The rules behind the rules
Every airline policy sits on two separate bodies of law: dangerous-goods rules, which decide whether your battery may fly, and disability-rights rules, which decide what the airline owes you. Knowing both is how you win an argument at the check-in desk.
These are the defaults, not a substitute for the airline’s own page. An airline may be stricter than the international baseline, and many are. wheelair never fills a missing airline figure with the number below — if a carrier does not publish a watt-hour cap, its record says “not published”, and you use this page to understand what will probably apply.
1. Can my battery fly? (dangerous goods)
Every country’s aviation authority builds its dangerous-goods law on the ICAO Technical Instructions for the Safe Transport of Dangerous Goods by Air (Doc 9284). Airlines work from the operational edition of the same rules, the IATA Dangerous Goods Regulations. The provisions that govern a wheelchair are ICAO Part 8, Chapter 1, Table 8-1, item 4 (“Mobility aids”) and IATA DGR 2.3.2, summarised in IATA Table 2.3.A (opens in a new tab). Both documents are expensive. The United States writes the same rules into 49 CFR 175.10(a)(15)–(17) (opens in a new tab), which is free and says nearly the same thing. Print that if you want the text in your hand.
Three things are true for every battery chemistry:
- The operator must approve it. ICAO Table 8-1 marks the whole mobility-aid entry — spillable, non-spillable, dry, nickel-metal hydride and lithium-ion alike — “approval of the operator is required”, and item 4(b) tells you to make advance arrangements and give the airline the battery type and instructions for isolating it. It is not the airline being difficult; it is the rule. The 48 hours everyone quotes is not from here — that number comes from passenger-rights law (EU 1107/2006 Art. 7(1), Canada’s ATPDR s. 32). The dangerous-goods rule says only “advance arrangements”, which is why some carriers want seven days.
- The captain must be told. The pilot-in-command is informed of the type and location of the battery on board — ICAO TI Part 7, Chapter 2, 2.13; in the US, 49 CFR 175.10(a)(16)(iii) for spillable and (a)(17)(vi) for lithium-ion.
- The chair must be immobilised. Battery securely attached, terminals protected against short circuit, electrical circuits isolated — key out, isolator switch off, terminals taped, or an airsafe connector unplugged. Under the US rule the battery must be disconnected unless the chair’s own design prevents unintentional activation (49 CFR 175.10(a)(15)(iv)).
Non-spillable batteries — gel, AGM, sealed lead-acid, dry cell, NiMH
The easy case. The battery stays attached to the chair, the terminals are protected against short
circuit (enclosing the battery in a battery container counts), the circuits are isolated, and the chair
travels in the hold. Where the battery has to come out it goes in strong rigid packaging, which the US rule
requires to be marked NONSPILLABLE BATTERY (49 CFR 175.10(a)(15)(v)(B)). A non-spillable
battery in a mobility aid has to meet Special Provision A67.
Exactly one spare is allowed, per passenger, and it travels in the hold, not the cabin — ICAO Table 8-1 item 4(d)(ii) and 49 CFR 175.10(a)(15)(vii). Do not confuse this with the separate, much smaller allowance for non-spillable batteries in portable electronic devices (12 V and 100 Wh maximum, two spares, cabin only). Different entry, different numbers — and it is the one ground staff reach for by mistake.
Spillable (wet) batteries
The hard case, and the one airlines most often refuse outright. If the chair can be loaded, stowed,
secured and unloaded always in an upright position, the battery may stay attached. If it cannot,
the battery must be removed and carried in a strong rigid outer packaging that is leak-tight and impervious
to battery fluid, with the battery secured upright inside it and surrounded by enough compatible
absorbent material to soak up the entire electrolyte. That packaging is marked
BATTERY, WET, WITH WHEELCHAIR or BATTERY, WET, WITH MOBILITY AID, carries a
Corrosive (Class 8) label and package orientation arrows, and must be secured against upset in the
hold rather than braced with other baggage — 49 CFR 175.10(a)(16)(iv). No spare spillable battery
is permitted at all. Many airlines simply say no rather than handle any of this.
