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# TSA and FAA Lithium Battery Rules: Carry-On, Checked Baggage, and Air Cargo

Three federal agencies govern lithium batteries on commercial aircraft — FAA, TSA, and DOT/PHMSA — and they operate on overlapping but distinct authority. For hardware companies, the stakes are high on both ends: customers who don't know the rules face confiscation and civil penalties, and cargo shippers who misdeclare batteries face federal enforcement under 49 USC § 5124. This guide covers exactly what the rules require, where the critical distinctions lie, and what product documentation must say.

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At a glance

Carry-On Wh Limit

100 Wh (160 Wh with airline approval)

Checked Bag — Spare Batteries

Prohibited regardless of Wh

Cargo Declaration

IATA Shipper's Declaration (Section IA/IB)

Regulatory Authority

FAA / TSA / DOT-PHMSA

Civil Penalty (Misdeclaration)

Up to $84,425 per violation

## Key regulatory concepts for aviation battery compliance

### Three Overlapping Regulatory Authorities

Aviation lithium battery rules involve three agencies simultaneously. FAA (Federal Aviation Administration) governs aviation safety — it sets the fire-risk basis for battery restrictions and issues Safety Alerts for Operators (SAFOs). TSA (Transportation Security Administration) governs airport security — its officers enforce battery rules at checkpoints and can confiscate non-compliant items. DOT/PHMSA governs hazardous materials in commerce — 49 CFR Part 173 and IATA DGR govern cargo shipments. A hardware company shipping products by air must satisfy all three frameworks.

### Passenger Carry-On Limits — The 100 Wh Threshold

FAA rules allow passengers to carry lithium-ion batteries up to 100 Wh per battery in carry-on baggage with no limit on quantity. Batteries between 101 Wh and 160 Wh require airline approval and are limited to two per passenger. Batteries exceeding 160 Wh are not permitted in carry-on or checked baggage for passenger use — they fall into cargo-only territory. The Wh rating (nominal voltage × rated capacity in Ah) must be marked on the battery. If not marked, the airline may apply conservative assumptions or refuse boarding.

### Checked Baggage — Spare Batteries Prohibited

This is the rule most passengers and hardware companies get wrong. Spare lithium batteries — meaning batteries NOT installed in a device — are prohibited in checked baggage, regardless of Wh rating. A 10 Wh power bank in checked luggage violates FAA rules just as much as a 100 Wh pack. Batteries installed in devices may travel in checked baggage (subject to the device being off and protected from activation). The basis is fire risk: a thermal runaway in a checked bag is inaccessible to crew during flight.

### Spare Battery Terminal Protection Requirement

Spare lithium batteries carried in carry-on baggage must have terminals protected against short circuit. Acceptable methods include: the original retail packaging, taping over exposed terminals, or placing each battery in a separate plastic bag or protective pouch. A loose battery in a bag — even a small one — is non-compliant. For hardware companies selling spare batteries, product packaging that doubles as compliant travel storage is worth designing for explicitly.

### Air Cargo — Shipper's Declaration and IATA DGR

Commercial shipments of lithium batteries as air cargo are governed by IATA Dangerous Goods Regulations (DGR), which incorporates 49 CFR by reference for US-origin shipments. The IATA DGR Section applicable to the shipment (IA, IB, or II) determines whether the Shipper's Declaration for Dangerous Goods is required. Section II small quantities may use a simplified lithium battery handling mark instead of a full declaration. Section IA and IB require the complete Shipper's Declaration (two original signed copies for the operator), cargo aircraft only restriction for IB, and specific operator approval for IA.

### FAA SAFO 19018 and the Fire Risk Basis

FAA Safety Alert for Operators 19018 documents the fire risk basis for lithium battery carriage restrictions. Lithium battery fires are self-sustaining and can overcome aircraft Halon suppression systems — the regulatory rationale is access: cargo hold fires are inaccessible, but cabin fires can be addressed by crew. This is why the rules distinguish so sharply between carry-on (crew-accessible) and checked/cargo hold (inaccessible). Hardware companies that understand this rationale can better explain restrictions to customers and design product documentation accordingly.

## Compliance process for hardware companies with battery products

01

Determine the Wh rating of every battery in your product line — nominal voltage × rated capacity in Ah. This rating must be physically marked on the battery cell or pack. If your battery is unlabeled, you must mark it before it can legally be transported by air by your customers.

