By Bernardo Campelo, Forbes Business Council E-Commerce Leader, Amazon SPN Certified provider, Amazon SP-API authorized partner, and Founder of PrepVia.
Picture a brand that sells a cordless handheld vacuum with a spare battery pack in the retail box. A new production run has to fly to make a promotion date. The day before cutoff, the forwarder sends one line: what is the state of charge of the batteries, and who signs for it? Nobody on the brand side has the answer on file.
That question comes from a rule that took effect on January 1, 2026, and it is easy to misread in both directions. One reading says the limit now covers every lithium-ion product you sell. The other says the rule only touches battery makers. Both are wrong.
Here is the thesis. The 30 percent limit is not one rule but several, one for each way a battery can sit in a box, and only some are mandatory. Amazon then asks its own question on top, and the paperwork you hold decides whether you can answer it honestly.
The 60-second version
The 2026 change made 30 percent state of charge mandatory by air for lithium-ion batteries packed with equipment, not for every lithium-ion product. Since January 1, 2026, the ICAO Technical Instructions and IATA rules require those batteries (Packing Instruction 966) to fly at no more than 30 percent of rated capacity: all of Section I, and Section II above 2.7 Wh. Batteries shipped by themselves (UN 3480) are also held to 30 percent; batteries contained in equipment are only strongly recommended to be. On Amazon, a blank state-of-charge answer makes the product ineligible for air, and the US version is still a proposal.
What Actually Became Mandatory on January 1, 2026
The cleanest statement of the rule is the IATA Battery Guidance Document revised for the 2026 regulations, dated January 1, 2026. It is built on the 2025-2026 edition of the ICAO Technical Instructions and the 67th edition of the IATA Dangerous Goods Regulations. IATA labels it guidance, not a compliance source, so treat it as a map to the binding text.
The change is narrow. From January 1, 2026, if your lithium-ion cells and batteries are packed with equipment, Packing Instruction 966, they must be offered for air transport at a state of charge not exceeding 30 percent of rated capacity. In Section I that covers every battery. In Section II it covers cells and batteries rated above 2.7 Wh. Anything above 30 percent needs approval from the State of Origin and the State of the Operator under Special Provision A331, and a Section II battery above 30 percent has to move to Section I, with those approvals.
The same date brought a parallel rule: vehicles powered by batteries above 100 Wh must fly at no more than 30 percent, or at an indicated battery capacity, the reading on the gauge, no higher than 25 percent.
Rated capacity is the amp-hour figure measured under the manufacturer's specified load, temperature and voltage cut-off; sub-section 38.3.2.3 of the UN Manual of Tests and Criteria gives the method. Do not plan on approval above 30 percent as your workaround: IATA notes an airline is not obligated to carry your consignment even then. The stated reason: a cell at a reduced state of charge is less prone to thermal runaway.
Three Configurations, Three Different Rules
The rule follows your configuration: where your battery physically sits relative to the device it powers. Amazon uses the same buckets in its listing form.
| Configuration | UN number and packing instruction | Examples | State of charge by air, 2026 text |
|---|---|---|---|
| Battery by itself | UN 3480, PI 965 | Power bank, replacement laptop battery, spare phone battery sold with a charger | Not exceeding 30 percent; higher only with State approvals (A331). No cargo on passenger aircraft unless approved (A201) |
| Packed with equipment, Section I (cells above 20 Wh, batteries above 100 Wh) | UN 3481, PI 966 | Hand or yard tools shipped with a battery above 100 Wh packed beside them | Mandatory from January 1, 2026: not exceeding 30 percent |
| Packed with equipment, Section II (cells up to 20 Wh, batteries up to 100 Wh) | UN 3481, PI 966 | Remote-control toy or camera with its removable battery packed beside it (Amazon's examples) | Mandatory above 2.7 Wh; at or below 2.7 Wh, a recommendation |
| Contained in equipment | UN 3481, PI 967 | A Kindle tablet, Amazon's own example | Strongly recommended: 30 percent, or 25 percent indicated capacity. Not mandatory |
| Battery-powered vehicle | UN 3556, PI 952 | Electric scooters, e-bikes, self-balancing vehicles | Above 100 Wh: 30 percent, or 25 percent indicated capacity. At or below 100 Wh, recommended |
| Sodium-ion battery by itself | UN 3551, PI 976 | Standalone sodium-ion packs | Not exceeding 30 percent; forbidden as cargo on passenger aircraft |
| Sodium-ion with or in equipment | UN 3552, PI 977 and PI 978 | Devices powered by sodium-ion packs | ICAO text silent; IATA recommends 30 percent |
The 2.7 Wh line is lower than it sounds. Watt-hours are rated capacity in amp-hours times nominal voltage. Illustrative math: a single 3.7 V cell rated at 730 mAh works out to 0.73 x 3.7, or about 2.7 Wh. Read the label before you assume a spare battery sits under the line.
