Who Do You Tell When an Approved Air Cargo Tracker Changes?
Disclosure: this article summarises publicly available carrier and regulator documents as they read on 22 September 2026, with the version and date of each source named in the text. Carrier conditions change without notice and differ by operator and routing. Nothing here is an airworthiness determination, a dangerous goods declaration, or advice that any specific device may be carried on any specific flight. Confirm current requirements with each operator before shipping.
Here is a procurement question with no published answer.
Your tracker is on an airline’s approved device list. Your cell vendor issues an end-of-life notice. You qualify a replacement cell — same chemistry, same capacity, same housing, same model number on the label. Is the listing still good? And if it is not, who exactly do you tell?
We went looking for that answer in carrier documents. One carrier answers it in a single sentence. The others do not mention it at all.
Four permissions, and only two of them are yours to keep
The word ‘approved’ gets used for four different decisions that travel separately. Confusing them is how a programme ends up with a folder full of certificates and no answer to the question above.
The first is cell and battery transport testing. The IATA Guidance Document for Lithium Batteries and Sodium ion Batteries (2026 Edition, dated 1 January 2026, built on the 2025–2026 ICAO Technical Instructions and the 67th edition of the DGR) puts it plainly: ‘To be permitted in transport all lithium cell and battery types must have passed the applicable tests set out in Subsection 38.3 of the UN Manual of Tests and Criteria.’ That test summary names a specific cell from a specific manufacturer.
The second is how the device itself is treated as dangerous goods — whether it rides under the exception for loggers in use on a consignment, or is offered as a regulated shipment in its own right. Those are two different paragraphs with two different sets of conditions, and we walked through the 2026 IATA data logger exception and which dispatch line it covers separately.
The first of those you hold outright, and it stays true as long as the cell it names stays in the product. The second is not a document you hold at all. It is a classification that depends on how a particular consignment is packed and what the device is doing on it, which is why the same part number can sit inside the exception on one dispatch line and outside it on the next.
The third and fourth belong to someone else. The IATA Air Cargo Device Assessment validates a device against Recommended Practice 1693 for electromagnetic compatibility and battery safety, and IATA is explicit about its limit: ‘This assessment does not substitute airline approval for device use on board.‘ The airline’s own authorisation is the fourth, and both FAA and EASA put that decision squarely on the operator. FAA’s cargo hazards guidance says ‘An operator should assess the capabilities, characteristics, energy density, and hazards of these devices before introducing the carriage of these devices into their operations in accordance with their Safety Management System.’ EASA is blunter: ‘EASA does neither certify nor approve cargo tracking devices,’ and ‘Operators remain responsible to authorise the use of PEDs on board their aircraft.’
There is a fifth thing that is not a permission at all, and it catches people: the routing. Lufthansa Cargo’s current device overview states that ‘The devices are not approved for transportation on interline routings with other carriers.’ An approval from the carrier whose name is on the air waybill does not follow the freight onto the next carrier’s aircraft.
Four permissions, two owners
What “approved” means depends on which of these four decisions is being talked about.
01
Cell transport testing
UN 38.3, per the UN Manual of Tests and Criteria. Decided by a test laboratory. Binds to one named cell from one manufacturer.
02
Dangerous goods treatment
Exception for a logger in use, or a regulated consignment. Decided by the shipper against the DGR. Binds to how the device travels.
03
IATA device assessment
Validated against Recommended Practice 1693. Decided by IATA. Binds to electromagnetic compatibility and battery safety.
04
Onboard authorisation
Operator responsibility under its own safety management system. Decided by each airline separately. Binds to that airline’s aircraft.
What one carrier actually asks for after approval
The Lufthansa Cargo and Lufthansa Group airlines tracker document, version V.23, May 2026, is the most complete public statement we found, and it is worth reading for three sentences.