02

Categorize each battery by transport context: batteries installed in devices (most relaxed rules), spare batteries shipped with devices in same package (UN 3481 treatment), and standalone spare batteries (UN 3480 — strictest rules). The same physical battery triggers different rules depending on how it is packaged and presented.

03

For retail consumer products, prepare customer-facing documentation: include the Wh rating prominently in the manual, product spec page, and FAQ. State explicitly whether the product's battery is removable and whether spare batteries are sold separately. Advise customers on the checked baggage prohibition for spare batteries.

04

For air cargo shipments of battery inventory: classify under IATA DGR, identify the applicable Section (IA, IB, or II) based on Wh and quantity, prepare the Shipper's Declaration if Section IA or IB applies, and confirm cargo aircraft only restriction with the freight forwarder if Section IB.

05

Update product manuals, box inserts, and e-commerce product pages with explicit battery travel language — Wh rating, carry-on status, and the spare battery checked-baggage prohibition. This is both a customer service function and a liability management function. Customers who are penalized or have items confiscated because of missing information are a warranty and reputation issue.

06

Check airline-specific rules for routes where your product ships. Carriers operating under IATA DGR may impose stricter rules than the IATA minimum — some carriers prohibit all standalone lithium batteries as cargo regardless of size. Your freight forwarder should have current carrier acceptance policies.

07

Monitor the IATA DGR annual publication cycle — a new edition is released each January and takes effect in January of that year. Changes to Section assignments, quantity limits, and packaging requirements can affect your cargo shipments mid-year if you're using an outdated edition.

## Frequently asked questions

### Can passengers carry lithium battery power banks in checked baggage?

No. Power banks are spare lithium batteries — they are not installed in a device — and spare lithium batteries are prohibited in checked baggage under FAA rules, regardless of Wh rating. This applies to all lithium battery power banks, from small 5,000 mAh units to large 26,800 mAh packs. The prohibition has no Wh threshold exception for checked baggage. Power banks may be carried in carry-on baggage (subject to the 100 Wh per battery limit, or up to 160 Wh with airline approval). Hardware companies selling power banks should include this rule explicitly in packaging and product documentation.

### What's the Wh limit for carry-on lithium batteries on US airlines?

The FAA carry-on limit is 100 Wh per lithium-ion battery for unrestricted carriage, with no limit on quantity. Batteries between 101 Wh and 160 Wh may be carried in carry-on with prior airline approval — typically granted informally at check-in — and are limited to two per passenger. Batteries exceeding 160 Wh are prohibited in carry-on and checked baggage for passenger carriage. For lithium-metal (primary, non-rechargeable) batteries, the limit is 2 g of lithium content per battery for unrestricted carry-on carriage. These are FAA minimums; individual airlines may apply stricter rules, particularly on international routes.

### How does a hardware company communicate battery rules to customers?

At minimum, every product containing a lithium battery should clearly state: (1) the battery's Wh rating, (2) whether the battery is removable, (3) carry-on vs checked baggage status of spare batteries if sold separately, and (4) whether the battery meets FAA carry-on limits. The Wh rating should appear on the product spec page, in the manual, and ideally on the product itself. Companies that sell high-capacity batteries (approaching or exceeding 100 Wh) have additional exposure — customer confusion at security checkpoints reflects directly on the brand. Some companies include a fold-out travel card in the box referencing TSA/FAA rules.

### What happens if a cargo shipment of batteries isn't declared correctly?

Undeclared or misdeclared dangerous goods shipments by air are a federal violation under 49 USC § 5124, which provides for civil penalties up to $84,425 per violation and criminal penalties including imprisonment for willful violations. DOT/PHMSA and FAA both have enforcement jurisdiction. Beyond the regulatory penalties, carriers who discover undeclared batteries at origin or in transit will refuse the shipment, creating supply chain disruption. Airlines may add the shipper to restricted shipper lists. The IATA requires carriers to report dangerous goods incidents — a fire involving undeclared batteries creates significant liability exposure.

**Disclaimer:** Educational resource only. Regulatory requirements change. Consult a licensed US attorney, customs broker, or compliance specialist before making decisions.

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