Trace Hazardous Materials
What Are Excepted Quantities (EQ)?
Excepted Quantities (EQ) refer to the classification applied when transporting substances classified as dangerous goods in extremely small quantities defined by regulations. This category is called Dangerous Goods in Excepted Quantities or simply Excepted Quantities, often abbreviated as EQ.
In freight forwarding practice, EQ is often confused with Limited Quantities (LQ). However, Excepted Quantities and Limited Quantities are not the same. The relevant cargo items, allowable quantities, packaging requirements, markings, documentation, and acceptance conditions by airlines, shipping lines, and CFS facilities must each be individually confirmed.
Excepted Quantities do not mean the cargo is "non-dangerous." Rather, this classification applies only when the cargo is dangerous goods handled in extremely small amounts that meet specific regulatory packaging, marking, and quantity conditions.
For items such as research reagents, inspection samples, chemical samples, fragrances, additives, and analytical substances, shippers may describe the cargo as "excepted," "sample," or "for testing." However, such descriptions alone do not guarantee the cargo can be treated as general cargo, non-dangerous, or as Excepted Quantities. It is essential to verify the SDS, UN number, proper shipping name, hazard class, packing group, quantity, packaging condition, and mode of transport.
Scope Covered in This Article
| Item | Contents Covered in This Article | Contents Covered in Other Articles |
|---|---|---|
| Basics of Excepted Quantities | Clarifies that Excepted Quantities are treated as dangerous goods, permitted under certain conditions only for extremely small quantities. | The overall process of dangerous goods transport is covered in the Dangerous Goods Transport article. |
| Differences from Limited Quantities | Covers the differences between Excepted Quantities and Limited Quantities regarding quantities, markings, packaging, and documentation requirements. | Details on Limited Quantities are covered in the Limited Quantities article. |
| Applicability | Discusses how applicability as Excepted Quantities depends on UN number, proper shipping name, hazard class, packing group, quantity per inner packaging, and total quantity per outer packaging. | Quantity limits and special provisions for individual UN numbers should be checked in the IMDG Code and IATA Dangerous Goods Regulations. |
| Triple Packaging | Covers verification of inner packaging, intermediate packaging, outer packaging, absorbents, cushioning materials, and outer markings. | Details on dangerous goods containers and approved packaging are covered in the Packing Group and Dangerous Goods Containers articles. |
| Excepted Quantities Mark | Explains the meaning of the Excepted Quantities mark, outer packaging markings, differences from standard dangerous goods labels, and additional conditions for air transport. | Dimensions, placement, and detailed conditions of markings should be confirmed with the latest regulations and carrier requirements. |
| Differences Between Maritime and Air Transport | Notes that cargo accepted as Excepted Quantities in maritime transport is not necessarily eligible for the same treatment in air transport. | Details on maritime transport are covered in the IMDG Code article, and air transport specifics are covered in the IATA Dangerous Goods Regulations article. |
| Differences from Non-Hazardous Cargo Certificates | Clarifies that Excepted Quantities are hazardous goods and distinct from non-hazardous cargo certificates. | The role and precautions regarding non-hazardous cargo certificates are covered in the Non-Hazardous Cargo Certificate article. |
| Practical Checks for Freight Forwarders | Addresses the practice of not accepting shippers’ descriptions of "micro quantity," "sample," or "for testing" at face value, but confirming SDS, packaging, markings, and acceptability. | Liability judgments, insurance, and claims after incidents are covered in the Cargo Claims and Liability Scope article. |
Basic Concept of Excepted Quantities
Excepted Quantities relate to the transport of extremely small amounts of dangerous goods such as research reagents, test samples, chemical samples, fragrances, additives, and analytical substances. Due to the limited quantities involved, simplified handling compared to standard dangerous goods transport may be permitted if certain conditions are met.
However, not all dangerous goods can be transported as Excepted Quantities. Whether cargo qualifies depends on factors such as the UN number, proper shipping name, hazard class, packing group, quantity per inner packaging, total quantity per outer packaging, packaging method, and mode of transport.
