Shipping drones and lithium batteries from China: a procurement guide

This overview addresses selected 2026 air and sea transport provisions and Chinese drone export controls, including announced changes taking effect on November 18, 2026.

Classify the batteries by their actual packing arrangement

Lithium-ion batteries use UN 3480 when shipped on their own and UN 3481 when packed with equipment or contained in equipment. They are classified as Class 9 dangerous goods, although qualifying shipments may use provisions that reduce particular transport requirements.

For air transport, distinguish these three arrangements:

A purchase order describing a “drone kit” does not establish its packing arrangement. Record where each battery will be placed. A loose spare beside a drone and a battery installed in that drone require different classification decisions.

Standalone lithium-ion batteries are restricted to cargo aircraft. The passenger-aircraft prohibition took effect in April 2016. The transition ending PI 965 Section II finished in April 2022, so small standalone batteries no longer have that simplified air-shipping route. A dangerous goods declaration is required under the applicable PI 965 provisions.

PI 966 and PI 967 provide routes for passenger and cargo aircraft, subject to their respective conditions. For installed batteries, secure them, prevent short circuits and protect the equipment against accidental activation. Under PI 966, batteries need inner packaging that prevents short circuits. They may share a compliant outer package with equipment, or be placed in compliant separate outer packaging and then combined with the equipment package or placed in a common overpack. Document the chosen arrangement; sharing a consignment alone does not establish compliance.

Apply the capacity and quantity conditions together

100Wh per battery and 20Wh per cell are important thresholds for simplified provisions. They are not, by themselves, confirmation that a shipment qualifies.

Cells above 20Wh or batteries above 100Wh require PI 965 Section IA or PI 966/967 Section I. Smaller units also require these sections if they exceed the applicable Section IB or II limits; capacity alone does not determine the section. Check all conditions before shipping under the selected instruction.

PI 965 Section IB permits up to 10 kg net battery weight per package, on cargo aircraft only. Section IA permits 35 kg per package on cargo aircraft. Both require a Shipper's Declaration for Dangerous Goods (DGD).

PI 966 and PI 967 Section II each have a 5 kg net battery weight limit per package on passenger or cargo aircraft. Qualifying shipments may use Section II without a DGD. PI 966 also limits the quantity to the number needed to operate the equipment plus no more than two spare sets. Record operating and spare quantities; exceeding Section II limits requires reassessment under Section I, not automatic acceptance of extra batteries.

PI 966/967 Section I limits are 35 kg net battery weight per package on cargo aircraft and 5 kg on passenger aircraft. These figures do not replace other packing conditions. The 160Wh passenger-baggage figure is not an air-cargo capacity ceiling: higher-capacity batteries are not automatically prohibited as freight.

Check state of charge before packing

For standalone batteries under PI 965, the normal air-transport limit is 30% state of charge (SoC). This requirement took effect in April 2016. Shipment above that level requires approval from the authorities of the State of Origin and the State of the Operator under Special Provision A331.

From January 1, 2026, PI 966 Section I requires all lithium-ion cells and batteries to be at 30% SoC or less, with no 2.7Wh exemption. Shipment above 30% requires approval from the authorities of the State of Origin and the State of the Operator.

Under PI 966 Section II, the mandatory 30% ceiling applies to cells and batteries above 2.7Wh, following the 2025 recommendation. For units at or below 2.7Wh, 30% or less remains recommended. Units above 2.7Wh shipped above 30% cannot use Section II: they must meet Section I and obtain both authorities' approvals.

For PI 967, there is no mandatory 30% ceiling, although lower charge is recommended. The IMDG Code does not impose a general 30% ceiling on intact batteries shipped by sea.

Ask the supplier to record the intended dispatch charge level and how it will be checked. Include this in the packing review so that a change from installed batteries to batteries packed alongside equipment also prompts a review of the applicable SoC requirement.

Assess sea transport under SP 188 or P903

IMDG Code Amendment 42-24 was voluntary in 2025 and became mandatory from January 1, 2026. Air packing instructions do not determine sea-transport eligibility.

Special Provision 188 (SP 188) can apply to both UN 3480 and UN 3481. Its capacity thresholds are 100Wh per battery and 20Wh per cell, but the shipment must also satisfy the other applicable conditions. Review short-circuit protection, packaging, the applicable 1.2-metre drop-test and battery-marking conditions, and the 30 kg gross package limit for standalone batteries.

Review those conditions against the actual configuration before relying on relief from ordinary Class 9 declaration and UN-specification packaging requirements.

Cells above 20Wh, batteries above 100Wh, and shipments failing any other applicable SP 188 condition do not qualify for that provision. P903 is the relevant sea packing instruction for the fully regulated shipments discussed here. Select packaging against the applicable requirements rather than treating a general package-weight figure as permission for a particular battery consignment.

Request documents that match the proposed shipment

Request the UN 38.3 Test Summary for the battery model. Manufacturers and distributors have been required to make this summary available since January 1, 2020. The summary and the underlying test report are distinct documents. Compare the model and battery specifications with the products being purchased.

Also request the Safety Data Sheet (SDS). This document has a standard 16-section structure and is prepared by the manufacturer or supplier, with transport information in Section 14. Review it alongside the battery specifications and the proposed UN classification.

For dispatch from China, establish whether a cargo transport appraisal report is required for the selected departure point and carrier. Ask which issuing bodies and validity periods are accepted, and which battery, packaging and shipment details must match the report.

CCAR-276-R2, the Chinese provisions on the transport of dangerous goods by civil air, took effect on July 1, 2024. For the appraisal report, confirm the actual acceptance requirements before relying on an existing document.

Review Chinese export controls separately

The drone-related announcements developed in the following sequence:

Treat this chronology as background for the export review. Repealed announcements should not be presented as the operative authority for a new shipment.

Announcement No. 49 of 2026 was issued by the Ministry of Commerce, the General Administration of Customs and the Equipment Development Department of the Central Military Commission. Its changes are announced but not yet effective as of November 13, 2026. From November 18, they include controls on autopilots specially designed for unmanned aerial vehicles (7A103.b) and certain technologies for items under 7A103, including gimbal stabilization and mission payload technologies (7E103).

The announcement also provides facilitation measures: items under 9A012.a.1 may be exported independently after registration before each export and receipt of an export certificate; eligible enterprises may use general licences. The customs declaration remarks field must state whether the goods are controlled items. Apply the relevant conditions and effective date when selecting a procedure.

Provide specifications for aircraft, engines, imaging equipment, radar, lasers, communications equipment, inertial measurement equipment, dedicated autopilots and civil anti-drone systems. Include relevant technology transfers, particularly gimbal stabilization and mission payload technologies. Controls depend on complete technical conditions; one isolated specification cannot establish the result.

Record the intended end user and end use. The Export Control Law and the Regulations on the Export Control of Dual-Use Items provide the current catch-all framework for unlisted items. The latter took effect on December 1, 2024. Assess risks involving national security and interests, weapons of mass destruction and terrorism, including relevant knowledge or notification triggers. Review military end uses against applicable controls and prohibitions; do not assume an unlisted drone is unrestricted or rely on the repealed No. 31 announcement as current authority. Request a documented assessment against the applicable list and end-use provisions before dispatch.

Complete a shipment-specific review

Keep a single review record containing the battery model, capacity, packing arrangement, package quantities, weights, SoC plan and supporting documents. Add the aircraft and payload specifications used in the export assessment.

Before releasing the order for shipment, resolve discrepancies between that record and the actual packed goods. If the battery quantity, installation arrangement or payload changes, revisit the affected classification and documentation decisions. When requesting a review from our team, provide this record and identify any questions that remain unresolved.