Transportation of Aerosol Products
What Is Aerosol Product Transport?
Aerosol product transport involves the hazardous goods handling procedures for international shipment of products contained in pressurized containers, such as spray cans, cosmetics, paints, lubricants, cleaning agents, deodorizers, rust preventives, and insecticides.
In freight forwarder operations, aerosol products may be presented as "daily necessities," "miscellaneous goods," "cosmetics," or "sample products." However, they may qualify as dangerous goods under transport regulations.
Especially in air transport, maritime consolidated cargo, CFS in-gate, and warehouse storage, incorrect prior verification can lead to rejection of acceptance, refusal of in-gate, shipment delays, loading denial, repacking, or additional charges.
Aerosol products are not simply spray cans; their handling classification depends on factors such as the pressurized container, propellant, contents, capacity, quantity, packaging form, and mode of transport.
Scope Covered in This Article
| Item | Contents Covered in This Article | Contents Covered in Other Articles |
|---|---|---|
| Basics of Aerosol Products | Handling the identification of dangerous goods when transporting spray cans, products in pressure vessels, and those containing propellants. | Details on manufacturing technologies and container design of aerosol products should be confirmed from manufacturer materials and specialized standards. |
| Relation to UN1950 | Practical confirmation of UN number, proper shipping name, class, and quantity for cargo potentially classified as UN1950 AEROSOLS. | How to interpret UN numbers in general is covered in the UN Number article. |
| Checking SDS and Product Specifications | How to use SDS, product specifications, dangerous goods classification documents, and photos of actual cargo to verify propellants, contents, flammability, and volume. | Comprehensive guidance on reading SDS is covered in the SDS article. |
| Verification for Air Transport | Practical confirmation of IATA Dangerous Goods Regulations, airline, courier, and airport warehouse acceptance conditions. | Details on general air dangerous goods are covered in the IATA Dangerous Goods Regulations article. |
| Verification for Sea Transport | Confirming IMDG Code compliance, shipping lines, NVOCCs, CFS, dangerous goods warehouses, and eligibility for LCL consolidation. | Details on maritime dangerous goods are covered in the IMDG Code article. |
| Relation to Limited Quantity and Excepted Quantity Dangerous Goods | Points of consideration for treating small spray cans, promotional samples, and trial products as limited quantity or excepted quantity dangerous goods. | Detailed rules for limited quantity and excepted quantity dangerous goods are covered in their respective individual articles. |
| Relation to Non-Dangerous Goods Certificates | Practical handling when non-dangerous goods certificates, SDS, product specifications, and actual cargo markings are inconsistent. | Formats and preparation methods for non-dangerous goods certificates are covered in the Non-Dangerous Goods Certificate article. |
| Handling Practical Issues | Cases where aerosol products declared as cosmetics, samples, or sundries become problematic as dangerous goods. | Cost allocation after accidents, damages, and delay liability are covered in the Cargo Accidents and Cost Allocation article. |
Overview of Aerosol Products
Aerosol products are pressurized items that contain liquids, powders, gases, propellants, or other substances within a container.
These products may use flammable gases as propellants, contain flammable liquids or corrosive substances in their contents, or include components classified as marine pollutants.
Therefore, even for the same "spray can," the handling as dangerous goods varies depending on the content, propellant, capacity, container design, quantity, packaging type, and mode of transport.
Freight forwarders should not judge aerosol products solely by their appearance or product category. Whether cosmetics, cleaning supplies, industrial sprays, or promotional samples, it is necessary to check the SDS, product specifications, and dangerous goods classification documents.
Reasons Aerosol Products Are Prone to Classification as Dangerous Goods
Aerosol products contain contents and propellants inside pressurized containers, posing risks different from those of typical liquid or solid products.
| Risk Factor | Description | Impact on Transport Operations | Reference Documents / Contacts |
|---|---|---|---|
| Pressurized Container | The container is under internal pressure. | Temperature changes, damage, leakage, and acceptance conditions for air transport could be affected. | SDS, product specifications, manufacturer |
| Propellant | May include flammable gases or non-flammable gases. | Presence of flammability influences dangerous goods classification and acceptance conditions. | SDS, product specifications, dangerous goods classification materials |
| Contents | Includes paints, cleaning agents, fragrances, lubricants, insecticides, etc. | Requires confirmation of flammability, toxicity, corrosiveness, and environmental hazards. | SDS, ingredient information, GHS labeling |
| Volume and Quantity | Capacity per unit, total number of units, and total weight are relevant. | May affect small quantity exemptions, limited quantity provisions, and carrier acceptance conditions. | Packing list, product specifications, shipper |
| Packing Type | Includes single items, cartons, sets, promotional items, and e-commerce shipments. | Affects outer packaging markings, dangerous goods labels, packing requirements, and compatibility with mixed cargo. | Photos of outer packaging, packing specifications, warehouse |
| Transport Mode | Conditions differ among sea transport, air transport, courier services, and inland delivery. | The same cargo may be accepted by sea but not by air. | Shipping lines, airlines, courier companies, CFS |
UN1950 and Aerosol Products
For aerosol products, the UN1950 AEROSOLS designation is commonly used.
