The transport of lithium batteries presents complex operational and safety challenges for the global logistics and postal sectors.
More than a decade after the establishment of an international regulatory framework, one question remains: is regulatory compliance enough to ensure flight safety? The answer is increasingly no.
The ICAO-UPU framework established an essential regulatory foundation for the acceptance of lithium batteries within international postal flows carried by air. Yet today, the industry’s greatest challenge lies in the disconnect between regulatory intent and operational reality. The issue is no longer the lack of regulation, but the lack of operational visibility and alignment between postal operators and airlines.
A solid regulatory foundation for lithium batteries in postal air transport…
The need for a standardized approach became clear over a decade ago, leading to a landmark milestone in 2012: the establishment of a formal protocol between the International Civil Aviation Organization (ICAO) and the Universal Postal Union (UPU).
This agreement laid the regulatory foundation for the acceptance of lithium batteries within international postal flows carried by air, balancing the requirements of a fast-paced global economy with the non-negotiable imperative of flight and transit safety.
Central to this regulatory framework is professional accountability. Postal operators are required to be formally accredited by their national Civil Aviation Authority (CAA). This accreditation process depends on the submission and approval of a comprehensive safety plan dedicated to the management and handling of lithium battery shipments within the postal network.
Once this accreditation is secured, and provided that strict compliance with international standards regarding quantity limitations and specialized packaging is maintained, authorized postal operators are granted the operational default to dispatch lithium batteries through international mail channels. The list of accredited Designated Operators is available on the UPU website.
…but operational reality tells a different story
While this framework provides a structured approach, the reality of the supply chain reveals significant gaps. There is a lack of strict, standardized constraints on the quantity of lithium batteries included in a single postal shipment, and postal operators are not required to inform airlines of the precise location of lithium-containing items within the receptacles tendered to them, preventing airlines to correctly perform their risk mitigation procedures.
Adding to this complexity is the role of individual airline policy. Despite a postal operator holding valid accreditation, many carriers exercise their right to implement Operator Variations, published within the IATA Dangerous Goods Regulations (DGR) manual, explicitly stating that they refuse to carry any lithium batteries whatsoever.
The Compliance Paradox: A Structural Misalignment
The consequences of this regulatory evolution create a profound and dangerous irony. While the ICAO/UPU framework has elevated awareness of Dangerous Goods (DGR) within postal organizations, it has created an opaque environment for air carriers.
This creates a structural misalignment with the Framework for Postal Services Agreement (FPSA), the standardized mail transport contract promoted by the UPU and IATA. The FPSA implicitly assumes that once a postal operator is authorized to handle lithium batteries, the contracted carrier will transport them under agreed conditions.
In practice, however, many airlines sign the FPSA while simultaneously maintaining internal Dangerous Goods policies that override the contract’s expectations. The FPSA envisions a compliant, standardized framework, while carriers operate under safety policies that are often considerably stricter.
The result is a cycle of operational uncertainty and recurring disputes, as many postal operators ignore the specific restrictions imposed by airlines in the IATA DGR manual. A significant amount of mail consignments is affected by this mismatch between the FPSA and the IATA DGR manual.
This gap puts the entire postal industry at risk. A single major incident could force the industry to rely exclusively on cargo aircraft, effectively excluding mail from passenger fleets. For safety reasons, airlines adopt strict policies, yet they often continue to accept mail from CAA-accredited operators even when their internal safety guidelines formally prohibit it.
The visibility gap
The greatest weakness of the current system is not the regulatory framework itself, but the lack of visibility. Today, airlines have little or no information about the location of lithium-containing items (ELI) within the receptacles they transport. Yet postal operators already possess this information.
Two persistent misconceptions continue to slow progress
Misconception N°1: Postal receptacles cannot be opened
There is a widespread assumption (often adopted by airlines as a universal standard) that postal bags cannot be opened for verification purposes. This is not legally absolute. It is the secrecy of correspondence (the privacy of the message) that is universally protected, not the physical receptacle containing the message itself.
While some countries maintain a strict refusal to allow their bags to be opened, this is not a global standard. Many postal operators already accept that a bag may be opened for legitimate safety and security reasons.
Furthermore, this assumption is contradicted by common industry practice: many postal operators already transport parcels « à nu » (out of bags). If receptacles were truly legally inviolable, such transport would not be possible.
Carriers should not hesitate to request authorization from their postal customers to open bags whenever safety requires it. In practice, this pragmatic collaboration often resolves significant operational difficulties.
Misconception N°2: The data does not exist
Another common assumption is that airlines simply cannot know where lithium batteries are located. In reality, the information already exists.
Postal operators are obligated by the UPU Convention to generate ITMATT messages (sent to destination posts) for all items containing merchandise, which include the item’s identification. Furthermore, the item number (S10 code) is linked to the receptacle number (S9 code) within the postal export process.
Postal operators therefore already possess the data of:
- what they are transporting
- where those items are located.
By aligning with air cargo practices and using the appropriate, already-defined segments within the CARDIT message, postal operators could provide airlines with the transparency needed to strengthen flight safety.
In fact, the M48 standard, which defines CARDIT content, already includes a segment allowing a carrier to be notified of the presence of dangerous goods within a specific receptacle. To our knowledge, this information segment is currently not utilized by any postal operator.
The UPU has already made a massive effort to integrate the necessary data into CARDIT messages to ensure ICS2 compliance; why wouldn’t an equivalent effort be possible to strengthen flight safety and address the demand from carriers to know what they are transporting?
Alternative solutions already exist
If enriching CARDIT messages is not a possible path to follow, the industry can also turn toward alternative solutions: using the HS codes contained within ITMATT messages, it is entirely feasible to store the S10-S9-Presence-of-DGR data triplet in a cloud and allow airlines to access this information source via an API while scanning the mail receptacles.
In short, effective solutions can be implemented if the industry commits to them.
From regulatory compliance to operational transparency
The current state of lithium battery transport in postal air cargo remains a critical vulnerability, characterized by a persistent disconnect between regulatory intent and operational reality.
While the ICAO/UPU framework initiated a necessary dialogue on safety, the industry has reached a point where “assumed compliance” is no longer sufficient to guarantee the security of flight operations.
The path forward demands a transition from institutional inertia to active collaboration. Airlines must adopt a more pragmatic approach to receptacle verification, moving past the misconception of total inviolability to exercise their safety-driven right to inspect potential hazards. Simultaneously, the postal sector must bridge the data integration gap by treating safety-critical information (such as the identification and location of lithium-containing items) as an essential component of the transport process rather than secondary or proprietary data.
Conclusion
Whether through the full utilization of existing standards like the CARDIT M48 segment or the adoption of modern, API-driven cloud solutions, the technical infrastructure to solve these visibility issues already exists.
Achieving a secure supply chain is no longer a question of technical possibility, but of industry will. Without proactive, multilateral coordination to align these systems, the risk of a major incident remains, threatening the continued inclusion of postal cargo in passenger air networks.
While we wait for more sustainable solutions, Leg-2 can help you set up an alternative solution, so let’s discuss.
