ICAO/IATA SoC: Which Limit Applies?

Does everyone understand the 2026 ICAO/IATA State of Charge requirements for electric vehicles under UN3556. Does ICAO/IATA need to clarify anything about “whichever is lower?”

As you know, in 2026 lithium battery-powered vehicles need to be shipped at an actual state of charge no more than 30% or an indicated state of charge no more than 25%. So this part confuses me. Yes, I understand the rationale behind the rule and the reality that not all batteries will have percentage gauges; they might have something like 3 or 4 LED indicators.

If I have a vehicle under UN3556 that has an actual state of charge of 30%, then the “fuel guage” showing battery percentage will also (most likely) show 30% right? But the rule says “indicated state of charge no more than 25%.” It doesn’t qualify this by saying “whichever is lower” or anything like that. So if my battery is 30% SoC then the indicator will also be at 30%.

Do you think that’s okay? I’m interested in how others are reading this.