Nothing in lithium battery shipping compliance causes more refused parcels than the three-way split between PI965, PI966 and PI967. They look interchangeable on a spec sheet. They are not. Pick the wrong one and the UN number on your shipping paper is wrong too, which is the single defect most likely to get a consignment pulled at a sort facility.
This guide sets out how the three packing instructions differ, how to work out which applies, and where the traps sit. There is a decision table you can keep, and a walk-through of the mistake we see more than any other.
Why lithium battery shipping compliance keeps tightening
Because the risk is real and it is being measured. The FAA's lithium battery incident record logged 93 verified events aboard aircraft during 2025 — batteries smoking, igniting or reaching extreme heat. Thirteen were on cargo aircraft and 80 on passenger aircraft. The FAA is explicit that these are only the events it could verify, so the true figure is higher.
That is the backdrop to every rule below. The packing instructions are not paperwork for its own sake; they are the mechanism that keeps a thermal runaway inside one package instead of one aircraft.
The three configurations
Everything follows from one question: where is the battery in relation to the equipment it powers?
PI965 — batteries on their own (UN3480)
The pack ships by itself. A replacement laptop battery. A power bank in a box. A spare drone cell. This is the strictest of the three, because a loose battery has no host device absorbing shock and no casing beyond its own.
Two consequences bite hard. First, air transport under UN3480 is cargo aircraft only — no passenger aircraft. Second, the state-of-charge cap: cells and batteries must not exceed 30 % of rated capacity. Your warehouse needs to actually manage that, which means either shipping stock pre-discharged or having a process to bring it down.
PI966 — packed with equipment (UN3481)
The battery and the device travel in the same outer package, but the battery is not fitted. A cordless drill with the pack in the moulded tray beside it. A camera boxed with a spare cell.
PI967 — contained in equipment (UN3481)
The battery is installed. A phone. A laptop. A Bluetooth speaker with the cell sealed inside. This is the most permissive of the three, and it is why so many brands ship assembled rather than loose.
| Configuration | Packing instruction | UN number | Proper shipping name | Passenger aircraft |
|---|---|---|---|---|
| Battery shipped alone | PI965 | UN3480 | Lithium ion batteries | Forbidden as cargo |
| Battery packed with equipment | PI966 | UN3481 | Lithium ion batteries packed with equipment | Permitted, conditions apply |
| Battery contained in equipment | PI967 | UN3481 | Lithium ion batteries contained in equipment | Permitted, conditions apply |
Watt-hours, not milliamp-hours
Every threshold in these instructions is expressed in watt-hours. Almost every consumer battery is marketed in milliamp-hours. Converting between them is the arithmetic that decides your paperwork:
Wh = (mAh ÷ 1000) × nominal voltage
20 000 mAh power bank at 3.7 V
= (20000 ÷ 1000) × 3.7
= 74 WhTwo numbers matter. Under 100 Wh keeps a battery in the relieved sections of PI965 to PI967. Over 100 Wh moves it into full regulation, with Class 9 hazard labels, a dangerous goods declaration and trained-shipper requirements.
The 100 Wh line runs straight through ordinary retail catalogues. A 27 000 mAh travel power bank at 3.7 V is 99.9 Wh. Add a little capacity and the compliance burden changes completely, for a product that looks identical on the shelf.
The mistake that gets shipments rejected
Here is the failure we see most, and it is subtle enough that it survives internal review.
A brand sells a portable speaker with a rechargeable cell sealed inside. Someone in the team looks up "lithium ion battery" in a reference table, finds UN3480, and writes it on the shipping paper. The packing instruction on the same document, filled in by someone reading the actual pack-out, says PI967.
Those two entries contradict each other. UN3480 is for batteries alone; PI967 is for batteries contained in equipment, which is UN3481. A carrier's DG checker will catch it, and the consignment stops.
Pull any SKU where the packing instruction is PI966 or PI967 and confirm the UN number reads UN3481, not UN3480. Then check the reverse: anything marked PI965 should be UN3480. If a spreadsheet has been maintained by hand for any length of time, you will usually find a few rows where the two columns disagree.
The UN number is the field that goes on the shipping paper and drives the carrier's acceptance decision. If it disagrees with the packing instruction sitting next to it, one of them is a false declaration — and there is no way for the person loading the aircraft to know which.
Classify7 ruleset team, on why the lithium resolver overrides free-text entry matching
Lithium metal follows the same shape
Everything above describes lithium-ion. Lithium metal (the non-rechargeable chemistry in coin cells, some cameras and a lot of medical devices) runs a parallel set with the same three-way structure:
- PI968, UN3090 — batteries alone
- PI969, UN3091 — packed with equipment
- PI970, UN3091 — contained in equipment
The threshold differs: lithium metal is measured in grams of lithium content rather than watt-hours, with 2 g the equivalent dividing line for cells. If your product has a coin cell in it (a watch, a car key fob, a musical greetings card), this is your column, not the ion one.
Lithium battery shipping compliance on the outside of the box
The packing instruction decides what goes inside. The outside has its own requirements, and they are checked far more often because a handler can see them.
| Requirement | Fully regulated (Section IA / IB) | Relieved (Section II) |
|---|---|---|
| Class 9 lithium battery hazard label | Required | Not required |
| Lithium battery mark | Required | Required |
| UN number on the package | Required | Shown within the lithium battery mark |
| Shipper's declaration | Required | Not required |
| Cargo aircraft only label | Where applicable | Where applicable |
| Air waybill statement | Required | Required where carried by air |
Two practical notes. The lithium battery mark must carry a telephone number for additional information, and it must be a number somebody answers — a dead line is a defect. And packages must be capable of withstanding a 1.2 m drop in any orientation without the cells shifting or the contents escaping, which quietly rules out a lot of thin mailers that would otherwise be cheaper.
Getting lithium battery shipping compliance right on the outer is the cheapest possible win, because these are the defects that get caught visually at induction rather than in a paperwork review.
What changed for 2026
The IATA Dangerous Goods Regulations 67th edition took effect on 1 January 2026. For battery shippers the structural rules held steady, and the notable additions sit around vehicles and in-cabin usage guidance rather than the packing instructions themselves. We cover the detail in our summary of the IATA DGR 2026 edition changes.
The stable-looking years are the dangerous ones, though. Editions change annually, addenda land mid-year, and a classification that was correct in December can be wrong in January. If you are storing determinations against SKUs, store the ruleset version alongside them — otherwise you have no way of knowing which of your catalogue needs a second look.
- Reading capacity in mAh straight onto a form that wants Wh.
- Applying the ion packing instructions to a lithium metal coin cell.
- Shipping UN3480 at full charge, ignoring the 30 % state-of-charge cap for air.
- Treating a "battery included" listing as contained-in when the pack actually sits loose in the box — that is PI966, not PI967.
- Assuming a marketplace's own hazmat approval covers your direct-to-consumer shipments. It does not.
Automating lithium battery shipping compliance
The determination is mechanical once you have three inputs: chemistry, watt-hour or lithium content, and packing configuration. That makes lithium battery shipping compliance an unusually good candidate for moving out of a spreadsheet and into your listing pipeline, where it can be re-run whenever an edition changes.
Send those three fields to POST /api/classify and you get the UN number, proper shipping name, packing instruction and per-carrier position back together, so the two fields can never disagree. If you sell through Amazon as well, the FBA hazmat review process wants much the same data in its own format. And if you are still deciding whether a product is in scope at all, start with how to tell if your product is a dangerous good.