On transmission: ‘Data transmission must be suspended and disabled during flight in order to comply to air safety regulations.’ An earlier Lufthansa document, Rev. 07 dated 15 February 2024, which the current overview does not mark as superseded, is more specific for higher-power devices, asking for ‘Automated and prolonged radio suspension during flight using multiple modes of redundancy’ above 100 mW, and adding that ‘Deactivation has to be verified in aircraft environment.’
On how a device gets assessed: ‘As of January 2026, the evaluation will take place exclusively via the IATA ONE Source portal.’
And then the sentence this whole article is about: ‘Hard- and software changes on already approved devices have to be reported to local sales.’
Read that narrowly, because it will not bear weight it was not built for. It says reported. It names local sales as the recipient. It sets no deadline, no format, and no threshold — a firmware bump and a new cell chemistry are covered by the same one sentence. It does not say re-approval, re-assessment or revalidation. That sentence on its own settles the reporting question and nothing else: whether a change also triggers retesting comes from the battery documentation, the scope of the device assessment, and each carrier’s own approval conditions. What the same document does say is that ‘Concessions to use the listed devices are based upon current provisions and can be revoked at any time,’ which is the real exposure: the listing is a decision someone else made and can unmake.
Is silence from the other carriers a lighter rule?
We checked what other major cargo carriers publish. The pattern is not what most procurement teams assume.
| Carrier | Public document found (Sept 2026) | In-flight transmission rule published | Change-notification duty published |
|---|---|---|---|
| Lufthansa Cargo / Lufthansa Group | Tracker overview V.23, May 2026 | Yes, explicit | Yes — report to local sales |
| Emirates SkyCargo | Approved data loggers list, 15 Oct 2024 | No. List separates transmitting and non-transmitting devices, states no conditions | No |
| Air France KLM Martinair Cargo | Approved tracking devices list, file updated Feb 2026 | No. Refers to conditions on a linked page | No |
| IAG Cargo | Tracking devices page and FAQ | No explicit rule. States approval ‘can take up to 12 months’ | No |
| Delta Cargo | Approved devices list, Rev 4.0, 1 Mar 2023 | No. Requires the device be declared on the air waybill by manufacturer and model | No |
| Qatar Airways Cargo | Approved devices page would not render on two attempts | Not verifiable | Not verifiable |
So the technical principle is industry-wide — every regulator quoted above puts portable electronic devices under the operator’s control — while among the carrier documents we could reach this month, only one states a reporting duty that survives approval.
An approved-device list records a decision an airline already made about a specific device at a specific moment. None of the lists we read describes a periodic re-check, and only one of them says anything at all about what the device owner owes once the listing exists. Absence of a published change rule is not permission to change quietly; it is an open question you have to close in writing, carrier by carrier.
Which changes are worth a notification?
Not every engineering change touches an air-cargo decision, and treating them all the same is how change notices stop being read. Five categories are worth flagging, and the ordering matters less than the fact that somebody owns the call.
The cell or battery pack. The UN 38.3 test summary is issued against a named cell from a named manufacturer. A second-source cell is a different test summary, and the Watt-hour and lithium-content conditions in the DGR exception are stated per cell and per battery. This is the clearest yes.
Anything that changes radio behaviour. Transmit power, antenna, the logic that decides the device is airborne, the suppression path itself. Lufthansa’s 100 mW threshold and its ‘multiple modes of redundancy’ language exist because this is the part an operator cares about.
Firmware, even with no hardware change. A build that alters flight-state detection, sampling during radio-off, buffer behaviour or reconnect ordering has changed the device an assessor looked at, while the enclosure and the model number stay identical. This is the change most likely to ship unannounced.
Antenna or enclosure revisions that keep the model name. If the name on the label is the key your customer and their forwarder use to find the device on a list, then a revision that is invisible in that key is a revision nobody downstream can see.
A second production line. Here we have to be honest: none of the carrier documents we read mention which factory built a unit, and we are not going to pretend otherwise. What a second line can change is whether the units in the box still match the sample that was assessed — the programmed firmware image, the antenna assembly step, the RF test limits, the cell lot. That is a question about how a configuration is reproduced across sites, not about paperwork.
