Firstly, addressing the question of whether it is permissible for the shipper to build a ULD (pallet or container) housing a package of lithium ion batteries prepared in accordance with Section II of PI 965, the answer is “YES”. At the beginning of Section II of PI 965 through PI 970, it states that cells and batteries meeting the requirements of this section are not subject to other additional requirements og this regulation except for (a) dangerous goods in passenger/crew baggage, (b) dangerous goods in airmail and (c) reporting of dangerous goods accidents/incidents. Consequently, stipulations of shipper-built ULDs in DGR 9.1.4 do not apply, and airlines are permitted to accept shipper-built Section II ULDs.
AS for the question of whether the Lithium Battery Handling Label is necessary on the black plastic sheet covering the ULD, the answer is “YES”.
At time of acceptance, there is no need to use a check list nor is it necessary to include Section II items on the NOTOC.
Furthermore, for an overpack, PI 965 Section II – Overpacks clearly allows a package of Section II bearing the Lithium Battery Handling label to be placed inside an overpack with other items as long as they do not react dangerously with each other. If the Lithium Battery Handling label cannot be seen from the outside, that label must be duplicated on the surface of the overpack together with the word “OVERPACK”.