Lithium-ion batteries
This is where the numbers everyone quotes come from, and where most confusion lives. The split is not the one most people assume. The rule does not ask whether the battery is designed to be removed. It asks: does the mobility aid provide adequate protection to the battery? ICAO, IATA and 49 CFR 175.10(a)(17)(v) all use that phrase. A chair whose frame and housing protect the battery keeps it installed even where the battery is removable; a chair that leaves the battery exposed has to give it up even if the manufacturer never meant it to come out. Lithium metal (non-rechargeable) batteries are forbidden in these devices outright.
| Situation | What the international baseline says |
|---|---|
| The aid protects the battery — it stays installed (most rigid power chairs) | The battery travels in the hold with the chair: securely attached, terminals protected, circuits isolated. The baseline sets no watt-hour ceiling, and since the 2025–2026 edition the ICAO Technical Instructions say so in terms, in a note to Table 8-1: “When the lithium battery(ies) remain installed in the mobility aid, there is no Watt-hour limit.” 49 CFR 175.10(a)(17)(i)–(iv) states no figure either. That is why British Airways, Qatar Airways, Cathay Pacific and Aer Lingus all publish “no limit”. Airlines may still impose their own: the Lufthansa Group — Lufthansa, SWISS and Austrian — caps an installed battery at two batteries of 160 Wh each, from 1 October 2025. |
| The aid does not protect the battery — it comes out (most folding/travel chairs) | The battery is removed following the manufacturer’s instructions, terminals insulated, each battery protected from damage (a protective pouch is the standard example), and carried in the cabin. ICAO Table 8-1 item 4(e)(ii) and 49 CFR 175.10(a)(17)(v)(D) both set a flat 300 Wh ceiling and no alternative to it. IATA’s own guidance — and most airlines that publish a figure, British Airways and Cathay among them — add that a chair fitted with two batteries it needs to run may carry 160 Wh each. That variant is not in the ICAO table, so treat it as the airline’s rule rather than the baseline. |
| Spare batteries | One spare of up to 300 Wh, or two spares of up to 160 Wh each, in the cabin, terminals insulated, each protected from damage — ICAO Table 8-1 item 4(e)(iii) and 49 CFR 175.10(a)(17)(v)(E). This is the sentence airlines paraphrase in a dozen different ways, and it is the only place the 160 Wh figure appears in the ICAO text. |
The “no limit” is under pressure. IATA’s 2026 mobility-aid guidance already tells operators to consider extra mitigation above 300 Wh installed — fire-resistant containers or covers, or carriage at 25% charge or less — and a proposal before ICAO’s dangerous goods panel would cap installed batteries at 300 Wh and delete the note for the 2027–2028 edition. That proposal is not law. But if your chair carries more than 300 Wh installed, expect the question, and expect the answer to move.
Watt-hours, not amp-hours. If your battery is labelled in amp-hours, multiply by the voltage: 24 V × 28 Ah = 672 Wh. Ground staff are trained to look for a Wh figure printed on the battery. A battery with no legible rating is the single most common reason a chair is refused, and several airlines say so outright.
The SSR codes airlines use for you
These four-letter codes are what actually travels in the booking, and they come from IATA Passenger
Services Conference Resolution 700. Quote them and you will be understood faster than any description.
