To:  

International Civil Aviation Organization (ICAO)  
European Union Aviation Safety Agency (EASA)  
European Commission  
Federal Aviation Administration (FAA)  
Relevant national and supranational regulatory authorities

Petition for revision of battery energy limits and regulatory barriers affecting transport, consumer electronics and technological progress

Petition text

We, the undersigned citizens, consumers and members of the general public, request a formal and coordinated review of current regulatory frameworks governing rechargeable batteries, with particular reference to energy limits expressed in watt-hours per single cell and their downstream effects on transport, consumer electronics and technological development.

This petition calls for:

1) a formal evaluation and adoption of an increased maximum allowable energy content per single rechargeable cell, up to 400 watt-hours;  
2) a simplification and harmonization of rules governing the transport of battery-powered devices (both passenger carriage and cargo);  
3) a broader reassessment of how battery transport and safety regulations indirectly shape the design, availability and performance of consumer electronics in Europe and the United States.

Background and problem statement

Current international regulations — originating primarily from aviation safety frameworks — impose strict per-cell energy limits (100 Wh standard, 160 Wh with approval) that were defined decades ago, based on early lithium-ion technology and conservative risk assumptions.

While originally intended for aviation safety, these limits now exert systemic effects well beyond air transport, influencing:

• product design decisions by manufacturers;  
• battery capacity and energy density available to consumers;  
• competitiveness of Western electronics markets;  
• pace of technological and scientific progress.

Impact on consumers and market competition

Major manufacturers of smartphones, laptops and consumer electronics currently deploy lower-energy-density batteries in European and North American markets compared to functionally equivalent products sold in other regions, notably East Asia.

This divergence is not driven by technological incapacity, but by regulatory risk aversion and compliance strategies shaped by fragmented and restrictive transport and safety rules. The result is:

• reduced battery life and performance for Western consumers;  
• artificial product differentiation based on geography rather than technology;  
• structural disadvantage for European and U.S. markets;  
• slower adoption of advanced battery chemistries and architectures.

Technological and scientific implications

Rechargeable batteries are a foundational technology for modern society, underpinning not only consumer electronics but also medical devices, mobility aids, research instrumentation and emerging technologies.

Constraining energy density at the regulatory level — indirectly and often unintentionally — discourages innovation, limits economies of scale and delays the deployment of safer, more efficient battery designs that could reduce overall system risk by requiring fewer cells per device.

Modern batteries incorporate multiple safety layers, including mandatory UN 38.3 testing, integrated battery management systems, thermal protection and robust mechanical design. Safety risk can no longer be meaningfully assessed by watt-hours per cell alone.

Need for regulatory modernization

We do not request deregulation or reduced safety standards. We request regulatory modernization based on current scientific and engineering realities.

A revised framework that allows higher per-cell energy limits — up to 300 watt-hours (and up to 360 watt-hours with airline approval) under harmonized safety conditions — would:

• improve transparency and legal certainty for citizens and travellers;  
• reduce unnecessary barriers in transport and logistics;  
• eliminate indirect constraints on consumer electronics design;  
• strengthen technological sovereignty and competitiveness of Western economies.

Requested actions

We respectfully request that competent authorities:

1) initiate a coordinated review of per-cell energy limits across aviation, transport and product safety regulations;  
2) assess the downstream economic and technological effects of current battery restrictions on consumer markets;  
3) adopt harmonized, evidence-based thresholds reflecting modern battery safety performance;  
4) ensure that future regulations do not unintentionally penalize consumers or hinder scientific and technological progress.

Closing statement

Battery technology is no longer a marginal safety concern but a strategic infrastructure for modern civilization. Regulations that indirectly limit its development and deployment must be reassessed with a broader perspective that balances safety, innovation, consumer rights and global competitiveness.

We urge regulators to act accordingly.