Even if the shipper states that the cargo is “a sample,” “a very small amount,” or “for testing,” this alone does not guarantee it can be treated as Excepted Quantities. It is necessary to verify the SDS, dangerous goods classification documentation, UN number, quantities, packaging details, and mode of transport to confirm if the cargo meets the applicable conditions under Excepted Quantities (EQ).
Difference Between Excepted Quantities and Limited Quantities
Excepted Quantities and Limited Quantities are both systems that allow simplified handling of certain dangerous goods, but they are not the same. Excepted Quantities are abbreviated as EQ, while Limited Quantities are abbreviated as LQ. They differ in their applicable conditions, quantities, markings, documentation, and acceptance criteria.
| Category | English Term | Basic Concept | Practical Notes |
|---|---|---|---|
| Excepted Quantities (EQ) | Excepted Quantities | A system for handling very small quantities of dangerous goods under limited conditions. | Confirm quantity per inner packaging, total quantity per outer packaging, triple packaging, and the EQ marking. |
| Limited Quantities (LQ) | Limited Quantities | A system for treating dangerous goods meeting specific inner packaging volume and outer packaging conditions as Limited Quantities. | Check the LQ mark, packaging requirements, and mode-specific acceptance criteria. |
| Common Point of Confusion | EQ and LQ | Both appear as “small quantities” of dangerous goods, leading to frequent confusion in practice. | They differ in system rules, quantity limits, markings, and acceptance conditions; they should not be used as synonyms. |
| Relationship with Regular Dangerous Goods | Regular Dangerous Goods Transport | If conditions for EQ or LQ are not met, cargo must be handled as regular dangerous goods. | Confirm dangerous goods declaration, standard labeling, packaging, and carrier, airline, and CFS acceptance. |
In practice, it is critical not to determine classification based solely on terms like “small quantity,” “excepted quantity,” “sample,” or “small bottle.” Whether to classify cargo as EQ, LQ, regular dangerous goods, or non-dangerous cargo should be verified based on the SDS and applicable regulations.
Cases Where Excepted Quantities (EQ) Cannot Be Applied
The Excepted Quantities classification does not apply to all types of dangerous goods. Depending on the hazard class, UN number, proper shipping name, packing group, and special provisions, certain cargo may not qualify as Excepted Quantities.
| Item to Confirm | Reason for Confirmation | Practical Points to Note | Reference Materials / Contacts |
|---|---|---|---|
| Hazard Class | Application of Excepted Quantities may be restricted depending on the class. | Extra caution is required for explosives, radioactive materials, and highly toxic substances. | SDS, hazard class references, dangerous goods specialists |
| UN Number | Whether Excepted Quantities treatment applies varies by UN number. | The applicability and quantity limits can differ even within the same hazard class depending on the UN number. | SDS Section 14, dangerous goods classification statements, IMDG Code, IATA Dangerous Goods Regulations |
| Packing Group | Highly hazardous cargo may not be eligible for Excepted Quantities treatment. | Special caution is necessary for PG I cargo and other high hazard levels. | SDS, dangerous goods declarations, manufacturer confirmation documents |
| Capacity / Weight of Inner Packaging | Excepted Quantities rules limit the amount per inner packaging unit. | Even if the overall outer package is small, exceeding limits per inner packaging disqualifies Excepted Quantities treatment. | Packing list, packing details, product capacity, shipper or packer confirmation |
| Total Quantity per Outer Packaging | The total amount per outer packaging is also subject to limits. | When grouping many small bottles, confirm that total quantity does not exceed outer packaging limits. | Packing list, outer packaging specifications, warehouse records |
| Triple Packaging | In some cases, requirements for inner packaging, intermediate packaging, and outer packaging must be met. | Small bottles or simple containers alone may not satisfy Excepted Quantities packaging requirements. | Packing photos, packaging specifications, dangerous goods specialists, packers |
| Mode of Transport | Conditions for Excepted Quantities treatment differ between maritime and air transport. | Cargo allowed as Excepted Quantities by sea may not be accepted under the same classification by air. | Shipping lines, airlines, CFS, air freight terminals, courier companies |
Whether cargo qualifies as Excepted Quantities must be judged based on the regulatory conditions of dangerous goods rules, not by product name or use as a sample. Particularly in air transport, despite regulatory allowance, airlines or courier companies may impose their own restrictions and refuse acceptance in practice.