However, simply stating UN1950 does not finalize all transport conditions. Factors such as flammability, non-flammability, toxicity, corrosivity, oxidizing properties, environmental hazards, volume, quantity, packaging type, and mode of transport may affect required markings, labels, documentation, packaging conditions, and acceptance criteria.
| Check Item | Details to Confirm | Practical Significance | Actions if Issues Arise |
|---|---|---|---|
| UN Number | Confirm whether the product corresponds to UN1950 AEROSOLS. | Serves as the initial reference point for dangerous goods transport confirmation. | Cross-check Section 14 of the SDS, dangerous goods declaration, and manufacturer documents. |
| Proper Shipping Name | Confirm if it is listed as AEROSOLS and whether supplemental information is required. | Forms the basis for dangerous goods declarations and carrier acceptance checks. | Verify the expressions used in the SDS and dangerous goods declaration. |
| Flammability | Confirm whether the aerosol is flammable or non-flammable. | Affects carrier acceptance conditions, labeling, and quantity restrictions. | If flammability is unclear, verify with the shipper or manufacturer. |
| Propellant | Confirm whether the propellant is flammable gas, non-flammable gas, or other types. | Critical for determining the hazard classification of the aerosol product. | Obtain product specifications or hazardous goods classification documents. |
| Contents | Verify contents such as paint, cleaning agents, fragrances, insecticides, lubricants, corrosive substances, etc. | Check the flammability, toxicity, corrosiveness, and environmental hazards of the contents themselves. | Review Sections 2, 3, 9, and 14 of the SDS. |
| Volume and Quantity | Check the volume per unit, number of units per carton, and total quantity. | Impacts evaluation of limited quantity, restricted quantity, and acceptance conditions. | Cross-check packing list against actual cargo. |
| Marine Pollutants | Confirm whether any components qualify as marine pollutants. | May require additional markings or declaration confirmation for maritime transport. | Verify with SDS, dangerous goods declaration, and outer packaging labels. |
| Mode of Transport | Confirm whether the shipment is by sea, air, or courier. | Acceptance conditions differ depending on the transport mode, even for the same UN1950 aerosols. | Separately check the IMDG Code and IATA Dangerous Goods Regulations. |
UN1950 serves as an initial checkpoint for aerosol products. Freight forwarders should confirm the UN number, proper shipping name, hazard class, flammability, quantity, packaging, and transport mode as a complete set.
Factors Changing Handling of the Same Aerosol Can
Although aerosol products may appear as identical spray cans, their transport handling can vary depending on certain factors.
| Branching Factor | Possible Outcome | What to Check | Recommended Approach |
|---|---|---|---|
| Whether the propellant is a flammable gas | It may be subject to stricter acceptance conditions as a flammable aerosol. | Confirm the propellant through the SDS, product specifications, and dangerous goods classification documents. | Check flammability information with the airline or shipping line. |
| Whether the propellant is a non-flammable gas | Even if not flammable, it may still require dangerous goods confirmation as a pressurized container. | Do not assume non-dangerous goods; verify the UN number and transport details. | Confirm Section 14 of the SDS and carrier’s conditions. |
| Whether the contents include flammable liquids | There may be restrictions related to ignition sources, temperature, air transport, and warehouse storage. | Check flash point, composition, GHS labeling, and Section 14 of the SDS. | Confirm dangerous goods handling, warehouse conditions, and air acceptance requirements. |
| Whether the contents have corrosive or toxic properties | Additional hazards may affect handling, storage, and compatibility with other cargo. | Verify hazard class, subsidiary hazards, GHS labeling, and the SDS. | Check required labels, segregation, and CFS acceptance conditions. |
| Change in capacity | Determines whether it qualifies as a limited quantity or small quantity dangerous good. | Confirm capacity per can, units per carton, and total quantity. | Recheck dangerous goods declarations and acceptance conditions if quantities change. |
| Change in packaging form | Packaging type—single units, sets, promotional items, or e-commerce shipments—may affect outer carton markings and packaging requirements. | Check inner and outer packaging, carton markings, and dangerous goods labels. | Review photos of outer packaging and packaging specification details. |
| Change in transport mode | May be accepted by sea but not by air, or only conditionally by air. | Separate checks for IMDG Code and IATA Dangerous Goods Regulations. | Do not apply sea transport acceptance decisions to air transport. |
For aerosol products, even if the same item was previously transported without issue, changes in capacity, packaging, transport mode, or airline/shipping line requirements should trigger reconfirmation.