Note the split: WCHR, WCHS and WCHC describe the help you
need; the rest describe the chair you are bringing. You need one from each group.
| Code | Means |
|---|---|
WCHR | R for ramp. You can manage steps and make your own way to and from your cabin seat, but need a wheelchair for the distance to and from the aircraft. |
WCHS | S for steps. You cannot manage steps but can make your own way to and from your cabin seat; you need a wheelchair to the aircraft and to be carried up and down steps. |
WCHC | C for cabin seat. Completely immobile: a wheelchair to the aircraft, carried up and down steps, and carried to and from the cabin seat. |
WCOB | You need the airline’s on-board (aisle) wheelchair. Used alongside one of the three above, not instead of one. |
WCMP | You are bringing a manual chair. IATA recommends this code be kept for manual chairs without a power-assist device — if yours has a power add-on, the battery code below is the one that matters. |
WCBD | Your chair has a non-spillable, nickel-metal hydride or dry battery. (The old definition was “dry cell” alone; IATA has broadened it.) |
WCBW | Your chair has a wet-cell (spillable) battery. |
WCLB | Your chair has a lithium-ion battery. |
Resolution 700 excludes Canada and the United States by its own terms, because domestic accessibility law governs there instead. The codes are still used on those bookings; the obligations behind them are not the resolution’s.
2. What does the airline owe me? (passenger rights)
Which law applies depends on where you fly from and to, and sometimes on the airline’s nationality. More than one can apply to a single journey.
United States — Air Carrier Access Act, 14 CFR Part 382
- A carrier must not charge for anything Part 382 (opens in a new tab) requires of it (§ 382.31(a)), and assistive devices must not count toward a carry-on baggage limit (§ 382.121(b)). Part 382 never uses the word “allowance” about checked bags: what a checked mobility aid gets instead is priority for stowage over all other cargo and baggage (§ 382.125(b)).
- On aircraft with 100 or more seats there must be priority space in the cabin for at least one adult-sized folding, collapsible or break-down manual wheelchair measuring 13 × 36 × 42 inches or less (§ 382.67(a)). What secures it is preboarding, not early check-in: take the preboarding you are offered and your chair displaces whatever is already in that space, crew luggage included (§ 382.123(a)(1)). Skip preboarding and you join the first-come, first-served queue (§ 382.123(a)(3)). The one-hour early check-in rule is a different rule, for battery-powered devices (§ 382.127(b)).
- Your chair must be returned as close as possible to the aircraft door unless you ask for it at baggage claim, and it must be among the first items retrieved from the hold (§ 382.125(c)–(d)).
- Carriers operating aircraft with 19 or more seats must have a Complaints Resolution Official available at each airport they serve, during all times they are operating there, in person or by telephone at no cost to you (§ 382.151(a)–(b)). The CRO can dispose of the complaint on the spot and can overrule any other employee except a captain making a safety decision (§ 382.151(e)). Asking for the CRO by name changes a conversation instantly.
- On flights to which the domestic baggage rule, 14 CFR Part 254, applies, liability for a lost, damaged or destroyed wheelchair is the original purchase price of the device, and the Part 254 cap does not apply (§ 382.131). On an international flight the Montreal Convention limits apply instead (§ 382.130(f)).
The 2024 wheelchair rule, and what is actually being enforced. DOT’s final rule Ensuring Safe Accommodations for Air Travelers With Disabilities Using Wheelchairs (opens in a new tab) (89 FR 102398, 17 December 2024) took effect on 16 January 2025 and is in the CFR now. It added: a rebuttable presumption that a checked chair not returned in the condition it was received was mishandled in violation of the ACAA (§ 382.130(a)); a duty to get a delayed chair to your final destination within 24 hours, or 30 hours on long international flights (§ 382.130(c)(1)); an airline-paid loaner chair that meets your actual mobility and safety needs (§ 382.130(e)); your right to choose your own repair vendor at the airline’s expense (§ 382.130(d)(2)); notification before the cabin door closes telling you whether your chair was loaded, and the right to get off and be rebooked at no cost if it was not (§ 382.125(f)); reimbursement of a fare difference where your chair would not fit on your preferred flight (§ 382.132); and hands-on staff training (§ 382.141).