Concept of Triple Packaging
For Excepted Quantities, even small amounts require packaging that prevents leakage, breakage, contamination, volatilization, or ignition. Triple packaging, combining inner containers, intermediate packaging, and outer containers, may be necessary.
| Packaging Element | Role | Points to Confirm | Actions if Issues Are Found |
|---|---|---|---|
| Inner Container | The container holding the dangerous goods directly. | Check the physical state, volume, seal integrity, and material compatibility. | If leakage or material incompatibility is detected, replace with a suitable container. |
| Intermediate Packaging | Packaging that protects the inner container and limits spread in case of leakage or damage. | May require absorbents, cushioning materials, dividers, or sealed bags. | If intermediate packaging is insufficient, request repackaging. |
| Outer Container | The outer packaging that withstands impact, pressure, and stacking during transport. | Confirm outer container strength, markings, total weight, and stacking safety. | If strength or marking is inadequate, change the outer container. |
| Absorbents and Cushioning Materials | Used to reduce damage expansion if liquid leakage or breakage occurs. | For liquid samples, the presence and quantity of absorbents is often critical. | Add required amounts of absorbents and cushioning materials. |
| Outer Markings | Indicates to transport personnel that the cargo is EQ. | Check for the appropriate Excepted Quantities mark, necessary information, and correct placement. | If markings are incomplete, correct them before in-gate. |
Especially with liquid samples or reagents, vibration and temperature changes during transport may cause container breakage. Freight forwarders should verify that the shipper has not simply placed materials in small bottles or inadequate containers, and request dangerous-goods-compliant packaging when necessary.
Meaning of the Excepted Quantities Mark
For Excepted Quantities, a special EQ mark may be required instead of the standard dangerous goods label. This mark indicates that while the cargo is classified as dangerous goods, it is packaged and marked under specific conditions as Excepted Quantities.
The EQ mark does not imply "not dangerous goods." Even if standard dangerous goods labels are not required or are simplified, the cargo must still meet the quantity limits, triple packaging, marking, and acceptance conditions applicable to Excepted Quantities.
| Check Item | Purpose of Verification | Practical Considerations | Actions if Issues Are Found |
|---|---|---|---|
| Presence of EQ Mark | Confirms whether outer packaging marking as Excepted Quantities is required. | If the mark is missing, acceptance at CFS, warehouses, airlines, or shipping lines may be delayed or refused. | Verify required marks prior to in-gate and correct the outer packaging label accordingly. |
| Relation with Standard Dangerous Goods Labels | Confirms if the cargo can be handled using the EQ mark instead of standard labels. | Ensure there is no confusion whether the cargo is handled as regular dangerous goods or EQ. | Check SDS, UN number, quantity, and packaging conditions carefully. |
| Marking on Outer Packaging | Ensures EQ cargo can be identified at the outer packaging level. | Check marking not only on inner containers but also on outer packaging. | Verify photographs of packaging, packing lists, and CFS or airline warehouse requirements. |
| Marking Requirements for Air Transport | Additional markings or airline-specific conditions may be necessary for air transport. | Maritime-specific markings alone may not suffice for air carriage. | Confirm IATA regulations, airline differences, and airline-designated markings. |
| Consistency Between Mark and Actual Cargo | Confirms that the EQ mark corresponds to the actual quantity and packaging conditions. | Simply applying the mark without meeting conditions means the cargo cannot be treated as EQ. | Cross-check packing list, quantity of inner containers, total quantity per outer packaging, and triple packaging compliance. |
The size, shape, placement of the mark, and additional air transport requirements should be confirmed against the latest regulations and the acceptance conditions of shipping lines and airlines. Freight forwarders should obtain photos and packing details from the shipper and verify that the outer packaging marking is appropriate for Excepted Quantities.
