IATA 2026 PI966 30% SoC Rule: Air Freight Checklist

Start here: does this checklist apply to your shipment?

Before you use anything below, work out which shipping rule your consignment falls under — this checklist only fits one of them.

If your goods are a device with lithium-ion packs packed alongside it in the same package — spare packs, a second battery in the box, a carton where the battery sits next to, not inside, the equipment — you are shipping under PI966, and the January 2026 state-of-charge (SoC) change applies to you. If the battery is installed inside the device and there is no loose pack in the box, you are in PI967. If you ship bare cells or batteries with no equipment at all, you are in PI965. This page covers PI966 only.

The risk this checklist removes is not a fine or a paperwork note. It is a pallet sitting at the origin cargo terminal, refused, after your production cut-off and before your customer's promised delivery date. Everything below is written to be completed before you book the flight.

Are you sure which one you are? The classic mis-classification case is a mixed consignment: a main device with two spare packs in the carton. That is PI966 territory even though the device itself is PI967-compliant. Get the forwarder to confirm, in writing, the packing instruction they will declare for your actual SKU list — not for the product family.

The rule in one paragraph: what changed on 1 January 2026

From 1 January 2026, the 67th Edition of the IATA Dangerous Goods Regulations applies a state-of-charge limit of no more than 30% of rated capacity to lithium-ion cells and batteries packed with equipment under PI966. Under Section I, shipments must generally be offered at no more than 30% of rated capacity; under Section II, the same 30% limit applies where the cell or battery exceeds 2.7 Wh. Above 30%, a shipment does not proceed on a carrier's informal agreement — it requires approval from the State of Origin and the State of the Operator, under the written conditions those authorities set. This summary reflects the freight-industry publisher leads cited on this page (see the evidence-gaps section); the authoritative text is IATA's DGR 67th Edition, which you or your forwarder must confirm directly.

One publisher also quotes a 25% display level for some "contained in equipment" cases. That figure appears in a single forwarder's summary, conflicts with the 30% figure in the other leads, and is not something we can resolve here. Treat it as an open question to put to your operating airline in writing — do not plan against it, and do not assume it replaces the 30% threshold for your PI966 shipment.

Step 1 — Confirm the packing instruction before anything else

Work the decision path in this order:

1. Battery installed in the device, nothing loose in the box → PI967 (not this page).
2. Battery packed with equipment in the same package → PI966.
3. Bare cells or batteries, no equipment → PI965.

Then ask the forwarder to put the PI in writing against the actual SKU list you will hand over. A verbal "that's fine" at quotation stage is not the same as the acceptance decision made by the airline's dangerous goods desk.

Step 2 — Place each SKU in Section I or Section II

Section I and Section II are not interchangeable labels; they change both the SoC obligation and how much documentation you carry. For Section II eligibility, the practical line to check is the 2.7 Wh threshold: above it, the 30% limit bites. This is a cell- and pack-level rating, not the rated output of the finished device, so it has to be read off the battery, not the product nameplate.

The declared section must match what your UN38.3 report and transport assessment describe. If the paperwork says one thing and the forwarder declares another, that mismatch is what gets examined at the terminal.

Step 3 — Work out what 30% of rated capacity means for your model

Thirty percent is a fraction of that model's rated capacity as declared for it. It is not a generic "ship it half charged" habit, and it does not carry across a product family. A 5 kWh pack and a 16 kWh pack at 30% are different absolute energies, and the two must be calculated separately.

Two things follow:

• Calculate per SKU. Build the number from the rated capacity figure your supplier publishes for the specific model — the same figure that appears in model datasheets and rated capacity data — and record it in your own files.
• Do not rely on a device-reported charge bar. A screen indicator is a display convention, not a compliance record. Get the SoC basis — the percentage and the capacity it is a percentage of — stated in writing by the party that set it.

Residual self-discharge between pack-out and flight is part of the risk, not an afterthought. If packs sit in a warehouse for weeks before the flight date, the SoC set at pack-out is not necessarily the SoC at handover. Ask the supplier what margin they build in, and how they document it.

Step 4 — Decide how SoC will be verified and evidenced before handover

You control three verification options at your own end:

• A supplier declaration of SoC per model and per batch — lightest, and entirely dependent on the supplier's honesty and record-keeping.
• A batch-level test record showing measured SoC at pack-out, retained by the supplier and available on request.
• A pre-shipment check per pallet or per carton before handover to the forwarder — heaviest, and the only one that speaks to the units actually moving.

Forwarder summaries also describe carriers applying acceptance conditions beyond the IATA baseline, which makes a written pre-acceptance check with the actual operating airline a sensible risk-reduction step. What we cannot tell you is the likelihood of a physical spot check at any specific terminal: none of the sources reviewed here provides first-party evidence of an individual airline's inspection protocol. Treat physical inspection as a planning assumption and confirm the operator's practice with your forwarder rather than budgeting around a number.

Step 5 — If you must ship above 30%, plan the approval route early

Above 30%, the route is approval from the State of Origin and the State of the Operator, under written conditions established by those authorities. This is an application process with lead time — it is not a workaround you can negotiate at the cargo terminal, and informal acceptance by a carrier does not substitute for it.

