FBA battery compliance · 2026 guide
Amazon Lithium Battery Requirements: 2026 Rules, 30% Charge & UN 38.3
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Identify the battery and how it is packed before completing Amazon’s battery questions. A battery installed in a device, a spare packed beside it, and a standalone battery can follow different shipping requirements. The listing attributes and supplier records need to describe the same product.
The rule to check first: Amazon’s January 1, 2026 update addresses lithium-ion batteries over 2.7 Wh packed with products: they must be at 30% state of charge or less for the announced air-fulfillment requirement. Amazon says unconfirmed compliance results in ground-only fulfillment. Check any separate product restriction in its own Amazon notice.
Packed with equipment, contained in equipment, or standalone?
Inspect the retail package to identify how each battery is supplied. A removable battery can still be contained in equipment when it is installed; a spare beside the device is a different configuration.
| Configuration | Typical example | 2026 air-transport distinction |
|---|---|---|
| Lithium-ion packed with equipment | A device and an uninstalled battery in the same package | IATA PI 966: the 30% limit is mandatory under Section I; under Section II it applies to cells/batteries over 2.7 Wh, with approval provisions for higher charge. |
| Lithium-ion contained in equipment | A rechargeable battery installed in the device | IATA PI 967 recommends reduced charge; its 2026 guidance does not make the same general 30% limit mandatory for this configuration. Carrier or Amazon requirements still need checking. |
| Lithium-ion batteries on their own | A standalone battery shipment; power banks are treated as batteries for transport | Separate lithium-ion requirements apply. Do not classify a battery as equipment merely because it has a case or USB port. |
| Lithium metal or another chemistry | A non-rechargeable lithium coin cell, for example | Identify the applicable chemistry-specific rules. The lithium-ion state-of-charge update does not replace those requirements. |
Use the IATA 2026 battery guidance with the applicable packing instruction and carrier conditions. Amazon eligibility and transport requirements are related checks; neither should be inferred solely from an ASIN being active.
How to answer Amazon’s battery information fields
Before filling in the listing form, collect the battery model, packaging configuration, and manufacturer specifications.
| Attribute | How to check it |
|---|---|
| Batteries required vs batteries included | Does the product need batteries to operate, and are they supplied in this offer? A battery-powered device sold without batteries can require them without including them. A mains-only product should not be marked battery-powered just because it plugs in. |
| Chemistry and model | Use the manufacturer’s exact battery type and model. Do not substitute the product’s marketing name for the cell or pack model. |
| Voltage, capacity, and watt-hours | Compare the battery label and technical specification. Check the units carefully. Convert mAh to Ah where needed, and keep rated energy in Wh separate from the percentage charge. |
| Cell/battery count and weight | Answer the specific field shown. A multi-cell battery pack and several separate batteries are not necessarily the same count. |
| Installation or packaging type | Check whether the battery is installed, packed separately with equipment, or shipped independently. Include any spare battery in the review. |
| State of charge | Use a documented production or shipping control. A supplier’s general statement that an item is “safe” does not establish its dispatch charge. |
If a field does not seem to fit the product, preserve the screen and ask for clarification through the relevant Amazon support path. Use an answer supported by the product specifications.
Battery documents: what each record establishes
UN 38.3 test summary
Provides a summary of transport testing for the relevant lithium cell or battery type. Request the summary for the exact model used in your product and a clear mapping when product and battery names differ.
SDS or exemption information
Supports Amazon’s dangerous-goods classification where requested. Use the document route Amazon specifies for the product; an SDS and a UN 38.3 summary serve different purposes.
Battery specification and label
Establishes the chemistry, voltage, rated capacity, model, and other physical specifications used to complete the listing fields.
Charge-control records
Documents how the supplier checks or controls dispatch charge for the relevant shipment configuration. Keep the procedure, acceptance criterion, and batch evidence together.
What to check in a UN 38.3 test summary
Confirm that the manufacturer and test laboratory are identifiable, the test reference and date are present, the cell or battery description matches the supplied model, and the summary records the relevant test outcome and signatory information. IATA explains the requirement for manufacturers and subsequent distributors to make a test summary available in its battery-shipping overview.
A generic file called “UN38.3 certificate” is not enough to establish a model match. Ask the issuer to correct errors or explain model relationships with supporting records. Do not edit a laboratory report yourself.
How to calculate watt-hours from volts and mAh
For a battery’s nominal ratings: Wh = V × Ah. If capacity is given in milliamp-hours: Wh = V × mAh ÷ 1,000.
Illustrative example: a battery labeled 3.7 V and 1,200 mAh has a calculated nominal energy of 4.44 Wh. A document showing 1,000 mAh at 3.7 V describes 3.7 Wh. That discrepancy needs explaining; neither value tells you the battery’s current state of charge.
Use the finished pack’s rated voltage and capacity. Adding capacities or multiplying by cell count without understanding the pack configuration can produce a wrong answer. Confirm the rating with the battery manufacturer.