Differences Between Maritime and Air Transport
Excepted Quantities have different handling requirements depending on whether they are transported by sea or air. Maritime transport follows the IMDG Code, while air transport is governed by the IATA Dangerous Goods Regulations.
| Category | Maritime Transport | Air Transport | Practical Notes |
|---|---|---|---|
| Primary Regulations | Confirmed mainly under the IMDG Code. | Confirmed mainly under the IATA Dangerous Goods Regulations. | Even for the same Excepted Quantities, conditions may differ between sea and air transport. |
| Main Verification Points | Check UN number, class, packing group, inner packaging quantity, total outer packaging quantity, EQ marking, and CFS acceptance conditions. | Check UN number, class, packing group, packing standards, quantity limits, EQ marking, airline variations, and courier restrictions. | Quantity limits and airline-specific differences are especially critical for air transport. |
| Acceptance Confirmation | Confirm acceptance with shipping lines, NVOCCs, CFS, dangerous goods warehouses, and consolidation agents. | Confirm acceptance with airlines, air freight forwarders, courier companies, and air cargo terminals. | Even if regulations allow acceptance, internal company policies may prohibit acceptance. |
| Practical Considerations | Although regulated as EQ, some CFS or consolidation agents may refuse to accept cargo. | Even minimal quantities may be rejected due to airline variations or courier restrictions. | For urgent cargo, confirm transport mode and acceptance conditions as early as possible. |
| Documentation and Markings | Verify EQ marking, in-gate conditions, acceptance for consolidation, and warehouse receiving conditions. | Verify air transport documentation, EQ marking, AWB entries, and airline-specific conditions. | Do not directly apply maritime information to air transport situations. |
Cargo accepted as Excepted Quantities under maritime rules may be rejected for air transport due to packing standards, quantity limits, or airline-specific restrictions. For urgent shipments or inspection samples, it is essential to confirm the transport mode and EQ conditions early in the process.
Relationship with SDS and Dangerous Goods Classification Documents
Whether cargo can be handled as Excepted Quantities should first be confirmed using the SDS and dangerous goods classification documents. Transport information sections of the SDS may include details such as the UN number, proper shipping name, hazard class, packing group, and transport precautions.
However, the mere presence of dangerous goods information on the SDS does not automatically mean the cargo qualifies as Excepted Quantities for transport. It is necessary to verify whether the item is eligible, whether quantity limits are met, whether triple packaging conditions are fulfilled, and whether the transport mode allows such classification.
Therefore, freight forwarders should start with the SDS but also confirm details with the shipper, manufacturer, dangerous goods specialists, shipping lines, airlines, and CFS. Especially if the SDS lists dangerous goods information but the shipper describes the cargo as "general cargo due to small quantities," it is important to check for supporting documentation.
Relationship with Non-Hazardous Cargo Certificates
Excepted Quantities should not be confused with non-hazardous cargo certificates. Excepted Quantities are dangerous goods handled under certain conditions in very small quantities. In contrast, a non-hazardous cargo certificate is a document that explains the cargo does not qualify as dangerous goods for transportation purposes.
| Category | Meaning | Points to Confirm | Action if Issues Arise |
|---|---|---|---|
| Excepted Quantities | Cargo classified as dangerous goods but in extremely small quantities meeting specific conditions. | Confirm quantities, packaging, markings, and acceptance conditions applicable to Excepted Quantities. | If conditions are not met, consider regular dangerous goods handling, Limited Quantities, or different transport modes. |
| Non-Hazardous Cargo | Cargo that does not qualify as dangerous goods for transportation purposes. | Verify the SDS, non-hazardous cargo certificate, component information, and transport information fields. | If the SDS or actual cargo markings indicate dangerous goods properties, re-check classification. |
| Cases Requiring Caution | When a non-hazardous cargo certificate is issued but the SDS includes UN numbers or hazard classes. | Do not rely solely on the document title; verify actual components, quantities, packaging, and transport conditions. | Confirm with the shipper or manufacturer to obtain accurate SDS or classification documentation. |
| Freight Forwarder’s Responsibility | Ensure consistency between the non-hazardous cargo certificate and the SDS. | Avoid assuming cargo is general cargo simply because a certificate is presented. | If discrepancies exist, do not proceed treating the cargo as non-hazardous; confirm classification basis. |
Even if the shipper provides a non-hazardous cargo certificate, if the SDS lists a UN number or hazard class, the freight forwarder should verify the details. It is important not to judge based on document titles alone but to confirm the actual components, quantities, packaging, and transport conditions.