None of it has been stayed, vacated or repealed. The airlines’ challenge (Airlines for America v. DOT, 5th Cir. No. 25-60071) has sat in abeyance since June 2025 with no ruling on the merits. What changed is enforcement posture: DOT has said it will not enforce four provisions — § 382.125(e), § 382.130(a), § 382.132 and § 382.141(a)(6) — until 31 December 2026 while it reconsiders them (90 FR 46751, 30 September 2025 (opens in a new tab)). They remain binding regulations; the regulator is simply standing back from them. The 24/30-hour return, the loaner chair, the vendor choice, the cabin-door notification and § 382.131 are not among the four, and are fully enforceable today.
European Union & United Kingdom — Regulation (EC) No 1107/2006
- An air carrier, its agent or a tour operator may not refuse a reservation or refuse to board you on grounds of disability or reduced mobility (Art. 3 (opens in a new tab)), except to meet safety requirements set in law or by the authority that issued the carrier’s air operator’s certificate, or where the size of the aircraft or its doors makes carriage physically impossible (Art. 4(1)). It must give you the reasons immediately, and in writing within five working days if you ask (Art. 4(4)) — the clock runs from your request, so ask in writing and date it. It must also publish its safety rules and size restrictions (Art. 4(3)).
- Assistance at the airport is free, and it is the airport’s job rather than the airline’s, funded by a charge the airport levies on carriers (Art. 8(1) and 8(3)), provided you notify at least 48 hours before the published departure time (Art. 7(1)). Miss the 48 hours and you do not lose the right — the airport must then make “all reasonable efforts” (Art. 7(3)).
- Two pieces of mobility equipment, electric wheelchairs included, carried without additional charge: Art. 10 read with Annex II, subject to the same 48 hours’ warning, to space on board, and to dangerous-goods law.
- Complain to the airport managing body or the airline first (Art. 15(1)); if that gets you nowhere, to the National Enforcement Body designated under Art. 14 in the country where it happened.
- Art. 12 says lost or damaged mobility equipment is compensated “in accordance with rules of international, Community and national law” — it fixes no figure of its own. The Commission’s interpretative guidelines (Notice C/2024/5992) read that as the Montreal Convention cap, and tell carriers they should offer you the special declaration of interest, ideally free of charge.
- In the UK the regulation still applies, as assimilated law, amended for Brexit by SI 2019/278 reg. 9 (opens in a new tab), which substituted Art. 14 and omitted Art. 16, the penalties article. The CAA (opens in a new tab) is the designated enforcement body (SI 2014/2833 reg. 4(1)), but it cannot fine an airline directly — it acts through enforcement orders and undertakings. A government bill to give it fining powers was still going through Parliament in mid-2026.
The EU has not revised 1107/2006. The Commission’s 2023 proposal on enforcement of passenger rights (COM(2023) 753) was still awaiting Parliament’s first-reading position in July 2026, so anything you read about new EU rights for disabled air passengers is not law yet.
Canada — Accessible Transportation for Persons with Disabilities Regulations (SOR/2019-244)
- A carrier must accept your mobility aid as priority baggage (s. 40(1) (opens in a new tab)) and may not charge for it, or for any other service Part 2 requires of it (s. 31(1)).
- Ask at least 48 hours ahead and the carrier must provide the service (s. 32(1)). Ask later and it must still make “every reasonable effort” (s. 32(4)) — short notice is not by itself a ground to refuse. The trap is 96 hours: request inside that window and the guarantee can fall away if the carrier needs documents to assess it (s. 32(3)).
- If your aid is damaged, destroyed, lost, or simply not there when you arrive, the carrier must, without delay and at its own expense, give you a suitable temporary replacement, reimburse the expenses you incurred, and arrange the repair — or, if the aid cannot be adequately repaired or is not returned within 96 hours on an air service, replace it or refund the full replacement cost (s. 61). Unlike the US rule, the carrier picks the repairer, not you. On international flights it must also tell you about the Montreal special declaration of interest (s. 62).
- These rules bind large air carriers — one million or more passengers worldwide in each of the two preceding calendar years (s. 25(2)). Smaller domestic carriers flying 30-seat and larger aircraft fall under the older Air Transportation Regulations (SOR/88-58) Part VII, whose s. 148(1) does spell out that aids travel free and in addition to the free baggage allowance.