For a battery contained in equipment, a reduced charge is not mandatory. The useful version: the moment a lithium-ion battery leaves the device and sits beside it in the box, the requirement applies, unless it is a Section II battery at or below 2.7 Wh.
Where the Configuration Gets Decided, and Where It Goes Wrong
Your configuration is a fact about the box, not the product category. In Amazon's listing definitions, a battery pre-installed or assembled in the item is contained in equipment. A battery packed with, but not inside, the device it powers is packed with equipment. Put a spare pack in a box whose device already has an installed battery, and your retail unit carries both.
Power bank bundles are the misread I would check first. Amazon and IATA both classify a power bank as a battery, not as equipment and not as a spare. In an IATA worked example with two phones and two power banks in one package, the power banks are UN 3480 under Packing Instruction 965, must ship below 30 percent, and bring the battery mark, the Class 9 battery label, the Cargo Aircraft Only label and a Shipper's Declaration.
This is where kitting quietly changes a classification. Bundle a power bank with a phone case and your kit now contains a standalone battery, because that battery powers nothing else in the box. Each choice like that changes the battery answers on your listing, and your listing is what Amazon classifies. Settle the kit composition in the same conversation as the kitting spec, and put it in your new ASIN launch timeline before the first inbound.
Packaging is the other place your prep step can break compliance. Amazon's battery packaging rules require rigid packaging: original manufacturer packaging, boxes, clamshells or blister packs. Zipper-sealed bags, shrink wrap and other non-rigid packaging are prohibited, terminals must not touch, and button cells need child-resistant packaging with a warning. One nuance: a repackaged battery secured in a box that is taped or closed with shrink wrap passes, because the box supplies the rigidity. The general rules in our 2026 prep requirements checklist still apply on top.
What Amazon Asks, and What It Does With the Answer
Amazon's dangerous goods required information page lists the battery questions in the FBA listing workflow: chemistry, configuration, watt-hours, weight and cell counts. One field maps to the air rule: Has Less than 30 Percent State of Charge. Amazon calls it a mandatory self-certification. You select Yes if the product ships below 30 percent of rated capacity, and if you leave it unanswered, your lithium battery products are not eligible for shipment via air methods.
Read the wording closely. Amazon says less than 30 percent; IATA says not exceeding 30 percent. A battery at exactly 30 percent meets the air rule and misses the literal text of Amazon's question. Set your factory target below 30 with a margin.
The page does not say what a No answer does, and it does not define which shipments count as air methods. What I plan around is simple: a blank field removes air as an option, so your field is never blank. Amazon's September 25, 2026 announcement of new dangerous goods questions from October 26 covers refrigerants, shock absorbers, markers and pool chemicals, not batteries.
Amazon's lithium battery requirements page adds the documents. If your product has lithium-ion batteries packed with equipment, it requires state-of-charge information at listing or on update. It requires a UN 38.3 test summary at ASIN setup and a battery exemption sheet uploaded in Manage dangerous goods classification. Incomplete, inaccurate or conflicting battery information can block your product from sale through FBA.
The same page sets energy limits per store. In the US, Amazon approves lithium-ion cells up to 60 Wh and batteries up to 300 Wh, and rejects anything above. In Europe, Mexico and Brazil, it rejects cells above 20 Wh and batteries above 100 Wh.
Then the clock. With complete information, Amazon classifies your product within two business days, and each resubmission takes another two. If your product is flagged while your inventory sits in a fulfillment center, you get 14 business days to provide documents before the inventory is disposed of at your expense. Our hazmat review guide covers that flow; the review reads the answers you gave at setup.