Comparison Table of Freight Forwarder Involvement Scope
| Category | Supportive Actions | Actions to Avoid | Practical Response |
|---|---|---|---|
| Entry-Level Confirmation for Excepted Quantities | Check the SDS, UN number, proper shipping name, hazard class, and packing group. | Do not assume cargo is Excepted Quantities or non-dangerous based solely on descriptions like "micro quantity" or "sample." | Obtain the latest SDS, dangerous goods classification statement, and packing details. |
| Verification of Excepted Quantities Applicability | Confirm quantity of inner packaging, total quantity per outer packaging, triple packaging, markings, and applicable transport mode conditions. | Do not automatically classify cargo as Excepted Quantities simply because the overall outer packaging is small. | Check the Excepted Quantities conditions specific to each UN number. |
| Distinguishing Excepted Quantities and Limited Quantities | Separate whether the cargo qualifies as Excepted Quantities or Limited Quantities. | Avoid treating EQ and LQ as the same regulatory classification. | Verify quantity, markings, documents, and acceptance conditions individually. |
| Triple Packaging Confirmation | Inspect the condition of inner container, intermediate packaging, outer container, absorbent material, and cushioning materials. | Do not assume EQ packaging conditions are met simply because the cargo is in a small bottle. | Obtain photos of packaging, packaging specifications, and validation from dangerous goods specialists. |
| Marking and Labeling Verification | Confirm Excepted Quantities markings, outer packaging labels, and additional conditions for air transport. | Do not assume that all stakeholders will accept the cargo just because EQ marks are present. | Review photos of outer packaging and packaging condition, and confirm carrier acceptance criteria. |
| Cross-Checking with Non-Hazardous Cargo Certificate | Verify consistency between non-hazardous cargo certificate, SDS, actual markings on cargo, and packing details. | Do not disregard dangerous goods information in the SDS solely because a non-hazardous cargo certificate is present. | If discrepancies exist, confirm classification basis with the shipper or manufacturer. |
| Acceptance Confirmation for Maritime and Air Transport | Check acceptance conditions of shipping lines, airlines, CFS, courier companies, and consolidated cargo operators. | Do not assume all parties will accept the cargo just because it is regulated as Excepted Quantities. | Conduct prior confirmation with each stakeholder and document their responses and conditions. |
| Situations with Remaining Doubts | Do not proceed as regular cargo; confirm with shipper, manufacturer, and dangerous goods specialists. | Do not prioritize deadlines by proceeding with in-gate or air booking without clarity. | Obtain supporting documentation to conclusively determine whether the cargo is EQ, LQ, regular dangerous goods, or non-hazardous. |
Common Practical Issues
Excepted Quantities often become problematic with research samples, inspection samples, and small cargo shipments of chemicals. Shippers tend to assume "it’s fine because the amount is very small," but dangerous goods transport requires checking not only quantity but also item category, concentration, container, packaging, transport mode, and acceptance conditions.