Documents Freight Forwarders Should Verify
When handling aerosol products, freight forwarders should not rely solely on the product name. Instead, they must cross-reference documentation with the actual product information.
| Document / Information | Items to Verify | Points of Caution | Actions if Deficient |
|---|---|---|---|
| SDS | Verify the UN number, official proper shipping name, hazard class, flammability, marine pollutant status, and transport information. | If the transport information section is blank, marked not applicable, or outdated, further confirmation is needed. | Request the latest SDS or a confirmation letter from the manufacturer. |
| Product Specification Sheet | Check the propellant, contents, container structure, capacity, and intended use. | The SDS alone may not provide sufficient details about the propellant or container. | Obtain manufacturer documentation, product catalogs, or hazardous goods classification materials. |
| Dangerous Goods Declaration | Confirm UN1950, proper shipping name, hazard class, quantity, packaging, and emergency contact details. | Ensure consistency with the SDS and actual product markings. | If inconsistencies exist, have the declaration corrected. |
| Photos of Actual Product and Outer Packaging | Check whether the product is in a spray can, GHS labels, dangerous goods labels, and carton markings. | The invoice description alone may not indicate if the item is a spray can. | Confirm outer packaging markings and the product condition before in-gate. |
| Non-Dangerous Goods Certificate | Verify the basis for classifying the product as non-dangerous goods. | Check for contradictions such as the presence of pressurized containers or propellants. | Cross-check against the SDS, product specifications, and product markings. |
| Quantity and Packaging Information | Verify individual unit capacity, number of units per carton, total units, and total weight. | This affects limited quantity determinations and acceptance conditions. | Review packing lists and packing details. |
Differences Between Air and Sea Transport
Aerosol products have different points of contact and acceptance conditions depending on whether they are transported by air or sea.
| Check Items | Air Transport | Sea Transport | Freight Forwarder Practical Notes |
|---|---|---|---|
| Governing Regulations | Check the IATA Dangerous Goods Regulations. | Check the IMDG Code. | When changing transport modes, reconfirm conditions. |
| Points of Contact | Confirm with airlines, courier companies, airport warehouses, and dangerous goods specialists. | Confirm with shipping lines, NVOCCs, CFS, dangerous goods warehouses, and trucking companies. | Even if regulations permit, carriers or facilities may refuse acceptance. |
| Main Confirmation Items | Check passenger aircraft acceptance, cargo-only aircraft conditions, packaging standards, quantity limits, and airline-specific restrictions. | Confirm shipping line acceptance, LCL consolidation eligibility, CFS in-gate conditions, outer packaging markings, and marine pollutant status. | Conditions for the same UN1950 can differ between sea and air transport. |
| Common Bottlenecks | Delays often occur during airline confirmation, airport warehouse in-gate, and courier acceptance checks. | Delays often happen during shipping line dangerous goods approval, CFS in-gate, consolidation eligibility checks, and warehouse acceptance. | Verify SDS and quantity details from the quotation stage. |
| Points to Note | Even cosmetics or samples may be subject to air dangerous goods acceptance restrictions. | Even if the shipping line accepts the cargo, CFS or warehouse may refuse acceptance. | Confirm carrier conditions separately from facility conditions. |
| Lead Time | Pre-approval and document checks typically require more time than regular cargo. | Dangerous goods booking, in-gate scheduling, and CFS confirmation often extend lead times compared to regular cargo. | Avoid proceeding with the same cut-off times as regular cargo. |
Freight forwarders transporting aerosol products should confirm according to the IMDG Code for sea transport and the IATA Dangerous Goods Regulations for air transport. Cargo accepted for sea transport cannot be assumed to be transferable to air transport without additional checks.
Precautions for Air Transport
Aerosol products are strictly regulated as dangerous goods in air transport.
For flammable aerosols, it is necessary to confirm whether they can be carried on passenger planes, if they are restricted to cargo aircraft only, packaging instructions, quantity limits, labeling and markings, and whether a dangerous goods declaration is required.
| Decision Factor | What to Confirm | Practical Considerations | Actions if Issues Arise |
|---|---|---|---|
| Flammability | Confirm whether the aerosol is flammable or non-flammable. | This affects acceptance conditions and carriage on airlines. | Check the SDS, product specification, and airline responses. |
| Carriage on Passenger Aircraft | Confirm if transport on passenger planes is allowed or if cargo aircraft only. | Booking on regular flights may not be possible. | Consider cargo flights, other airlines, or switching to sea transport. |
| Quantity and Volume | Confirm capacity per unit, quantity per outer packaging, and total quantity. | Packaging and documentation requirements may change depending on quantity. | Consider splitting quantities, changing packaging, or obtaining a revised quote. |
| Packaging | Check leak prevention, damage prevention, outer packaging strength, and inner packaging condition. | Standard general cargo packaging may not be accepted. | Use dangerous goods packaging, repackage, or correct outer package markings. |
| Courier Company Conditions | Confirm if acceptance is possible for small shipments or e-commerce cargo. | Even if allowed by regulations, couriers may refuse acceptance. | Consider alternative couriers, air cargo carriers, or sea transport. |
Even products that appear to be general consumer goods, such as cosmetics, hair sprays, deodorant sprays, and cleaning sprays, may qualify as dangerous goods for air transport. It is important to present the SDS and dangerous goods information to confirm acceptance before obtaining quotes or making bookings for air shipments.
Points to Note for Maritime Transport
In maritime transport, aerosol products may be classified as dangerous goods under the IMDG Code.
When booking with the shipping line, it is necessary to confirm the UN number, proper shipping name, hazard class, quantity, packaging, packing, presence of marine pollutants, and emergency response information.
| Check Item | Details to Confirm | Points of Attention | Actions if Issues Arise |
|---|---|---|---|
| Shipping Line Acceptance | Confirm whether the shipping line accepts the aerosol product. | Conditions may vary depending on the route, shipping line, and transshipment ports. | Consider alternative shipping lines, routes, or direct shipping options. |
| LCL Consolidation Eligibility | Confirm if the aerosol product can be consolidated into the same container with other cargo. | If consolidation is not allowed, FCL shipping or separate arrangements may be required. | Consider FCL shipments, alternative CFS, or different services. |
| CFS In-Gate Conditions | Confirm whether the CFS can accept aerosol products. | Even if the shipping line accepts it, the CFS may refuse receipt. | Consider alternative CFS, dangerous goods warehouses, or adjust the in-gate date. |
| Packaging Labeling | Confirm necessity for dangerous goods labels, UN number markings, limited quantity marks, and marine pollutant marks. | Labeling deficiencies may lead to refusal of receipt or relabeling requirements. | Correct the packaging labels before in-gate. |
| Warehouse Storage | Confirm the availability of dangerous goods storage, temperature control, no open flames, and ventilation requirements. | General warehouses may refuse storage. | Consider dangerous goods-compatible warehouses, direct delivery, or adjust the storage date. |
When consolidating LCL shipments, CFS operators may impose individual conditions for accepting aerosol products. Failure to confirm deadlines, acceptable in-gate dates, dangerous goods labels, packaging markings, and compatibility with other cargo in advance could result in refusal at the CFS.
Relation to Limited Quantities and Excepted Quantities of Dangerous Goods
Aerosol products may qualify for limited quantity or excepted quantity handling depending on their volume, quantity, and packaging conditions.
However, small quantity does not mean the product is not dangerous goods. Whether aerosol products can be treated as limited or excepted quantities depends on the volume, quantity, packaging, markings, transport mode, and acceptance conditions of shipping lines or airlines and should be confirmed accordingly.
| Category | Perspective for Aerosol Products | Precautions | Contacts / Reference Materials |
|---|---|---|---|
| Limited Quantity | Considered if volume and quantity meet specific criteria. | Not treated exactly the same as general cargo. | SDS, Dangerous Goods Declaration, Shipping Line / Airline |
| Excepted Quantity | May qualify for simplified handling under certain conditions for very small quantities of dangerous goods. | Confirmation is needed regarding applicability for aerosol products based on product composition and transport regulations. | Shipper, Manufacturer, Dangerous Goods Specialist |
| Small Volume Spray Cans | Even small cans require verification of pressure vessel status and propellant type. | Do not assume general cargo handling solely because of small quantity. | Product Specification Sheet, SDS, Photos of Actual Product |
| Promotional Samples / Test Products | Despite small quantities, these still require evaluation as aerosol products. | Determination should be based on content, propellant, container, and quantity, not use. | Shipper, Manufacturer, Product List |
This article focuses on key points for considering limited and excepted quantity handling of aerosol products, rather than detailed regulations on these categories.
Relationship with Non-Dangerous Goods Certificates
For aerosol products, shippers may provide a Non-Dangerous Goods Certificate. However, when dealing with spray cans or products in pressurized containers, relying solely on a Non-Dangerous Goods Certificate is risky.
Aerosol products require more thorough checks than regular liquids or general merchandise due to their pressurized containers, the use of propellants, and the potential presence of flammable, corrosive, toxic, or environmentally hazardous substances in their contents.
| Item to Confirm | Details to Confirm | Action if There Is a Discrepancy | Party to Confirm With |
|---|---|---|---|
| Non-Dangerous Goods Certificate | Verify the rationale for non-dangerous goods classification, the applicable products, issuer, and issuance date. | Check if it matches the applicable products. | Shipper, Manufacturer |
| SDS | Confirm the UN number, transport information, GHS labels, flammability, and pressurized container information. | If the SDS contains dangerous goods information, do not rely solely on the Non-Dangerous Goods Certificate for classification. | Shipper, Manufacturer, Dangerous Goods Specialist |
| Product Specifications | Check the propellant, contents, volume, and container structure. | If the propellant is a gas or if the container is pressurized, verify transport regulations accordingly. | Manufacturer, Shipper |
| Physical Markings | Check GHS labels, dangerous goods labels, fire hazard warnings, and pressurized container markings. | Verify there are no contradictions between physical markings and the non-dangerous goods explanation. | Warehouse, Delivery Company, Shipper |
| Transport Mode | Confirm if the transport is by sea or air. | Confirm that the rationale for non-dangerous goods classification is valid for the specific mode of transport. | Shipping Line, Airline, CFS |
If contradictions arise among the Non-Dangerous Goods Certificate, SDS, product specifications, and physical markings, reconfirm with the shipper or manufacturer, and if necessary, consult the shipping line, airline, CFS, or dangerous goods specialists.
Common Product Names Missing Proper Description on Invoices
Aerosol products are sometimes listed on invoices under product names that do not clearly identify them as dangerous goods.
| Example Invoice Description | Reason for Oversight | Recommended Approach | Documents to Check |
|---|---|---|---|
| cosmetics | Listed simply as cosmetics, making it unclear that the items are hair sprays or deodorant sprays. | Verify the presence of spray cans using product lists, SDS, and actual photos. | Product details, SDS, photos |
| cleaner | Described as cleaner, without specifying whether it is a spray or a liquid bottle. | Check container shape, propellant type, flammability, and confirm with the SDS. | SDS, product specifications, photos |
| spray | Only described as “spray,” providing no information on contents or propellant. | Confirm usage, ingredients, volume, SDS, and any dangerous goods classification documents. | SDS, product specifications, dangerous goods classification documents |
| sample | Handled as a sample, increasing the risk that dangerous goods checks are omitted. | Even for small quantities, confirm if the item is an aerosol product. | Product lists, SDS, actual photos |
| parts | Listed as parts, which may include spray-type repair agents or lubricants. | Verify contents with component details, photos, and product specifications. | Parts list, photos, product specifications |
| gift set | Aerosol cans may be included as part of a set. | Check the detailed list of set contents to identify any aerosol products. | Set content list, SDS, actual photos |
Freight forwarders should not rely solely on the invoice description. They need to confirm container type, whether the product is in spray form, the presence of an SDS, dangerous goods classification, and packaging condition.
Comparison Table of Freight Forwarder Involvement
| Category | Supportive Actions | Actions to Avoid | Practical Response |
|---|---|---|---|
| When Receiving Product Names at Quotation Stage | Confirm the presence of spray cans, pressurized containers, or aerosol products. | Assuming the cargo is non-dangerous based only on descriptions such as cosmetics, general goods, or samples. | Request SDS, product lists, and actual photos. |
| When Receiving an SDS | Verify UN1950, official shipping name, flammability, and transport information section. | Concluding transport eligibility solely because an SDS is provided. | Cross-check with dangerous goods declarations, product specifications, and carrier conditions. |
| When Reviewing Product Specifications | Check propellants, contents, volume, and container structure. | Deciding dangerous goods classification based solely on product specifications. | Verify against SDS Section 14 and dangerous goods classification references. |
| When Receiving a Non-Dangerous Goods Certificate | Confirm consistency with SDS, product specifications, and actual cargo markings. | Concluding the check is complete based on the certificate alone. | Reconfirm with the shipper or manufacturer if inconsistencies are found. |
| When Arranging Air Transport | Confirm IATA Dangerous Goods Regulations, airline, and courier acceptance conditions. | Assuming air transport acceptance because maritime transport was accepted. | Check quantity limits, passenger aircraft carriage restrictions, and cargo aircraft exclusive conditions. |
| When Arranging Sea LCL Consolidations | Confirm CFS acceptance, consolidation eligibility, outer packaging markings, and delivery date. | Assuming CFS will accept cargo just because the shipping line does. | Confirm with CFS, consolidation providers, and dangerous goods warehouses. |
| When Handling Small-Lot and E-commerce Shipments | Verify restrictions with courier companies, airlines, and inland delivery services. | Assuming dangerous goods confirmation is unnecessary simply because shipment volume is small. | Confirm acceptance conditions by transport mode. |
| When Documents and Cargo Are Inconsistent | Clarify discrepancies and confirm with the shipper or manufacturer. | Proceed with in-gate, loading, or shipment despite inconsistencies. | Hold arrangements to finalize classification and transport conditions. |
Common Practical Issues
| Case | Issue | Documents / Parties to Check | Recommended Actions |
|---|---|---|---|
| Shipment declared as cosmetics included spray cans | No confirmation was made whether the products qualify as aerosols subject to dangerous goods regulations. | SDS, product list, photos of the actual cargo, shipper | Reconfirm classification as dangerous goods if necessary. |
| Airline refused to accept aerosol products | Conditions and quantity limits for air transport acceptance may not have been checked. | Airline response, SDS, quantity information | Consider alternative airlines, cargo-only flights, or switch to sea transport. |
| CFS refused in-gate of aerosol products | Acceptance conditions for dangerous goods at the CFS may not have been confirmed in advance. | CFS response, shipping line response, dangerous goods information | Check alternate CFS, dangerous goods warehouse, FCL consolidation, or other shipping line services. |
| Non-dangerous goods certificate issued but SDS shows UN1950 | Contradictions exist between documents on whether the cargo is dangerous goods or not. | Non-dangerous goods certificate, SDS, manufacturer confirmation | Confirm with shipper and manufacturer to establish accurate dangerous goods classification. |
| Planned to ship as limited quantity dangerous goods, but labeling and packaging were insufficient | Even limited quantity dangerous goods must meet required conditions, which were not fulfilled. | Outer packaging markings, quantity, packaging, carrier requirements | Verify outer markings, quantity, packaging, documentation, and shipping line or airline conditions. |
| Issues with mixing aerosol products with other cargo for sea transport consolidation | Dangerous goods class and CFS consolidation rules may not have been checked. | CFS response, consolidator response, dangerous goods class | Consider consolidation eligibility, segregation requirements, FCL shipment, or separate sailings. |
| Samples arranged as regular cargo | Decision based only on use or quantity without confirming the presence of pressurized containers. | Product list, SDS, photos of actual cargo, product specifications | Even for samples, confirm SDS details, container type, propellant, and capacity. |
| Gift sets included spray cans as part of the set | Product name of the whole set does not reveal aerosol content. | Set content list, photos of actual cargo, SDS | Check each item in the set and perform necessary dangerous goods classification. |
4-Column Checklist
| Confirmation Situation | Party to Confirm With | Items to Confirm | Actions If Issues Arise |
|---|---|---|---|
| When the quote request lists cosmetics, general goods, or samples | Shipper / Manufacturer | Check whether spray cans, pressurized containers, or aerosol products are included. | If unclear, request product list, photos of actual items, and SDS. |
| Upon receiving the SDS | Shipper / Manufacturer | Confirm UN1950, official proper shipping name, flammability, transport section, and marine pollutant status. | If fields are blank or unclear, request manufacturer confirmation or dangerous goods classification documents. |
| When reviewing product specifications | Shipper / Manufacturer | Check propellant, contents, capacity, container structure, and intended use. | If inconsistent with SDS, reconfirm classification. |
| When a non-dangerous goods certificate is submitted | Shipper / Manufacturer | Verify SDS, product specifications, actual markings, and basis for non-dangerous goods status. | If conflicting with UN1950 or pressurized container info, hold handling as regular cargo. |
| When arranging air transport | Airlines / Courier Companies / Air Freight Agents | Confirm IATA Dangerous Goods Regulations handling, quantity limits, passenger aircraft acceptance, and packaging requirements. | If not accepted, consider sea transport, different airline, or cargo-only flights. |
| When arranging maritime LCL consolidation | Shipping Lines / NVOCC / CFS / Consolidators | Check IMDG Code handling, CFS acceptance, consolidation eligibility, and outer packaging markings. | If not accepted, consider FCL shipment, alternative CFS, or dangerous goods warehouse. |
| When checking outer packaging markings | Shipper / Warehouse / Delivery Company | Confirm dangerous goods labels, UN number, GHS markings, limited quantity markings, and carton labels. | Correct markings, relabel, or repack before in-gate. |
| When documents do not match the actual goods | Shipper / Manufacturer / Warehouse | Verify SDS, dangerous goods declaration, photos of actual goods, product specifications, and invoice. | Hold in-gate, loading, and shipment until correct classification and transport conditions are confirmed. |
Example 1: Case Where Hair Spray Was Included in Cargo Declared as Cosmetics
The invoice simply listed the goods as "cosmetics," and the shipment was quoted as ordinary cargo for air transport.
Upon reviewing the product list, it was found that the set included hair spray and antiperspirant spray. In this case, even if declared as cosmetics, it may be necessary to check the cargo as aerosols subject to dangerous goods regulations.
The freight forwarder should verify the SDS, product specifications, actual product photos, volume per unit, total quantity, propellant type, and flammability.
For air transport, acceptance conditions of the airline or courier must be confirmed. If the shipment is not accepted or accepted with conditions, alternative options such as sea transport, a different airline, or splitting the quantity should be proposed to the shipper.
Example 2: Case with a Non-Dangerous Goods Certificate but UN1950 Listed on the SDS
This involves a situation where the shipper has submitted a non-dangerous goods certificate, but Section 14 of the SDS indicates UN1950 AEROSOLS.
In such cases, relying solely on the non-dangerous goods certificate to proceed as regular cargo is risky. It is necessary to confirm whether the product is the same, whether the SDS is the latest version, and which transport mode the non-dangerous goods certificate applies to.
The freight forwarder should verify with the shipper or manufacturer about the propellant, pressure vessel, contents, capacity, and the basis for the transport information section.
If inconsistencies remain unresolved, confirmation should be obtained from the shipping line, airline, CFS, or dangerous goods specialists to determine whether the cargo should be handled as dangerous goods.
Example 3: Case Where the CFS Could Not Accept Aerosol Products in LCL Ocean Freight
In this case, although the shipping line confirmed acceptance of aerosol products classified under UN1950, the CFS used for the LCL consolidation stated it could not accept the cargo.
For maritime transport, the shipping line’s acceptance and the CFS’s acceptance are separate decisions. Especially for aerosol products, issues such as storage conditions, fire safety management, consolidation restrictions, delivery dates, and the presence of dangerous goods labels can affect acceptance.
The freight forwarder should consider alternatives such as using a different CFS, utilizing a dangerous goods warehouse, converting to FCL, switching to a different carrier service, or postponing shipment to the next vessel.
When informing the shipper, it is important to explain the reasons for the CFS refusal, propose alternative arrangements, clarify any additional costs, and outline the potential impacts on the schedule.
Specific Case 4: Attempting to Ship a Small Quantity Sample as Regular Cargo
This case involved a shipper explaining that since it was a small quantity sample, shipping as regular cargo would be acceptable, and requested air transport for a few cans of cleaning spray.
However, even in small quantities, aerosol products contain pressurized containers and propellants, which may require dangerous goods verification. The fact that the cargo is a sample does not exclude it from being classified as dangerous goods.
The freight forwarder should confirm the SDS, individual container volume, total quantity, type of propellant, contents, outer packaging markings, and acceptance conditions of the airline or courier company.
Even if the cargo qualifies as limited quantity dangerous goods or is eligible for exceptional handling, compliance with labeling, packaging, quantity limits, documentation, and carrier requirements remains necessary.
Items to Confirm with the Shipper
When transporting aerosol products, the freight forwarder should confirm dangerous goods information with the shipper at an early stage.
- Whether the product is contained in spray cans or aerosol containers.
- Whether it falls under UN1950 AEROSOLS.
- Whether it is a flammable or non-flammable aerosol.
- The type of propellant used.