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The Paperwork Checklist, Configuration by Configuration
This is the instrument: the documents you need, mapped to the three lithium-ion configurations. Where a line is my operating practice rather than a named regulatory document, the table says so.
| Document | Who produces it | Battery by itself (UN 3480) | Packed with equipment (PI 966) | Contained in equipment (PI 967) |
|---|---|---|---|---|
| UN 38.3 test summary | Cell, battery or product manufacturer; distributors must make it available | Required; Amazon wants it at ASIN setup | Required; Amazon wants it at ASIN setup | Required unless the equipment holds only button cells |
| UN 38.3 test report | Test laboratory | Cited by number and date in the summary | Same | Same |
| Amazon battery exemption sheet | You, on Amazon's Excel template | Upload in Manage dangerous goods classification | Same | Same |
| Safety data sheet (SDS) | Manufacturer or importer | Not required by IATA to ship batteries; Amazon may ask for an SDS or an exemption sheet | Same | Same |
| Written state-of-charge statement (my practice, not a named form) | Manufacturer, per production lot | Evidence for the Amazon self-certification; limit mandatory by air | Evidence; limit mandatory in Section I and above 2.7 Wh | Evidence; limit only recommended |
| Battery data: Wh, lithium content, weight, cell count | Battery label, packaging or manufacturer documents | Listing attributes | Listing attributes | Listing attributes |
| Shipper's Declaration for Dangerous Goods | The shipper of the air consignment | Required under PI 965, Sections IA and IB | Section I fully regulated; Section II exempt from certain documentation, still regulated | Same as packed with |
Five checks tell you whether what you hold is any good.
- Match the test summary to the SKU. IATA lists ten required elements, including manufacturer and test lab contacts, a unique report number and date, chemistry, mass, Wh rating, model numbers, each test with pass or fail, and a named responsible person. A model number or Wh that disagrees with your listing is the conflict Amazon says can block the product.
- Ask for the report behind the summary. The report is how you confirm the summary describes the battery in your box. IATA says the summary stays valid unless the battery changes in a way that requires retesting, so a new cell supplier means asking again.
- Get the state of charge in writing, per lot. IATA says no extra document is needed to certify 30 percent for batteries shipped by themselves, because the signed Shipper's Declaration already certifies it. That covers the airline, not you. You are the one clicking Yes on Amazon's self-certification, so ask the factory for percent of rated capacity at pack-out, method, date and PO number.
- Use the exemption sheet, not a battery SDS hunt. IATA states that neither its rules nor the transport rules for other modes require an SDS to ship batteries, since GHS does not cover manufactured articles such as batteries. Amazon accepts an exemption sheet for battery and battery-powered products: fill every red cell, save it as Excel, and keep it consistent with the listing. An SDS you do upload must be created or updated within the past five years, with all 16 sections and a name and brand matching the detail page.
- Compute Wh from nominal voltage. Amazon says to use the nominal voltage printed on the battery, not the input, output or maximum charging voltage.
What Changes for Whom
The second half of the instrument: the same rule, by your role.
| Who | What the 2026 text changes | What to do now |
|---|---|---|
| Brand shipping batteries packed with the device, any leg by air | 30 percent mandatory in Section I, and above 2.7 Wh in Section II | Lot-level charge statement; answer the Amazon field; confirm your Section from the Wh |
| Brand shipping batteries installed in the device | A strong recommendation, not a requirement | Ask the factory what charge it ships at; answer Amazon from evidence |
| Power bank and spare battery sellers | Nothing new in 2026: already held to 30 percent; no cargo on passenger aircraft unless approved | Keep the test summary current; check the US 300 Wh ceiling and lower limits abroad |
| E-mobility brands | Vehicles above 100 Wh fly at 30 percent or 25 percent indicated capacity | Brief the forwarder before booking air; track the separate CPSC proposal |
| Sodium-ion brands | Standalone packs held to 30 percent; with or in equipment, a recommendation | Show the real chemistry on the listing; get a UN 38.3 summary for the sodium-ion cell |
| Manufacturer | IATA assigns classification, and making the information available, to the manufacturer | Supplies the test summary, Wh rating and charge statement |
| Whoever ships the air consignment (factory or forwarder) | Packs, marks, labels and documents; signs the declaration where one is required | Needs configuration, Wh, test summary and charge level before booking |
| Prep center | No new duty in the text; packaging and kitting can still break compliance | Keep battery packaging rigid; never change a kit's battery configuration without a listing update |
On training, IATA says Section IB shippers need formal dangerous goods training, and Section II shippers need "adequate instruction" under DGR 1.6, for which IATA suggests written procedures, a training record and a refresher at least every two years. That is your forwarder or the factory shipping team, not your listing manager. On freight mode, these are air rules: an ocean and truck route is not governed by the IATA text, but Amazon's question still sits on the listing. See air vs ocean freight from China to FBA.
