Batteries and spare parts are where we see private senders and smaller businesses come unstuck more than anywhere else. Most people assume you put it in a box and send it. In reality a lithium battery is Class 9 dangerous goods, a used gearbox can be regulated because of the oil still in it, and the wrong paperwork stops a shipment before it ever reaches an aircraft. This guide explains what actually applies, in plain English.
In 40 years in this trade, the same problems come up again and again: misdeclaration, no HS code on the commercial invoice, poor packing, and — above all — people simply not knowing what the export process involves. Batteries and spare parts concentrate all four. They are ordinary objects that most of us own, and almost nobody realises they are regulated the moment they go near an aircraft. Nothing here is difficult once you know it. The expensive way to find out is at the airport, with a shipment that has already been refused.
Before the regulations, the practical answer for most people reading this:
So: if you are moving house or sending bags and the battery is not essential, leave it out — it is the cheapest, simplest route. If the battery is the shipment, or you are a business sending product, it can be done properly as DG. Either way, tell us what is in it before you pack.
This is not paperwork for its own sake. Lithium-ion batteries can and do cause fires that destroy aircraft and kill the people on board, and the rules exist because that has already happened.
So when we say a battery has to be declared, packed and documented properly, it is not administrative caution. An undeclared battery in a box is a risk to the aircraft and everyone on it — which is why the penalties are serious and why we ask every customer what is in the shipment before it is packed.
The items involved are ordinary: a laptop, a power bank, a cordless drill, an e-bike battery, a drone, a child’s ride-on toy, a replacement phone battery, a car part with a control unit in it. That is exactly why people get caught out.
Almost everything follows from this one distinction. The same battery is treated three different ways depending on how it travels, and each has its own UN number and packing instruction.
| How it travels | Lithium-ion | Lithium metal |
|---|---|---|
| On its own a spare battery, a power bank |
UN3480 • PI 965 | UN3090 • PI 968 |
| Packed with equipment device and a spare battery in one box |
UN3481 • PI 966 | UN3091 • PI 969 |
| Contained in equipment battery installed in the device |
UN3481 • PI 967 | UN3091 • PI 970 |
A worked example: wireless earbuds sent in their charging case are “packed with equipment”. Send the charging case on its own, with no earbuds, and it becomes a loose battery — a stricter category.
A fully charged lithium cell releases far more energy if it fails. Regulators have steadily tightened the rules on how charged a battery may be when it is handed over.
If a battery falls into any of these categories, tell us early. There are often sensible alternatives — sea freight for some items, buying the battery at destination for others, or sending the equipment without its battery.
This is the part people underestimate. Depending on the type, size and configuration of the battery, a shipment may need all of the following:
Batteries at least look like batteries. Spare parts are harder, because the item itself seems completely ordinary. These are the ones we see most:
The rule of thumb: if it holds a charge, holds a liquid, holds pressure, has ever held fuel, or sticks firmly to your fridge — tell us before it is packed.
The second most common cause of delay we see has nothing to do with hazards. It is a commercial invoice that isn’t complete.