Lithium batteries power today’s global economy – but they also introduce real risk. Battery incidents in freight have risen 40% since 2021, leading to catastrophic failure of packaged goods and aircraft systems.
Shipment of lithium batteries is regulated under the International Air Transport Association (IATA) Dangerous Goods Regulations (DGR). Like all dangerous goods, lithium battery shipments require a cooperative effort between shippers and carriers. Each party has responsibilities and accountability that they must ensure are upheld in practice.
Responsibility for Dangerous Goods compliance starts with the shipper. The shipper is the one who understands the product – how it’s built, what’s inside it, how the batteries are configured. That information becomes the foundation for everything that follows, from packaging to labeling to documentation. The shipper provides the technical truth, and the forwarder ensures that truth is translated into compliant transport.
This is why even the most experienced forwarder can’t fix certain problems once the cargo is in motion. They can check, validate, and flag issues. But forwarders must rely on the shipper’s documentation and instructions to verify that the contents, classification, and packaging are compliant with applicable regulations.
Cooperation begins with understanding and following the IATA Dangerous Goods Regulations, the industry rulebook used by airlines, shippers, freight forwarders, and ground handlers to transport dangerous goods by air. They are aligned with the International Civil Aviation Organization (ICAO) Technical Instructions, which set the global baseline for the safe transport of dangerous goods by air. IATA’s DGR turns those requirements into an operational manual used day-to-day across the air cargo chain.
The risk of non-compliant dangerous goods shipments—especially lithium batteries—can lead to cargo rejection, fines, safety incidents, or grounded shipments.
What IATA DGR Actually Means in Day-to-Day Operations
The Shipper’s Declaration for Dangerous Goods (DGD) is the shipper’s documentation and instructions to verify that the contents, classification, and packaging are compliant with applicable regulations.
From a warehouse operations perspective, one of the most common issues involves incorrect or inconsistent labeling—particularly shipper and consignee details or business entity names. To mitigate this risk, Dimerco’s procedure is to prepare standardized labels with verified information and affix at least two labels to each piece of cargo. We also ensure that all documentation, including the DGD, House Air Way Bill (HAWB), and physical labels, reflects consistent and matching information to prevent discrepancies during airline acceptance.
The IATA’s DGRs are a reality for shippers and forwarders. It’s not just about following the rules to satisfy the bureaucracy. It’s a liability transfer from shippers to forwarders to carriers.
While airlines ultimately accept cargo based on compliance, forwarders are the first gatekeepers in the chain.
Only one mistake can lead to:
- Shipment rejection
- Airline penalty
- Possible blacklisting
- Safety risk (worst case)
Every shipment must be flawless. There are no excuses. Compliance is not optional—it means operational survival.
Step-by-Step: What Forwarders MUST Do
Step 1: Identify Dangerous Goods (MOST MISSED STEP)
Forwarders must exercise due diligence even on the most trusted shipper’s documentation. The Shipper’s Declaration of Dangerous Goods alone is NOT enough.
Forwarders are accountable for:
- Reviewing MSDS/SDS
- Checking the UN number & proper shipping name
- Validating whether the cargo is a hidden Dangerous Good due to misclassification (a very common problem).
Examples:
- Lithium batteries are located inside equipment, but are not labeled with UN3481
- Chemicals labeled as “non-hazardous” but still regulated
Step 2: Classification & Regulation Check
The forwarder must confirm that items are correctly labeled for
- Hazard class (1–9)
- Packing group
- Passenger vs Cargo Aircraft restrictions (CAO vs PAX)
Mistakes in classification may cause automatic airline rejection of the cargo.
Step 3: Packaging Compliance (Shipper + Forwarder Responsibility)
The Forwarder has the responsibility to verify compliance with the following:
- UN-certified packaging
- Inner/outer packaging requirements
- Weight limits (especially lithium batteries, e.g. PI 965/968)
This is a potential area of non-compliance for forwarders. Many forwarders assume the shipper packed the items correctly without verifying compliance with the regulations. This is a significant risk gap for forwarders and shippers.
Step 4: Marking & Labeling
The packaging compliance check should also include markings and labels to ensure that the outside of the package indicates the actual contents.
- Correct hazard labels
- Handling labels (e.g., lithium battery mark)
- Orientation arrows (if required)
If labels and markings are missing or incorrect, the shipment will be rejected before acceptance.
Step 5: Documentation Validation
Each document must be checked to ensure all the information matches, and any additional information may be required for the carrier to accept the shipment.
- Shipper’s Declaration for Dangerous Goods (DGD)
- Air Waybill (must match DGD exactly)
- Supporting documents (SDS and test reports if needed)
One of the most common mistakes is a description mismatch between the Air Waybill and the Declaration for Dangerous Goods. Any differences between the documents, no matter how minor, can lead to shipment rejection.
Step 6: Airline Pre-Check & Booking Approval
Keep in mind that not all airlines accept all types of Dangerous Goods. The forwarder must:
- Pre-alert airline
- Confirm acceptance policy
- Secure approval before cargo arrives
We have dealt with airlines that are stricter about lithium batteries or that will refuse certain UN numbers entirely. Flawless documentation up to this point is critical to ensure the cargo is accepted.
