Airline Luggage and Airtags

I do not know if it is of real help here, but IMHO this whole article is doing a decent job to point out what has been going on:

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The linked FAA document is useful there. Basically, it’s saying that Bluetooth devices do emit a signal - but that anything under 100mW isn’t a problem. And that’s the category that AirTags fall into. There’s literally a section in there that’s pretty much about the product category that AirTags are in:

CARGO-TRACKING DEVICES, DATA LOGGERS, RADIO FREQUENCY
IDENTIFICATION (RFID), AND ELECTRONIC BAG TAGS. This paragraph
applies to PEDs designed for use on aircraft in locations inaccessible to the flightcrew
during flight. Because this class of PEDs cannot be turned off manually in the event of an
emergency, the aircraft operators must ensure certain design and operational
considerations are addressed.

The device may use low-powered wireless communications during flight without the
need to comply with paragraph 10.3.1. RTCA DO-363 states: “[e]xperience shows that
low-power emission levels do not affect aircraft systems. The low-power limit is 100mW
EIRP (effective isotropic radiated power). Wireless communication standards which are
limited to this level do not need to be analyzed for backdoor coupling. This includes
Bluetooth (IEEE 802.15.1) and ZigBee (IEEE 802.15.4).

In other words, the FAA says that devices designed in compliance with a standard that specifies less than 100 mW (like AirTags) are fine.

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I think it was intended to be that the battery in combination with being unable to be turned off that was the (an) issue.

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https://www.faa.gov/newsroom/lithium-batteries-baggage

Note the first sentence:

Lithium batteries, which power everyday devices, can catch fire if damaged or if battery terminals are short-circuited.

and

If these devices are packed in checked baggage, they should be turned completely off, protected from accidental activation and packed so they are protected from damage.

The concern seems to be something weird happening and the battery catching on fire. Again, near the end:

Damaged, defective or recalled lithium batteries must not be carried in carry-on or checked baggage if they are likely to be a safety concern by overheating or catching on fire.

I would imagine that even if you directly shorted out the tiny battery in an AirTag, the risk would be relatively low.

A pretty nice article, that stated, that the devices are prohibited.
Unless the last part, where the LBA was mentioned.
The Article is unfortunately missing, that the LBA is, due to European Regulations, not responsible for this kind of legislation. The EASA is!
And at the EASA, we worked out a pretty easy regulation, that became part of the EU-Regulation someone back in 2013/14 already. It says pretty much, that it is the whole responsibility of the Airlines, if they want to operate PED, to proof to the Authority that it is under a sufficient safe level.
LH spent a lot of money to proof that for their FlyNet with Test over a couple of month, at least 2 involved Universities and 2 Companies who developed the equipment.
And, while the use of this system was approved, as it is increasing the safety a lot, as the power of the Cellphones (illegally been operated on board) would be decreased from the maximum they were working in the past, towards an absolute minimum, there is still the legal requirement to switch off all PED during an Automatic Approach and/or Landing, because it was clearly proven, that the radiation was still to high, to allow them to still work in that phases of a flight.
This testing was not done, when LH developed its own SmartTag (therefore it has no location function) and it would not be done for the product of a third party like Apple.
If Apple want that proof for their products, they could do the test, and certifiy them, to get the approval, but LH is for certain not doing this.

Not to mention, even if one SmartTag might be no problem for the safe conduct of the flight, there are normally a couple of hundred bag loaded into an aircraft, which would result into a completely different scenario, if most of them would have been equipped with a working AirTag.

I really should not go down this rabbit hole because it leads to nowhere, but the EASA actually has chimed in, too. (I think that basically everybody has chimed in to this point…)

I am too tired too look for English sources, but one of many reports of today:

Das Bundesamt fßr Zivilluftfahrt wiederum verwies auf blue News-Anfrage auf die Eigenverantwortung der Airlines, die ihnen die Europäische Agentur fßr Flugsicherheit (EASA) zugestehe. Und eben jene EASA bestätigte, dass ihre Regularien in der Tat Gepäck-Tracker weder verbieten noch erlauben, sondern stattdessen die Fluggesellschaften selbst bestimmen dßrfen, ob ihre Verwendung sicher sei.

Source: https://www.bluewin.ch/de/digital/lufthansa-macht-kehrwende-bei-airtags-im-gepaeck-1417736.html

Translation:

In response to a blue News request, the Federal Office for Civil Aviation referred to the personal responsibility of the airlines, which the European Aviation Safety Agency (EASA) concedes to them. And the same EASA confirmed that their regulations in fact neither prohibit nor allow baggage trackers, but instead allow the airlines themselves to determine whether their use is safe.

The EASA pointed to their FAQ regarding Personal Electronic Devices:

As far as I am concerned, this “story” ended when Lufthansa released their statement that they decided after consultation with the Luftfahrtbundesamt that AirTags do not pose a safety risk and therefore are allowed on Lufthansa flights.

This is not about certification of a product for airplanes, this is about the question if a passenger is allowed to take a particular personal electronic device on an airplane. As we now know: yes, the passenger is allowed to take tracking devices with low battery and transmission power in checked luggage. And that’s it. And … I am out (already way too much time wasted on this one). :wink:

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ICAO didn’t permit lithium battery powered equipment stay on in the checked baggage according to their TI about dangerous goods rule.
This is true.
Each domestic rule may be different.

BUT
ICAO ANC will approve small lithium battery powered equipment with power on soon.

It was agreed at DGP working group 2022 last November, and proposal was send to ANC.
ICAO ANC discussed it on 2023-03-27 meeting. This item was included in the meeting agenda.

If ANC approve DGP’s proposal, PED w/ <0.3g Li metal, or <2.7Wh Li-ion is exempt from requirement completely switch-off for checked baggage.

My concern is about RF radiation problem. DGP said that RF radiation is out of DGP scope. It means RF matter is not dangerous goods matter, then DGP don’t take responsibility about it.
According to Cargo rule, such devices must meet defined standards for electromagnetic radiation to ensure that operation of the device does not interfere with aircraft systems.
From example of data-logger, the standard is ”RTCA DO160 Section21". EMC regulation like FCC don’t cover this standard.
I think that Air-Tag satisfy the criteria of RF radiation limit. Bou, how do AirTag show the conformation to the standard? I don’t know. I can find any DIRECT evidence from Air-Tag’s specification sheet.
I want Apple to supply conformity statement, evidence or certification document…

You could always email Apple’s PR department and see if that sort of thing exists.

Practically speaking, they’re so ubiquitous that airlines will most certainly make their decisions and have regulations (or not) regarding them.

Thank you for your advice.
I’ve already questioned it.
“NOW”, they don’t have such evidence.
As a matter of fact, it will not be required for checked BAGGAGE. Because ICAO/IATA dangerous goods rule don’t request it for checked baggage.

But when I place AirTag into the CARGO like FedEx, and if I honesty declare it, they have to request some evidence, for compliance with ICAO/IATA rule.

Freight does not cause a ShitStorm within the “Social Media”… :thinking::face_vomiting: :exploding_head: