IATA DGR 1.2.7.1 (i): Exemption for Lithium Battery-Powered Data Loggers & Tracking Devices
When shipping high-value pharmaceuticals, perishables, or precision chemicals, you will often find a small active device attached to the cargo: a lithium battery-powered data logger or shipment tracking device.
A critical regulatory question arises: Must these lithium battery-powered devices be declared as Dangerous Goods (DG) for air transport?
The answer is: Under specific conditions, they qualify for an exception and are exempt from the DG declaration. This essential exemption is codified in Section 1.2.7.1 (i) of the IATA Dangerous Goods Regulations (DGR).
I. Understanding Section 1.2.7.1 (i)
This provision establishes a specific exception for data loggers and tracking devices powered by lithium batteries. When such devices are attached to or placed within a package, overpack, or Unit Load Device (ULD) to remain active for monitoring purposes during transit, they are exempt from the DGR, provided all of the following nine criteria are met:
All nine conditions must be satisfied:
- Operational Intent: The device must be actively used, or intended for use, during the transport cycle.
- Cell/Battery Compliance: Each internal cell or battery must strictly adhere to the provisions of 3.9.2.6 (a), (e), (f) (where applicable), and (g).
- Lithium-Ion Limits: The nominal Watt-hour (Wh) rating must not exceed 20 Wh per cell or battery.
- Lithium-Metal (Cell) Limits: The lithium content must not exceed 1 g per cell.
- Lithium-Metal (Battery) Limits: The aggregate lithium content must not exceed 1 g per battery.
- Quantity Limitation: The number of devices per package or overpack must be limited to the minimum essential quantity required for its tracking or data-logging function.
- Structural Integrity: The device must be of robust design, capable of withstanding the mechanical shocks and loadings typical of the air transport environment.
- Thermal Safety: The device must be designed to prevent any dangerous release of heat during operation.
- Avionics Compatibility: The device must comply with prescribed Electromagnetic Interference (EMI) standards to ensure its signals do not interfere with sensitive aircraft systems.
II. Battery "Hard Requirements"
To qualify for this exemption, the internal lithium batteries must meet strict safety criteria:
- Safety Certification: Cells or batteries must pass the UN38.3 test series, and a UN38.3 Test Summary must be available.
- Capacity Limits:
- Lithium-ion: β€ 20 Wh.
- Lithium-metal: β€ 1 g (cell) / β€ 1 g (battery).
III. Operational & Compliance Considerations
In addition to battery qualifications, two key operational factors must be addressed:
1. Electromagnetic Compatibility (EMC)
Since these devices remain active during flight, they must comply with electromagnetic radiation standards. IATA (2021) guidance recommends that such devices meet the RF emission limits specified in RTCA DO-160, Section 21, Category H. This ensures that the device's signal does not interfere with sensitive cockpit avionics.
2. The "Necessary Quantity" Rule
The number of devices must be limited to what is strictly necessary for data collection.
π‘ Advice for Shippers & Forwarders: When utilizing this exemption, it is best practice to reference IATA DGR 1.2.7.1(i) on the Air Waybill (AWB) or supporting documents. Always keep UN38.3 Test Summaries and EMC/EMI conformity records ready for inspection by airlines or regulatory authorities.