| Case | Issues | Documents / Parties to Confirm | Recommended Approach |
|---|---|---|---|
| Shipper states “micro-quantity, so ordinary cargo” | Confuses Excepted Quantities with non-hazardous cargo. | SDS, UN number, quantity, packaging details, shipper/manufacturer | Clarify whether the cargo is Excepted Quantities, Limited Quantities, regular dangerous goods, or non-hazardous. |
| Confusion between EQ and LQ | Assumes Excepted Quantities and Limited Quantities fall under the same rules. | SDS, dangerous goods determination documents, quantity details, regulatory requirements | Verify whether it is Excepted Quantities or Limited Quantities and separately confirm marking, quantity, and documentation requirements. |
| Inner container capacity exceeds limits | Only the total outer packaging quantity is considered; restrictions on each inner container are overlooked. | Packing list, inner container capacity, outer container details, packing list | Confirm capacity and weight by each inner container as well as the total quantity per outer packaging. |
| Packaging does not use triple packaging | Attempting to ship only with small bottles or simple containers. | Packing photos, packaging specifications, shipper, packer, dangerous goods specialists | Check conditions for inner container, intermediate packaging, outer packaging, absorbents, and cushioning materials. |
| Excepted Quantities marks are missing | Insufficient confirmation of marking requirements or mistaken treatment as ordinary cargo. | Photos of outer packaging, packaging specifications, shipping line and airline requirements | Confirm required marks, placement, and package markings; correct them before in-gate. |
| Rejected by airlines or courier companies | Insufficient verification of airline differences, quantity limits, and packaging standards. | IATA regulations, airline responses, courier company feedback, packaging documents | Recheck air transport conditions and consider sea transport, alternative airlines, or different routes. |
| CFS or consolidation agents refuse acceptance | Even EQ shipments may face restrictions due to company rules or storage conditions. | Shipping lines, NVOCC, CFS, dangerous goods warehouses, consolidation agents | Confirm acceptance conditions in advance and consider alternative CFS, FCL shipment, or dangerous goods warehouse. |
| Non-hazardous cargo certificate conflicts with SDS | May be caused by outdated documents, SDS for different products, or incorrect dangerous goods determination. | Non-hazardous cargo certificate, SDS, manufacturer confirmation documents, actual package markings | Confirm with shipper or manufacturer and obtain correct SDS or determination documents. |
4-Column Verification Checklist
| Verification Occasion | Party to Confirm With | Verification Items | Action If Issues Are Found |
|---|---|---|---|
| When the shipper describes cargo as "trace amounts," "samples," or "for testing" | Shipper / Manufacturer | Check SDS, UN number, proper shipping name, hazard class, and packing group. | Do not treat as general cargo based only on product description; verify dangerous goods applicability. |
| When requested to arrange shipment as Excepted Quantities (EQ) | Shipper / Dangerous Goods Specialist | Confirm EQ applicability per UN number, quantity per inner packaging, total quantity per outer packaging, and triple packaging. | If conditions do not match, consider handling as Limited Quantities, regular dangerous goods, or arrange alternate transport mode. |
| When judgment is required between Excepted Quantities and Limited Quantities | Shipper / Manufacturer / Dangerous Goods Specialist | Verify whether cargo qualifies as Excepted Quantities or Limited Quantities based on quantity, marking, and documentation requirements. | Do not confuse the two systems; reconfirm using criteria for the relevant classification. |
| When checking packaging condition | Shipper / Packing Contractor / Warehouse | Confirm inner packaging, intermediate packaging, outer packaging, absorbent material, cushioning, and total quantity. | If packaging does not meet conditions, require repackaging or switch to regular dangerous goods handling. |
| When checking outer packaging markings | Shipper / Warehouse / CFS / Airline warehouse | Check for EQ mark, marking location, condition of outer packaging, and relation to regular labels. | Correct any marking deficiencies before cargo in-gate. |
| When arranging maritime transport | Shipping Line / NVOCC / CFS / Consolidator | Confirm EQ conditions per IMDG Code, CFS in-gate acceptance, LCL consolidation allowance, and shipping line acceptance rules. | If not accepted, consider different CFS, FCL shipment, dangerous goods warehouse, or different vessel service. |
| When arranging air transport | Airline / Air Freight Forwarder / Courier Company | Check IATA conditions, quantity limits, packaging standards, airline variations, and courier restrictions. | If not accepted, consider maritime transport, alternate airline, or different routing. |
| When a non-dangerous goods certificate is submitted | Shipper / Manufacturer | Verify consistency among non-dangerous goods certificate, SDS, actual cargo markings, and packaging details. | If inconsistencies arise, do not proceed as general cargo; reconfirm classification basis. |
Example 1: Case Where Research Samples Were Requested to Be Shipped as General Cargo
The cargo owner instructed that since these were only very small amounts of research samples, they could be shipped as general cargo by air in small chemical bottles.
