Japan's Civil Aviation Bureau is proposing to expand its dangerous-goods rules for sodium-ion batteries, adding new named categories and shipping numbers alongside the lithium-battery provisions already on the books. The draft amendments, opened for public comment on September 24, 2026, rewrite the 1983 notice on air transport of explosives and dangerous goods together with two implementing circulars.
The trigger is external. The ICAO Council approved a revised set of Technical Instructions in March 2026 that take effect January 1, 2027, and Japan's own rules have to align before then.
New entries for a battery chemistry
Under the draft, standalone sodium-ion batteries get their own UN shipping number, while battery packs mixing sodium-ion and lithium-ion cells generally ship under the numbers already used for lithium-ion batteries, 3480 or 3481. Vehicles powered by lithium or sodium-ion batteries, including vehicles using mixed battery packs, would ship under UN numbers 3556 through 3558. Sodium-ion batteries fitted into cargo transport units would ship under 3563 or 3564, depending on whether they are mixed with lithium-ion cells. New special provision A235, plus an expansion of the existing provision A901 to cover sodium-ion cells, would set packaging, labeling and quality-control conditions, and cap the watt-hour rating of mixed-chemistry packs shipped under a size exemption at 100 watt-hours.
| UN Number | Covers |
|---|---|
| 3556-3558 | Vehicles powered by lithium or sodium-ion batteries, including vehicles using combined lithium-ion and sodium-ion battery packs |
| 3563 / 3564 | Sodium-ion batteries installed in cargo transport units (3563 covers packs mixing lithium-ion and sodium-ion cells, 3564 covers sodium-ion only) |
| 3538 | Magnetic resonance imaging machines containing 12 kilograms or more of non-flammable, non-toxic gas |
Beyond batteries
The draft also creates a category for magnetic resonance imaging machines containing small volumes of non-flammable, non-toxic gas: units holding less than 12 kilograms of that gas would be exempt from the dangerous-goods ban entirely, while units at or above that threshold would ship as UN 3538 under new special provision A236. Liquid organic hydrogen carriers would get a dedicated handling provision, A238, capping dissolved hydrogen content at 0.5 litres per kilogram of carrier. Separately, the operating circular would add blood- and blood-product storage items to the list of medical-related items air carriers may bring aboard for in-flight use.
The companion circular on hazard testing addresses used medical devices sent for disinfection, cleaning, sterilisation, repair or evaluation: such devices would be excluded from the outright transport ban when they meet set conditions, but any lithium or sodium-ion batteries built into or packaged with them would still have to meet the separate rules that apply to those batteries. The same circular adds a flowchart for classifying small-sample energetic organic materials under UN numbers 3223 or 3224.
The clock
Comments are due by October 26, 2026. The bureau's Safety Policy Division plans to publish the final notice in early December 2026, with the amended rules applying from January 1, 2027.
| Milestone | Date |
|---|---|
| Public comment opens | September 24, 2026 |
| Public comment closes | October 26, 2026 |
| Final notice publication (planned) | Early December 2026 |
| Amended rules take effect | January 1, 2027 |