Two practical consequences:

• Start the application before you book, not after your forwarder queries the paperwork.
• Get the operating airline's written position. Airlines may impose conditions tighter than the IATA baseline, and a compliant shipment on one lane is not automatically accepted on another.

Step 6 — Assemble the per-SKU document pack that ends the argument

Request these three documents per model, and understand what each one does:

• UN38.3 test report — addresses the cell/battery design type test. It does not evidence the state of charge of the units in your carton, and it does not by itself authorise air or sea movement. For a closer read on its scope, see what a UN38.3 test report actually covers.
• MSDS / SDS — the safety data documentation that accompanies the shipment.
• Transport assessment or transport-condition report — the document that speaks to the shipment as configured, including the declared section.

Then run one internal control line per SKU, with these columns: model, packing instruction, section, Wh rating, rated capacity, SoC basis (who set it, at what value, evidenced how), and document reference. When a forwarder or an airline asks a question, that single row answers it.

Five misconceptions that get PI966 shipments rejected

"We passed UN38.3, so we're compliant."

UN38.3 is a design-type test for the cell or battery. It says nothing about the charge level of the specific units you are offering. A shipment can have an impeccable UN38.3 report and still be refused for SoC.

"Section II means the 30% rule doesn't apply to us."

Per the publisher leads, the 30% limit applies under Section II where the cell or battery exceeds 2.7 Wh. Section II changes the documentation burden; it does not exempt you.

"Our forwarder accepted it, so it will fly."

Forwarder acceptance is not State approval. Above 30%, the required route is approval from the State of Origin and the State of the Operator under written conditions — carrier discretion does not replace it.

"One SoC figure covers the whole product family."

The calculation is per model and per rated capacity. A single declaration reused across a range of packs is a paperwork defect waiting to be found.

"30% is universal across all lithium shipments and all packing instructions."

Applicability varies by UN classification, packing instruction and energy rating — which is exactly why Step 1 comes first. The unresolved 25% figure quoted by one forwarder for some contained-in-equipment cases is a reminder to verify against IATA's text and your operator, not a summary.

Where this actually bites on US / EU / UK export lanes

The pinch points are operational, not theoretical:

• Origin-terminal acceptance. This is where the decision lands, and where an above-30% consignment with no approval has nowhere to go.
• Multi-pack consignments. Several spare packs in one carton multiply the number of units whose charge state must be evidenced — and the number that can each independently fail a check.
• Last-minute SKU substitution. Swapping a pack after the documentation was assembled against a fixed cut-off is how compliant shipments become non-compliant ones.

State variations and operator variations sit on top of the IATA baseline, so a shipment accepted on one route is not automatically accepted on another. Confirm the route-specific conditions rather than assuming continuity.

Evidence gaps: how to verify this yourself rather than trusting a summary

The authoritative text is the current IATA Dangerous Goods Regulations, 67th Edition, together with IATA's own lithium battery guidance. Blog summaries — this one included — are a starting point, not the rule.

About the leads used on this page: the publisher dates are not independently verified, a source URL does not itself verify a claim, and the cited pages were used as research leads rather than confirmed primary sources. The 25% display level quoted by one forwarder is flagged above precisely because it conflicts with the other leads and we cannot adjudicate it.

Where the evidence is absent, use a verification method instead of a figure: ask your forwarder and the operating airline, in writing, to confirm (a) the SoC limit for your specific SKU, (b) the section it will be declared under, and (c) any additional acceptance conditions beyond the IATA baseline. Keep those replies with the SKU row described in Step 6.

Next step: close the paperwork gap before you book

The six checks, on one screen:

1. Confirm the packing instruction is PI966 — in writing, for the actual SKU list.
2. Place each SKU in Section I or Section II, checking the 2.7 Wh line.
3. Calculate 30% of rated capacity per model and record the basis.
4. Decide how SoC is verified and evidenced before handover.
5. If shipping above 30%, start the State of Origin and State of the Operator approval route early.
6. Assemble the per-SKU document pack: UN38.3 report, MSDS, transport assessment.

Request the compliance document pack for your specific model (UN38.3 report, MSDS, transport assessment) and discuss a packed-with-equipment air freight plan. Bring your SKU list and the destination lane, and we will match the documentation to the model rather than to a generic template. The full set of lithium battery certification and transport documents we hold is listed in the compliance hub, and the team can walk through which documents apply to your configuration.

If your consignment includes spare packs alongside equipment, say so when you enquire — that one detail determines whether this checklist applies at all.

FAQ

Who is responsible for setting and evidencing the state of charge — the battery manufacturer, the equipment maker, or the shipper?

Responsibility follows the offer for transport. The shipper offering the goods is accountable for the declared condition of the shipment, which in practice means they must obtain the SoC basis and supporting records from whoever set the charge state. If that party is a contract packer, put the obligation in the packing instruction you issue, and keep the returned record.

What happens if a PI966 shipment is offered above 30% state of charge — can the airline still accept it?

Only through the approval route described in Step 5: approval from the State of Origin and the State of the Operator, under those authorities' written conditions. A carrier accepting it informally is not the same thing, and the decision point is the origin terminal.

Do we need to re-check SoC if the flight slips by a few weeks?

Yes, treat a slipped flight as a new verification event. Self-discharge over storage time means the charge state at pack-out is not necessarily the charge state at handover, and the record you hold should reflect what was true at the point of offer.

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