However, upon reviewing the SDS, the UN number and hazard class were indicated, showing that the shipment qualifies as dangerous goods during transport. Labels such as research, testing, or sample do not imply exemption from dangerous goods classification.
The freight forwarder should verify the SDS, UN number, proper shipping name, hazard class, packing group, quantity of inner packaging, total quantity per outer packaging, and airline acceptance criteria.
If the shipment cannot be treated as Excepted Quantities, options such as Limited Quantities handling, full dangerous goods handling, alternative transport modes, repackaging, or adjusting the shipping schedule should be considered.
Example 2: Case of Incorrect Marking Due to Confusing EQ and LQ
This case involves a shipper who assumed that because the quantity was small, it could be handled like Limited Quantities and thus confused the marking and documentation requirements between Excepted Quantities and Limited Quantities.
Excepted Quantities and Limited Quantities both relate to small amounts of dangerous goods, but their regulatory systems, quantity limits, markings, and documentation requirements differ.
The freight forwarder should review the SDS, UN number, hazard class, packing group, quantity per inner packaging, total quantity per outer packaging, and triple packaging status to determine whether the cargo should be treated as EQ or LQ.
If the markings or packaging do not comply with the applicable system, repackaging, correction of markings, and document amendments should be completed before in-gate confirmation.
Example 3: Case of Insufficient Triple Packaging
This case involved a shipper attempting to send chemical samples simply placed in small bottles inside a cardboard box.
For Excepted Quantities, even small amounts require proper combinations of inner containers, intermediate packaging, and outer packaging, along with absorbents, cushioning, and airtight sealing. Simply placing the samples in small bottles may not meet the packing conditions required for Excepted Quantities.
The freight forwarder should verify package photos, inner container volume, intermediate packaging, absorbents, outer packaging, and outer markings.
If conditions are not met, options include repacking by a dangerous goods specialist, treating the cargo as regular dangerous goods, or considering alternative transport modes.
Example 4: Case Where Non-Hazardous Certificate Conflicted with SDS
This case involves a situation where the shipper submitted a non-hazardous certificate, while Section 14 of the SDS included a UN number and hazard class.
Having a non-hazardous certificate does not allow ignoring dangerous goods information on the SDS and processing the cargo as general cargo. Possible reasons include outdated certificates, SDS for different products, formulation changes, or misclassification.
The freight forwarder should verify with the shipper and manufacturer, cross-checking the relevant product, the latest SDS, the non-hazardous certificate, dangerous goods classification documents, and actual cargo markings.
Until the discrepancy is resolved, it is standard practice not to finalize whether the cargo should be handled as general cargo, Excepted Quantities, Limited Quantities, or regular dangerous goods, and to hold arrangements accordingly.
Points to Confirm with the Shipper
For cargo that may be handled as Excepted Quantities, the freight forwarder should confirm the following information with the shipper at an early stage.
- Whether the latest SDS is available.
- Whether the UN number, proper shipping name, hazard class, and packing group have been confirmed.
- Whether the UN number and item can be handled as Excepted Quantities.
- Whether the capacity and weight per inner packaging meet the conditions.
- Whether the total quantity per outer packaging is within the limits.
- Whether triple packaging is required: inner packaging, intermediate packaging, and outer packaging.
- Whether absorbents, cushioning materials, sealed bags, or partitions are needed.
- Whether an EQ mark or outer packaging marking is required.
- Whether transport will be arranged by sea or air.
- If by air, whether the airline or courier company can accept the shipment.
- Whether CFS, consolidation agents, dangerous goods warehouses, and shipping lines can accept it.
- Whether the cargo is correctly classified as Excepted Quantities, Limited Quantities, regular dangerous goods, or non-hazardous cargo.
- If a non-hazardous certificate is available, whether it is consistent with the SDS and actual markings.