What to do if Amazon limits fulfillment or requests documents
Record the ASIN, SKU, marketplace, message, and deadline. Ground-only fulfillment, a dangerous-goods classification review, an inbound restriction, and listing removal are different statuses.
Check the physical battery label against listing attributes, specification, UN 38.3 summary, and requested classification documents. Make a short mismatch list.
Ask the manufacturer or document issuer to fix inaccurate records or provide the model mapping. Correct catalog attributes only when the evidence supports the change.
Answer the requested battery questions and provide the relevant attachments. Explain which mismatch was corrected and where the reviewer can find the matching model and ratings.
Check the current classification and fulfillment status after review. Retain the case history and use the deadline in your notice; do not assume a universal review time or disposal deadline.
If the hold remains after you respond, ask our regulatory team to review the battery restriction. Send the affected ASIN, Amazon’s request and the documents already submitted so we can compare the product, report and response.
A supplier request you can adapt
Send the supplier your finished-product model, marketplace and a description of the retail package. Ask for a response that identifies the actual battery used in the units you will ship.
Battery document request
Subject: Battery records for [product model] and shipment [reference]
Please confirm the battery manufacturer, exact cell or pack model, chemistry, nominal voltage, rated capacity in Ah or mAh, and rated energy in Wh. Please provide readable label photographs, the matching UN 38.3 test summary, and the SDS or other classification document requested for this product.
The retail package contains [device and all included batteries]. Please confirm which batteries are installed and which are packed separately, including spares. If the product name differs from the battery model in the documents, please provide a written model mapping supported by your production records.
Where the applicable shipment requires a charge limit, please identify the dispatch-charge procedure, how charge is checked, the acceptance criterion, and the record for the relevant production batch. Please also disclose any battery supplier, model or specification change since the documents were issued.
Keep a question open if the supplier sends a document for a different battery. A product photograph may establish which label is present, while a manufacturer’s model mapping explains how the finished product and battery records connect. Both can help resolve the mismatch.
Example: make the battery evidence easy to follow
Suppose a fictional desk lamp is sold as model DL-10, but its battery is labeled BP-44. A useful working index could look like this:
| Record | Identity to locate | What remains to check |
|---|---|---|
| Product and packaging photographs | DL-10 and the installed BP-44 battery | The photographs show the version and package actually offered. |
| Battery specification and label | BP-44, 3.7 V, 1,200 mAh, 4.44 Wh | The listed ratings match across the label and specification. |
| UN 38.3 test summary | The relevant tested battery type and test reference | The manufacturer explains any model naming difference and confirms applicability. |
| Amazon response | Affected ASIN, model mapping and requested attachments | The response answers the specific review request and identifies each supporting file. |
These fictional ratings illustrate document matching, not a shipment classification. Add filenames and page numbers to the index, and keep any unresolved mismatch visible. If the supplier changes BP-44 to another battery, review the affected documents, attributes and shipment information before treating the previous records as applicable.
Check each marketplace without changing the physical facts
Availability, carrier routes, and Amazon program conditions can differ. Keep the same product’s ratings consistent across marketplaces, then verify each market’s current eligibility. A product being ground-eligible in one program does not establish air eligibility in another.
For a toy containing a battery, also review Amazon’s toy-testing process. Battery transport evidence does not replace toy-safety documentation.
Amazon lithium battery compliance FAQ
Does every battery inside a device have to ship at 30% charge?
Do not apply the packed-with-equipment rule to every configuration. The IATA 2026 guidance distinguishes PI 966 from PI 967. Identify the configuration, then check the current Amazon and carrier requirements for that shipment.
What happens if Amazon cannot confirm the charge requirement?
The cited Amazon announcement says the product will be fulfilled only by ground until further notice. A different safety or dangerous-goods notice can impose other restrictions, so read the notice for the affected product.
Is UN 38.3 the same as an SDS?
No. The transport test summary and a safety data sheet serve different purposes. Supply the records requested for the relevant model and classification process.
Does an old test date automatically make a summary invalid?
Do not infer validity from the date alone. Check the battery type, changes to its design, the applicable requirements, and any specific Amazon request. Ask the manufacturer or testing organization to assess whether the records remain applicable.
Can I mark batteries as not included to avoid a review?
The listing must describe the actual offer. If batteries are supplied, changing the answer to avoid review creates inaccurate product information. Resolve the classification or document issue instead.
What if the battery model differs from the product model?
That can be normal. Provide a supported mapping showing which cell or pack is used in the finished product, then ensure the relevant summary and specifications match that battery.
Need help with battery documents or a hazmat review? Send ASA the exact Amazon notice, affected ASINs, battery model, and the document mismatch you need to resolve.
Official references: Amazon’s 2026 air-shipping update; IATA 2026 guidance; Amazon dangerous-goods information and documents; Amazon lithium battery requirements (Seller Central sign-in may be required).