IATA 2026 Guidance Explained
Nickel-metal hydride (NiMH) batteries are widely used across consumer electronics, industrial devices, tracking equipment and mobility aids. While they are far less high-profile than lithium batteries, confusion around their regulatory status still causes delays, unnecessary declarations and avoidable shipment holds.
To address this, IATA has issued updated guidance for UN 3496, Batteries, nickel-metal hydride, aligned with the 2026 IATA Dangerous Goods Regulations (67th Edition). You can download the full document here.
The key message is reassuringly simple: NiMH batteries can be shipped by air as “Not Restricted” — provided Special Provision A199 is fully met.
This article explains what that means in practice.
Historically, nickel-metal hydride batteries were treated in air transport much like “dry batteries”. They were effectively unregulated, as long as basic safety measures were applied.
Although UN 3496 has existed in the UN Model Regulations for some time, it was originally regulated only for maritime transport. It was later added to the ICAO Technical Instructions and the IATA DGR to ensure alignment with the UN system — not to introduce new restrictions.
To avoid unnecessary regulatory burden, Special Provision A199 was added alongside UN 3496, confirming that no additional dangerous goods requirements apply when basic safety controls are in place.
No — when prepared correctly.
Nickel-metal hydride batteries, and equipment or vehicles powered by them, are considered “Not Restricted” for air transport provided Special Provision A199 is met.
This applies whether the batteries are:
shipped by themselves,
installed in equipment, or
powering devices or vehicles.
The critical point is that UN 3496 is not used as a shipping UN number in air transport. Including it on documentation as if it were fully regulated is a common error.
Special Provision A199 sets out two simple safety conditions:
Prevent short circuits
This can be achieved by:
insulating exposed battery terminals, or
disconnecting the battery from equipment and protecting exposed connectors.
Prevent unintentional activation
Equipment must be prepared so it cannot power on during transport.
That’s it.
No dangerous goods declaration.
No Class 9 labels.
No UN specification packaging.
The guidance also clarifies a common operational scenario.
Devices such as:
RFID tags
watches
temperature or data loggers
may be transported while intentionally active, provided they:
are not capable of generating a dangerous evolution of heat, and
meet electromagnetic compatibility standards, ensuring they do not interfere with aircraft systems.
They must also not emit disruptive signals during transport (for example alarms or strobe lights).
Even though NiMH batteries are Not Restricted, documentation still matters.
When an air waybill is used, the description must include:
the words “Not Restricted”, and
a reference to Special Provision A199.
Importantly:
Do not use “UN 3496” on the air waybill for air transport.
UN 3496 is not a UN number applied in aviation shipments.
Correct wording avoids confusion at acceptance and prevents unnecessary escalation.
Nickel-metal hydride batteries are one of the simplest battery types to ship by air — when handled correctly.
Most issues arise not from risk, but from:
incorrect UN number usage,
over-declaration,
or misunderstanding the scope of A199.
Ensuring teams understand this distinction can significantly reduce delays and rework.
To support your internal review and operational planning, we have created a practical one-page compliance checklist summarising the key requirements introduced in the 2026 IATA update. This resource is designed for use by shippers, freight forwarders and compliance teams as a quick-reference tool alongside the Regulations.
You can download the PDF checklist here. We recommend sharing it with relevant personnel and incorporating it into your 2026 readiness review.
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