Step 7: Handling, Storage & Handover
The forwarder must ensure that all DG cargo is properly segregated from other goods and stored under the required conditions in a DG-certified warehouse.
The risk is that improper storage could result in a compliance violation, even if the paperwork is correct.
Biggest Risks Forwarders Face
In managing thousands of dangerous goods shipments each year, forwarders encounter several common issues that can lead to compliance violations and potentially risky situations. Each of these issues can be avoided by strictly following the regulations and proper procedures.
- Shipper Says It’s Not DG
The forwarder accepts cargo without following the verification steps above. In this case, the liability falls solely on the forwarder. The forwarder is responsible for identifying errors and rejecting the load.
- Lithium Battery Misclassification
This is the most common dangerous goods violation globally, as billions of lithium batteries circle the supply chain. They are embedded in everyday products like medical devices and often overlooked or misdeclared.
Lithium-ion, lithium-metal, and sodium-ion batteries fall under Hazmat Class 9 based on their potential risks during transportation. Lithium batteries must be properly classified, packaged and labeled.
The classification of lithium batteries for Section II shipments is often abused or misapplied.
Section II lithium batteries are smaller, excepted dangerous goods (Class 9) that meet specific, low-watt-hour constraints, allowing them to bypass some, but not all, IATA/DOT regulations. These cells require specialized labeling, robust packaging to prevent short circuits, and strict adherence to quantity limits. Stand-alone Section II batteries (UN3480/3090) are generally forbidden on passenger aircraft. While a DGD may not be required, the air waybills must often include specific phrases noting compliance, depending on carrier practices.
- Documentation Errors
Small typos or administrative errors can result in a shipment rejection or a fine. Every waybill number, UN classification number, and shipping name must be absolutely correct.
- Airline-Specific Rules Ignored
Following IATA regulations to the letter may not be enough, as IATA policy can be superseded by the carrier’s specific practices. Keep in mind that airline policy is often stricter than IATA rules, so forwarders must comply with each carrier’s rules.
- Lack of DG Training
Anyone involved in air shipments of restricted materials must complete International Air Transport Association (IATA) DGR training. Training is valid for 24 months and must be renewed. Staff with expired certification or who have never been certified should not be involved with Dangerous Goods shipments.
Forwarders must understand that training is not optional under IATA DGR—it’s legally required.
How Forwarders Reduce Risk
Forwarders must implement systems to manage Dangerous Goods shipments to reduce their own risk and the risks for any parties involved in moving the cargo. This is where experience matters. Not just knowledge of regulations, but knowledge of how those regulations are applied in day-to-day operations.
- Build Internal SOPs
Develop a standard checklist to evaluate and verify dangerous goods shipments before they are accepted for shipment. Create a mandatory document validation flow that verifies every aspect aligns with IATA and airline requirements.
- Train Staff Regularly
Ensure all staff complete IATA DGR certification, both initial and recurrent, within the allotted time before the certification expires. Conduct role-based training (ops vs sales vs warehouse) to ensure staff are educated on aspects of compliance that apply to their daily workflow.
- Use a Pre-Alert & Double-Check System
Early in the booking process, obtain both operations and supervisor validation for each DG shipment to ensure internal SOPs are followed. Pre-alerts enable the internal team to prepare for the incoming paperwork.
- Partner with DG Specialists
For complex shipments such as radioactive materials and explosives, work with specialists with the necessary experience to ensure that packaging, labeling, and carrier selection comply with regulations.
- Communicate Clearly with Shippers
Forwarders must define responsibility boundaries from the beginning and require proper documentation upfront. Most forwarders like Dimerco are not certified to re-pack dangerous goods or reissue the Shipper’s Declaration for Dangerous Goods. If there is an issue with the shipper’s documentation and instructions, the load may be returned, or a specialist DG handling partner may be engaged to repack the cargo and reissue the DGD.
Treat Everyday DG Shipments With Care
In practice, most DG issues don’t come from complex Class 1 (explosive) or Class 7 (radioactive) cargo—they come from everyday shipments like lithium batteries, chemicals, or equipment that are misdeclared or misunderstood.
Forwarders operating in a specialized semiconductor manufacturing ecosystem where dangerous goods shipments are rapidly increasing must realize they may be under extra scrutiny.
Rules compliance will be especially critical to avoid fines and delays. As electronics hubs like Dallas-Fort Worth and Phoenix expand, airlines may scrutinize sensitive shipments more closely. Airlines will be especially sensitive to shipments using general cargo rates for DG-designated shipments. Some of those shipments may be held for compliance review or escalated to the airline headquarters for high-level review. Shipments could be delayed, or shippers could be permanently banned by a carrier for failing to follow regulations.
Strict compliance with DG regulations and the forwarder’s own internal processes ensures each shipment receives the same level of diligence regardless of its classification. The reward is fewer delayed shipments, lower fines, and a higher level of customer service.
Forwarders who treat DG compliance as a checklist will struggle. Those who treat it as a risk management system will win.
Dimerco works with shippers to anticipate issues, adapt quickly, and keep shipments moving without disruption. For more information on shipping cargo under IATA Dangerous Goods Regulations, contact a Dimerco expert.