare against the 100 Wh per cell and 300 Wh per battery thresholds.

03

Determine the correct UN number: standalone cells/batteries (UN 3480 or UN 3090) vs packed with equipment (UN 3481 or UN 3091) vs contained in equipment (UN 3481 or UN 3091).

04

Select the applicable packing instruction (PI 965–970) and determine Section I or Section II based on Wh thresholds. Section II carries lighter requirements but still demands proper inner/outer packaging, markings, and labels.

05

For air shipments under Section II UN 3480: verify SOC is at or below 30% per Special Provision A88 before packaging. Document the SOC verification in your quality records.

06

Prepare documentation: Shipper's Declaration for Dangerous Goods (Section I shipments), air waybill with DG notation, and relevant markings (Class 9 label, lithium battery mark, handling labels). For ADG road transport: prepare a compliant dangerous goods consignment note with UN number, proper shipping name, packing group (N/A for lithium batteries under PI 965–967), and emergency contact.

07

Verify with your carrier: Australian airlines including Qantas Freight and Virgin Australia Cargo each publish carrier variations under the IATA DGR that may be more restrictive than the baseline rules. Confirm acceptance before tendering the shipment.

## Frequently asked questions

### What Wh threshold triggers Section I treatment for lithium ion batteries?

Section I applies when a lithium ion cell exceeds 100 Wh or a lithium ion battery (pack) exceeds 300 Wh. Below these thresholds you qualify for Section II under PI 965 (standalone) or PI 966/967 (packed with/in equipment), which has lighter documentation requirements. Section I requires a Shipper's Declaration for Dangerous Goods and stricter quantity limits per package.

### Can you ship lithium batteries as passenger baggage on Australian domestic flights?

Spare lithium batteries (not installed in devices) must be carried in carry-on baggage only — they are prohibited in checked baggage. The limits are 100 Wh per battery without airline approval and up to 160 Wh per battery with airline approval (maximum two batteries). Batteries installed in personal electronic devices may travel in either checked or carry-on baggage. Australian airlines follow IATA DGR passenger provisions, and CASA enforces these rules domestically.

### Do state and territory dangerous goods rules differ from the ADG Code for road transport?

The ADG Code is adopted by reference in each state and territory's road transport dangerous goods legislation, so it applies nationally. However, individual states may have additional requirements around driver licensing (dangerous goods driver licence), vehicle placarding, and route restrictions that go beyond the base ADG Code. Western Australia, in particular, has its own Dangerous Goods Safety Act 2004 that overlaps with but is not identical to the ADG framework for certain facility and storage requirements.

### What changed in the latest IATA DGR edition for lithium batteries?

The IATA DGR 66th Edition (2025) introduced updates including expanded requirements under Special Provision A154 for damaged and defective batteries, revised PI 965 Section IB quantity limits, and tightened provisions around battery-powered vehicles and equipment. Carrier variations continue to proliferate — many carriers impose lower quantity limits or outright prohibitions on certain Section I UN 3480 shipments than the baseline DGR allows. Always check the current edition and your carrier's specific variations.

**Disclaimer:** Educational resource only. Regulatory requirements change and vary by product category. Consult a qualified legal or compliance professional before making decisions.

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