- The three-year Accessibility Plan — often the most detailed document an airline produces, and the source of several records in wheelair — is not an ATPDR requirement. It comes from the Accessible Canada Act s. 60(2) and, for transport, the Accessible Transportation Planning and Reporting Regulations (SOR/2021-243) s. 3(3) (opens in a new tab), with progress reports in the intervening years.
Elsewhere
- Brazil — ANAC Resolution No. 280 of 11 July 2013, as amended by Resolution No. 608/2021. Art. 23 carries your mobility aid free but caps it at one piece, half the EU allowance. Art. 9 §1 sets 72 hours’ notice where a companion or medical documents are needed and 48 hours otherwise. Art. 25 makes a checked aid a fragile, priority item, deems it lost after 48 hours and requires indemnity within 14 days. ANAC opened a public consultation in 2025 on replacing the resolution outright; nothing had replaced it by mid-2026.
- India — DGCA Civil Aviation Requirement, Section 3 (Air Transport), Series ‘M’, Part I, Carriage by Air — Persons with Disability (Divyangjan) and/or Persons with Reduced Mobility, Issue III of 28 February 2014, Revision 8 of 29 October 2025. 48 hours’ notice (para 4.1.6); assistive devices carried free and additional to the baggage allowance (para 4.1.8); your own battery-powered chair permitted subject to the IATA DGR and the ICAO Technical Instructions (para 4.1.9); and no refusal on disability grounds without an in-person medical examination and written reasons (para 4.1.35). It states no watt-hour figures of its own.
- Australia — the Disability Discrimination Act 1992 and the Disability Standards for Accessible Public Transport 2002 (opens in a new tab), made under s. 31 of that Act. The standards do reach aircraft, but patchily: many Parts leave aircraft out of their application tables, and “small aircraft” of fewer than 30 seats are exempt from a long list of requirements. Section 30.1 does make disability aids additional to the baggage allowance. The standards are still at their 1 May 2011 compilation; a modernising amendment went out as an exposure draft in October 2025 and had not been made by mid-2026. A Disability Access Facilitation Plan is a voluntary publication the government encourages, not a legal requirement — worth reading, not worth citing as an obligation.
Damage to your chair: the Montreal Convention
On international journeys, carrier liability for checked baggage — a wheelchair included — is capped by Article 22(2) of the Montreal Convention 1999. Domestic US flights escape the cap because 14 CFR 382.131 substitutes the original purchase price; international flights out of the US do not (14 CFR 382.130(f)). The cap is set in IMF Special Drawing Rights and reviewed by ICAO as depositary every five years under Article 24, rising only where accumulated inflation has passed 10%. It went from 1,000 SDR originally to 1,131 SDR in 2009, 1,288 SDR on 28 December 2019 and 1,519 SDR on 28 December 2024 (opens in a new tab) — roughly US$2,000. For most power chairs that is far below replacement cost.
Three things, and the seven-day clock is the one people miss. Make a special declaration of interest: Article 22(2) requires it to be made at the moment you hand the chair over, not afterwards, and a supplementary fee may apply. Photograph the chair from every angle at the gate with the date visible, and again the moment you get it back — damage claims are won with photographs and lost without them. Then complain in writing within seven days of receiving the chair. That deadline is Article 31(2) and (3) of the treaty, not an airline invention, and Article 31(4) says that if you miss it no action lies against the carrier at all, short of proving fraud. Delay, as opposed to damage, gives you 21 days.
Every instrument on this page was read against its primary source in July 2026: the ICAO Technical Instructions Part 8 and IATA DGR Table 2.3.A, 49 CFR 175.10 and 14 CFR Part 382 on eCFR, Regulation (EC) No 1107/2006 on EUR-Lex, SOR/2019-244 on Justice Laws Canada, and ICAO’s 2024 revision of the Montreal Convention limits. Law moves. If you are reading this much later, follow the links.