Common Misconceptions
With Excepted Quantities, terms like “micro-quantity,” “sample,” or “for research use” may lead to overlooking proper dangerous goods confirmation. The following misconceptions can easily result in refusal of in-gate acceptance or loading refusal.
| Misconception | Practical Consideration | What Should Be Confirmed |
|---|---|---|
| Excepted Quantities are not dangerous goods | Excepted Quantities are handled under the assumption that they are dangerous goods, subject to specific conditions. | Confirm SDS, UN number, hazard class, and Excepted Quantities conditions. |
| Samples automatically qualify as Excepted Quantities | Even if it is a sample, UN number, hazard class, packing group, quantity, and packaging conditions must be confirmed. | Check the quantity of inner packaging, total quantity per outer packaging, triple packaging, and mode of transport. |
| EQ and Limited Quantities mean the same thing | Excepted Quantities and Limited Quantities are separate regulatory schemes. | Confirm quantity limits, marking, documentation requirements, and acceptance conditions for each scheme. |
| Having an EQ mark guarantees acceptance | The presence of an EQ mark alone is insufficient; packaging requirements, quantity limits, acceptance conditions, and mode of transport must be checked. | Verify outer packaging markings, triple packaging, quantities, and carrier acceptance criteria. |
| If quantity is small, a non-hazardous certificate is sufficient | Excepted Quantities are classified as dangerous goods and differ in meaning from a non-hazardous cargo certificate. | Cross-check SDS, non-hazardous cargo certificates, dangerous goods determination documents, and actual cargo labeling. |
| If EQ applies in maritime transport, it applies automatically for air transport | For air transport, IATA conditions, airline-specific rules, quantity limits, and packaging standards must be confirmed separately. | Confirm airline, courier company, and air cargo terminal conditions. |
| If the entire outer package is small, it can be treated as EQ | If the quantity per inner container or total quantity per outer packaging exceeds limits, EQ classification cannot apply. | Check inner packaging quantities, total outer packaging quantity, and packing details. |
| If the shipping line accepts the cargo, CFS or consolidation agents will also accept it | Acceptance decisions by shipping lines, CFS, dangerous goods warehouses, and consolidation agents are separate. | Confirm CFS in-gate conditions, LCL consolidation eligibility, and dangerous goods warehouse rules. |
Practical Considerations
- Excepted Quantities are not general cargo but should be treated as a category within dangerous goods.
- Do not confuse Excepted Quantities with Limited Quantities.
- Confirm the UN number, proper shipping name, hazard class, and packing group.
- Verify the capacity and weight per inner packaging and the total quantity per outer packaging.
- Check for triple packaging: inner packaging, intermediate packaging, and outer packaging.
- Confirm the requirement for absorbents, cushioning materials, sealed bags, and dividers.
- Determine whether EQ markings and outer packaging labels are necessary.
- Review requirements with the understanding that conditions differ between maritime and air transport.
- Pre-confirm acceptance with airlines, courier companies, CFS, consolidators, and shipping lines.
- Do not rely solely on the SDS; cross-check packaging condition, quantity, markings, and transport mode.
- Verify there are no contradictions between a non-hazardous cargo certificate and the SDS.
- If any doubts arise, confirm details with the shipper, manufacturer, or dangerous goods specialists.
Summary
Excepted Quantities refer to substances classified as dangerous goods that may be handled in extremely small quantities under specified regulatory conditions. Excepted Quantities are not general cargo but must be managed on the basis that they are dangerous goods.
For Excepted Quantities, it is necessary to verify the UN number, proper shipping name, hazard class, packing group, quantity per inner packaging, total quantity per outer packaging, triple packaging, EQ markings, and transport mode-specific conditions. This classification is separate from Limited Quantities, and EQ and LQ should not be treated as synonymous.
Freight forwarders should avoid proceeding based solely on explanations like "it’s a micro quantity, so it’s fine" or "it’s a sample, so it is general cargo." Instead, they should promptly confirm the SDS, dangerous goods classification document, packing details, quantities, markings, and acceptance conditions of CFS, shipping lines, and airlines to prevent in-gate refusals, shipment delays, or air carriage rejections.
The key point of this article is that Excepted Quantities should not be treated as non-hazardous small shipments. Rather, they should be handled in practice as dangerous goods by confirming EQ conditions, triple packaging, markings, transport mode restrictions, and acceptance criteria.