- Whether the contents have flammability, corrosivity, toxicity, oxidizing properties, or environmental hazards.
- Whether an SDS, dangerous goods classification documents, or product specification sheets are available.
- The capacity per unit, total quantity, and total weight.
- Whether it may qualify as limited quantity or excepted quantity dangerous goods.
- The intended mode of transport: air, sea, or courier.
- Whether the cargo meets acceptance requirements of the airline, shipping line, CFS, and warehouse.
- If a non-dangerous goods certificate is provided, whether it conflicts with the SDS or actual cargo markings.
Common Misconceptions
Because aerosol products often resemble everyday items, dangerous goods checks are frequently overlooked.
| Misconception | Practical Perspective | Items to Confirm |
|---|---|---|
| Because they are cosmetics, they are not dangerous goods | Hair sprays, deodorant sprays, mist products, and the like may still require dangerous goods verification. | Check the SDS, container design, propellant type, and airline acceptance conditions. |
| Small quantities qualify as general cargo | Even small quantities need confirmation of transportation conditions as aerosol products. | Confirm capacity, quantity, eligibility as limited quantity dangerous goods, and marking requirements. |
| Non-flammable gases are safe | Even if non-flammable, since aerosols are pressurized containers, transportation checks may still be necessary. | Confirm the SDS, UN number, and air and sea acceptance conditions. |
| Having a non-dangerous goods certificate is sufficient | It is necessary to verify consistency between the non-dangerous goods certificate, SDS, product specifications, and actual markings. | Check propellant type, pressurized container status, GHS labeling, and transport information. |
| If it was shipped by sea, it can also be shipped by air | Air transport may have stricter acceptance conditions and quantity limits than sea transport. | Confirm the IATA Dangerous Goods Regulations and airline conditions. |
| If it is not labeled as spray, it is not an aerosol product | On invoices, it may be listed as cosmetics, cleaner, sample, gift set, or similar. | Verify product lists, photos of the actual goods, SDS, and container shape. |
| Limited quantity dangerous goods do not require labeling or packaging checks | Even for limited quantity dangerous goods, labeling, packaging, quantity, and acceptance conditions must be confirmed. | Check outer package markings, packaging, quantity, and shipping line and airline requirements. |
| CFS always accepts cargo accepted by the shipping line | The shipping line’s acceptance does not guarantee CFS acceptance. | Confirm CFS in-gate conditions, eligibility for consolidation, and the need for dangerous goods storage. |
Points Freight Forwarders Should Note
Transporting aerosol products is a practical area prone to oversight within dangerous goods and chemical transport.
- Do not rely solely on the invoice description to assess the cargo.
- Confirm the presence of spray cans, pressurized containers, or propellants.
- Check for the inclusion of UN1950.
- Verify flammability status, content, volume, quantity, and packaging type.
- Cross-check the SDS, product specifications, dangerous goods declaration, and actual cargo markings.
- Separately confirm transport conditions for air and sea shipments.
- Even for limited quantities of dangerous goods, verify labeling, packaging, and acceptance criteria.
- Do not judge solely based on a non-dangerous goods certificate.
- Pre-confirm acceptance conditions with CFS, warehouses, shipping lines, and airlines.
Summary
Transporting aerosol products involves managing the dangerous goods confirmation process for internationally shipping items filled in pressurized containers, such as spray cans, cosmetics, paints, lubricants, cleaners, deodorants, rust preventatives, and insecticides.
Although aerosol products may appear as everyday items or general merchandise, they may require dangerous goods confirmation under UN1950 AEROSOLS. Handling varies significantly depending on the propellant, flammability, contents, capacity, quantity, packaging type, and transport mode.
For air transport, it is necessary to confirm whether carriage on passenger aircraft is permitted, cargo aircraft only conditions, packaging standards, quantity limits, and any airline-specific requirements. For sea transport, confirmation is required on the shipping line’s acceptance, CFS in-gate conditions, LCL consolidation eligibility, and marine pollutant classification.
Freight forwarders must not treat aerosol products simply as spray cans but should cross-check the SDS, product specifications, dangerous goods declarations, actual cargo markings, UN number, acceptance of small quantity dangerous goods, and acceptance criteria of shipping lines, airlines, CFS, and warehouses. This ensures safe shipment preparation.
The key point of this article is to approach aerosol products not as everyday goods, general merchandise, or cosmetics, but as dangerous goods that require a combined confirmation of pressurized containers, propellants, contents, capacity, quantity, packaging, and transport mode in dangerous goods transport operations.