What belongs in the supply agreement, not the datasheet
A datasheet describes a device. An air-cargo programme needs the thing a datasheet cannot give you, which is a named, frozen configuration and a rule for what happens when it moves. If you are sourcing a multi-sensor cold chain cargo tracker that will fly, four clauses do more work than any amount of certificate collecting.
Define the approved baseline as a document, not a model number: BOM revision, cell manufacturer and part number, PCB and antenna revision, firmware version and build hash, and the test limits the line is screening to. Write down which supplier-side change classes trigger a notice to you, and how much lead time you get. Say who files with ONE Source and who contacts each carrier’s local sales, because ‘reported to local sales’ has no owner unless you give it one. And keep a retest scope matrix: for each change class, what gets retested, and whether a new UN 38.3 summary is needed.
We cannot give you a standard lead time to copy, because the one carrier that asks for notification does not state one. Thirty days before a change reaches production is a defensible starting position, and you should expect to negotiate it.
Frequently Asked Questions
Does passing the IATA Air Cargo Device Assessment mean airlines will accept my tracker?
No. IATA states that the assessment “does not substitute airline approval for device use on board.” It validates the device against Recommended Practice 1693 for electromagnetic compatibility and battery safety. Each operator still makes its own decision about carriage on its aircraft, and FAA and EASA both place that responsibility on the operator.
If I change the battery cell, do I need a new UN 38.3 test summary?
A UN 38.3 test summary is issued for a specific cell or battery design from a specific manufacturer, so a different cell is covered by a different summary. The IATA 2026 guidance requires that all lithium cell and battery types in transport have passed the Subsection 38.3 tests. Whether your existing summary still applies is a question for the cell manufacturer and your dangerous goods adviser, not one to answer from the model number.
Do all airlines require tracking devices to stop transmitting in flight?
Not in published form. Lufthansa Cargo states it explicitly in its V.23 document of May 2026. Among the other major cargo carriers whose documents we could reach in September 2026, most publish an approved-device list without stating transmission conditions. The underlying principle is consistent — regulators place portable electronic device authorisation with the operator — but the published wording is not.
Is an approval from one airline valid on a connecting carrier?
Not automatically, and at least one carrier says so directly. Lufthansa Cargo’s V.23 document states that its listed devices “are not approved for transportation on interline routings with other carriers.” Multi-carrier routings need to be checked per operator on the actual routing.
Who should be told when an approved air cargo tracker changes?
Lufthansa Cargo requires that “Hard- and software changes on already approved devices have to be reported to local sales,” with no stated deadline. No equivalent published requirement was found at the other carriers checked. In practice that means the obligation has to be written into your supplier agreement and your own carrier communications, because you cannot rely on a published rule to tell you when to speak up.
Key Takeaways
Four permissions, not one. Cell transport testing, dangerous goods treatment, the IATA device assessment and the operator’s own authorisation are separate decisions. Only the first two are documents you hold and control.
The listing can be withdrawn. Lufthansa Cargo describes its device concessions as ‘based upon current provisions’ and revocable at any time. An approval is a standing decision by someone else, not an asset on your balance sheet.
One carrier, in the documents we could reach, states a duty that survives approval. ‘Hard- and software changes on already approved devices have to be reported to local sales’ — reported, no deadline, no threshold. Do not inflate it, and do not assume the carriers that say nothing want nothing.
Firmware is the invisible change. A build that alters flight-state detection or radio suppression changes the assessed device while the label stays identical.
Freeze the configuration in the contract. BOM revision, cell part number, antenna revision, firmware hash and test limits, plus a change-notice clause with a lead time and a named owner for carrier notification.
Which brings the question back to you. If your cell vendor sent an end-of-life notice tomorrow, who on your side would know which carriers to tell — and could they name, from a document rather than from memory, the configuration that was approved in the first place?