PrepVia is the Miami 3PL and prep center at the end of the chain: it receives, counts, photographs, preps, labels, stores and ships to Amazon. The PrepVia facts page lists Amazon SPN Certified for FBA Preparation and does not list a dangerous goods certification. PrepVia does not claim to measure state of charge or to sign Shipper's Declarations. What it does publish is that it checks the listing status of lithium battery products before receiving, so the units do not sit in review at the warehouse.
The US Rulebook: Proposed, Not Final
In 49 CFR 172.102, Special Provision A100 says lithium-ion cells and batteries must be offered for transport at no more than 30 percent of rated capacity, with anything higher only under conditions approved by the PHMSA Associate Administrator. Codes containing the letter A apply only to transportation by aircraft. PHMSA describes A100 as currently assigned to UN 3480, batteries shipped by themselves, a limit in force since a PHMSA interim final rule took effect on March 6, 2019.
On February 10, 2026, PHMSA published the HM-215R proposed rule, docket PHMSA-2023-0111. It proposes extending A100 to lithium-ion batteries packed with and contained in equipment, to new sodium-ion entries and to battery-powered vehicles, to match the 2025-2026 ICAO Technical Instructions. It mirrors the ICAO split: mandatory above 2.7 Wh for packed with equipment, a recommendation for contained in equipment, and no mandatory limit for sodium-ion with or in equipment. Comments closed on April 13, 2026.
As of October 1, 2026, a Federal Register search by that docket number returns only the February proposal, with no final rule. Which text governs your US domestic air leg in the meantime is a question for your trained shipper, not for a blog post.
If you sell e-mobility, one more track: on June 24, 2026, the CPSC published a proposed safety standard for lithium-ion batteries used in micromobility products. That is product safety, not transport, and it is also a proposal.
Frequently Asked Questions
Does every lithium-ion product have to ship at 30 percent state of charge in 2026?
No. By air, the limit is mandatory for lithium-ion batteries shipped by themselves (UN 3480), for batteries packed with equipment (Packing Instruction 966: all of Section I, and Section II above 2.7 Wh) and for battery-powered vehicles above 100 Wh. For batteries contained in equipment, IATA strongly recommends 30 percent but states it is not mandatory.
What happens if I leave Amazon's state-of-charge question blank?
Amazon calls Has Less than 30 Percent State of Charge a mandatory self-certification, and says that if you do not answer it, your lithium battery products will not be eligible for shipment via air methods. Amazon does not publish what a No answer does, so answer it from a written factory statement.
Do I need an SDS for a lithium battery product on Amazon?
Not by default. IATA states that its rules do not require an SDS to ship batteries, since GHS does not cover manufactured articles such as batteries. Amazon may ask for an SDS or an exemption sheet, and it accepts the exemption sheet for battery and battery-powered products.
Is the UN 38.3 test summary the same as the test report?
No. The test report is the laboratory's full record of the UN 38.3 tests. The summary is a shorter document with ten required elements, including the report number and date, the Wh rating, model numbers and pass or fail results. Amazon requires the summary at ASIN setup, and IATA says it stays valid unless the battery changes in a way that requires retesting.
Is the US version of the 30 percent rule final?
Not as of October 1, 2026. The HM-215R proposed rule of February 10, 2026, docket PHMSA-2023-0111, would extend Special Provision A100 to more lithium-ion entries, sodium-ion entries and battery-powered vehicles. No final rule under that docket appears in the Federal Register yet.
Can my prep center certify the state of charge of my units?
Not PrepVia. Its facts page lists Amazon SPN Certified for FBA Preparation and does not list a dangerous goods certification, and PrepVia does not claim to measure state of charge or to sign Shipper's Declarations. IATA places classification with the manufacturer, so the charge statement belongs to the factory.
Final Take
The 30 percent rule is precise, and precision is what battery listings usually lack. Batteries by themselves: mandatory. Packed with equipment: mandatory from January 1, 2026, in Section I and above 2.7 Wh in Section II. Contained in equipment: a strong recommendation. Get your configuration right and your paperwork follows.
Amazon's part is one field and a few uploads, but the field is a certification with your name on it. A blank takes air off the table; a Yes you cannot back up is a statement without evidence. The fix is cheap: a lot-level charge statement, a matching test summary, and an exemption sheet that agrees with the listing.
The US text is still a proposal. Build your battery file per ASIN before your next production run, and before anyone at the airline or the dock has to ask.
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