How can you confirm lithium batteries are in compliance? Have we finally found the Holy Grail?

A new “Note” has appeared in the 2025-2026 ICAO Technical Instructions/2025 IATA Dangerous Goods Regulations which adds a new level of opaqueness to the transport of lithium batteries by air (and other modes).

This follows adoption of the recommendation by the UN Sub-committee of Experts on the Transport of Dangerous Goods, relating to the test summary for lithium and sodium ion batteries as specified in the Manual of Tests and Criteria UN38.3.

The note reads:

“The term MAKE AVAILABLE means that manufacturers and subsequent distributors ensure that the test summary is accessible so that the shipper and other persons in the supply chain can confirm compliance”.

This appears to be an incomplete sentence…the shipper and other persons in the supply chain can confirm compliance with what?

– That they have a test summary?

– That the cell/battery has been subjected to all the necessary tests and successfully passed them?

– That the in house quality management program the manufacturer used was to a satisfactory standard and each cell/battery is 100% compliant, without any manufacturing defects.

Notes in the regulations are not regulations but are intended to be a way of providing guidance and/or interpretation of a complex area. Unfortunately, as we know from experience, this text will be interpreted quite literally by many in the supply chain and will no doubt lead to confusion, rejections and delays of lithium and sodium ion battery shipments.

Thanks for the note!

I suspect we will be waiting a few more years to find the Holy Grail.