Dangerous goods
Lithium batteries from Korea: the UN 38.3 test summary
Korea exports a great many lithium cells, batteries and products built around them. Almost every one of those shipments turns on a document the shipper does not produce and often has never seen: the UN 38.3 test summary. If you cannot put your hands on it, the freight does not fly.
The rule in one line
Every lithium cell and battery must be tested to the UN Manual of Tests and Criteria, Part III, sub-section 38.3. IATA's guidance for 2026 is blunt about what happens otherwise: a cell or battery that has not passed the UN tests “may only be transported under State Approval as per Special Provision A88”. In practice that is not a route, it is a refusal.
Since 1 January 2020 the test result has had to travel with the product as a summary document. Per the same guidance, “manufacturers and subsequent distributors of cells or batteries and equipment powered by cells and batteries manufactured after 30 June 2003 must make available the test summary” described in paragraph 38.3.5 of the Manual, Revision 8. Button cells installed in equipment, including on circuit boards, are excepted.
Note the words subsequent distributors. If you buy cells in Korea and export them, or export a device somebody else assembled, the obligation reaches you as well as the maker. It is not enough to know the test was done somewhere upstream.
What the summary has to say
A test summary is not a certificate with a logo on it. The Manual sets out what it must contain, and a document missing these is not a test summary whatever it is titled:
- Name of the cell, battery or product manufacturer, and its contact details — address, phone, email and website.
- Name of the test laboratory, with the same contact details.
- A unique test report identification number, and the date of the test report.
- Description of the cell or battery: lithium ion, lithium metal or sodium ion; mass; watt-hour rating or lithium content; a physical description; and model numbers.
- The list of tests conducted and the result of each, pass or fail.
- A reference to assembled battery testing where it applies (38.3.3(f) and (g)).
- Which revised edition of the Manual was used, and any amendments to it.
- Name and title of the responsible person, as an indication that the information is valid.
Check the model numbers against what is actually in the carton. A summary for a neighboring model is the most common reason a consignment is held, and it is usually discovered at the airline, not at the factory.
You do not have to put a paper copy in every box. IATA notes that compliance “may be achieved by placing the test summary on a website and providing a QR code or URL with the battery, its packaging or on the transport documentation”. If your supplier offers a link, save the file as well — links move, and a held shipment is a poor moment to discover it.
State of charge: the 2026 change that catches exporters out
The state-of-charge limit used to be a rule about batteries shipped on their own. It is no longer only that. IATA's 2026 guidance records that “from 1 January 2026, lithium-ion batteries that are packed with equipment and vehicles powered by lithium ion or sodium ion batteries must be offered for air transport with the battery at a reduced state of charge, unless otherwise approved by the relevant States” under Special Provision A331. ICAO adopted the change into the 2025–2026 edition of the Technical Instructions.
What that means depends on how the battery is packed, and the four cases are not the same:
| How it ships | PI | State of charge |
|---|---|---|
| Batteries on their own | 965 | Required: not over 30% of rated capacity. Above 30%, only with the approval of the State of Origin and the State of the Operator |
| Packed with equipment, Section I | 966 | Required from 1 Jan 2026: not over 30%. Above that, both States must approve in writing |
| Packed with equipment, Section II | 966 | Required from 1 Jan 2026 for cells and batteries over 2.7 Wh. Above 30% they must move under Section I, with both approvals |
| Contained in equipment | 967 | Recommended, not mandatory: not over 30%, or an indicated battery capacity not over 25%. IATA calls it “strongly recommended as a transport safety measure” |
So a Korean exporter who has shipped devices packed alongside their batteries for years, at whatever charge they left the line with, is inside a new requirement as of January 2026 — while the same device with the battery installed is only inside a recommendation. That distinction decides whether a shipment is refused or merely discouraged, and it is worth establishing before the carton is sealed.
For sodium ion batteries packed with or contained in equipment, IATA notes the ICAO Technical Instructions are “currently silent regarding the state of charge”. Silence is not permission to assume it will stay that way; the guidance describes the chemistry as emerging and further regulation as expected.
Two further points on batteries shipped alone: they cannot travel on a passenger aircraft unless approved under Special Provision A201, which on the Korea lane means cargo aircraft in practice and changes both routing and price. And rated capacity has a defined meaning — capacity measured under a load, temperature and voltage cut-off specified by the manufacturer, with the method in sub-section 38.3.2.3 of the Manual. It is not the number on the marketing sheet.
Which UN number you are shipping
| What is in the box | UN | Packing instruction | Per-package limit |
|---|---|---|---|
| Batteries alone, cells over 20 Wh or batteries over 100 Wh | UN 3480 | PI 965 Section IA | Passenger aircraft forbidden; cargo aircraft 35 kg |
| Batteries alone, cells up to 20 Wh or batteries up to 100 Wh | UN 3480 | PI 965 Section IB | Passenger aircraft forbidden; cargo aircraft 10 kg |
| Packed with equipment, over the same thresholds | UN 3481 | PI 966 Section I | Passenger 5 kg; cargo 35 kg |
| Packed with equipment, at or under them | UN 3481 | PI 966 Section II | Passenger 5 kg; cargo 5 kg |
| Contained in equipment, over the thresholds | UN 3481 | PI 967 Section I | Passenger 5 kg; cargo 35 kg |
| Contained in equipment, at or under them | UN 3481 | PI 967 Section II | Passenger 5 kg; cargo 5 kg |
Section IA needs UN specification packaging; Section IB packages are drop and stack tested and carry the lithium battery mark alongside the Class 9 hazard label and the cargo aircraft only label. Power banks are batteries, not equipment, and are assigned to UN 3480. Sodium ion batteries now have their own entries and packing instruction, so a supplier switching chemistry changes your paperwork.
Before the booking
- Get the test summary from the manufacturer in writing, as a file, before you quote a routing.
- Match model numbers and watt-hour ratings on the summary to the goods, not to the purchase order.
- Confirm the state of charge with the factory and record who confirmed it.
- Decide the UN number and packing instruction from what is physically in the carton.
- Tell the forwarder at booking, not at the warehouse. Cargo aircraft capacity is planned, not found.
- Keep the summary with your export shipping documents for the file.
These rules are aviation rules and they change on an annual cycle. Confirm the current edition with your forwarder or the airline before you rely on any figure here.
Keeping the file together
A held battery shipment is rarely one missing document. It is a summary in an email thread, a state-of-charge confirmation in a chat message, and a packing photograph on somebody's phone. Cargovate's platform keeps one record of a shipment across carriers and borders — where it is, who holds it, and what was recorded at each step — so the file that answers the airline is assembled before it is needed rather than after.
Last reviewed 2026-09-20