IATA Dangerous Goods Regulations
Interlink編集部What Is the IATA Dangerous Goods Regulations?
The IATA Dangerous Goods Regulations (DGR) are operational rules that specify classification, packaging, labeling, marking, quantity limits, and documentation requirements to safely transport dangerous goods by air.
Commonly referred to as IATA DGR in English, these regulations are essential in air cargo operations.
For freight forwarders, the IATA DGR is key for quotations, bookings, airline acceptance confirmations, dangerous goods declarations, packaging standards, labeling, marking, quantity restrictions, and determining whether cargo can be carried on passenger aircraft.
Cargo accepted for maritime transport may be prohibited or restricted for air carriage. Therefore, when shipping cargo that could contain dangerous goods by air, checks based on the IATA DGR should be conducted from the quotation stage onward.
Scope Covered in This Article
| Item | Content Covered in This Article | Content Covered in Other Articles |
|---|---|---|
| Basics of the IATA Dangerous Goods Regulations | Organized as the practical rules freight forwarders should confirm when handling air dangerous goods. | Detailed clause-by-clause commentary on IATA DGR and qualification systems are covered in specialized training and official regulations. |
| Key Checks for Air Dangerous Goods | Covers SDS, UN number, proper shipping name, hazard class, packaging group, packing instructions, and quantity limitations. | The detailed chemical classification itself is handled in the SDS, GHS Labeling, and Dangerous Goods Classification articles. |
| Differences from the IMDG Code | Focuses on differences in packaging, quantity limits, labeling, and acceptance between sea and air transportation. | Detailed marine dangerous goods transport is covered in the IMDG Code article. |
| Relationship to SDS | How to connect SDS transport information fields to confirming air dangerous goods. | Creation methods and detailed explanation of each SDS section are covered in the SDS article. |
| Relationship to Dangerous Goods Declarations | Cross-checking the air dangerous goods declaration, SDS, actual goods, and external markings. | Detailed descriptions and formats of dangerous goods declarations are covered in the Dangerous Goods Declaration article. |
| Lithium Battery Cargo | Practical confirmation procedures for lithium-ion batteries, lithium metal batteries, standalone, contained-in, and embedded types. | Detailed packing instructions and quantity limits for lithium batteries should be confirmed with the latest regulations and airline conditions. |
| Passenger Aircraft vs. Cargo Aircraft Only | Practical checks on Passenger Aircraft, Cargo Aircraft Only, quantity limits, and packaging conditions. | Restrictions by airline, aircraft type, and flight are covered in the Airline Acceptance Conditions article. |
| Troubleshooting | Procedures for handling non-compliance discovered during budgeting, before pickup, after pickup, after airport delivery, or just before loading. | Cost responsibility, damage claims, and delay liability are covered in the Cargo Accident & Cost Responsibility article. |
Overview of IATA Dangerous Goods Regulations
The IATA Dangerous Goods Regulations serve as the primary practical guidelines for stakeholders transporting dangerous goods by air.
These regulations cover the classification of dangerous goods, UN numbers, proper shipping names, hazard classes, subsidiary risks, container types, packaging standards, quantity limits, labels, markings, dangerous goods declarations, and restrictions specific to individual airlines.
Compared to maritime transport, air transport involves limited cargo space and additional risks such as pressure changes, temperature fluctuations, vibration, and restricted response options in case of fire. Consequently, dangerous goods transported by air are generally subject to stricter controls than those transported by sea. Therefore, freight forwarders need to verify dangerous goods information from the quotation stage onward.
Key Items to Check for Air Dangerous Goods
For air dangerous goods, having a UN number on the SDS alone is not sufficient. You must confirm packaging standards, quantity limits, loading conditions, and whether the airline will accept the shipment. Without these confirmations, shipments risk being stopped after pick-up or at airport in-gate.
| Check Items | What to Confirm | Consequences of Inadequate Confirmation | Practical Measures |
|---|---|---|---|
| Dangerous Goods Classification | Verify if the cargo qualifies as dangerous goods under air transport regulations. | Shipment may be processed as regular cargo but stopped upon airline inspection. | Cross-check SDS, GHS labeling, product specification sheets, and manufacturer documentation. |
| UN Number | Confirm the applicable UN number for transport as dangerous goods. | The airline cannot determine acceptance without this information. | Review the transportation section of the SDS and the dangerous goods declaration. |
| Proper Shipping Name | Check that the Proper Shipping Name is accurately stated. | Mismatch occurs with dangerous goods declaration or labels. | Confirm the UN number and Proper Shipping Name together. |
| Dangerous Goods Class and Subsidiary Risks | Confirm both primary and subsidiary hazards are identified. | Cannot verify labeling, segregation, or acceptance conditions. | Compare dangerous goods declaration, SDS, and airline requirements. |
| Packaging Group | Determine if packaging group requirements apply to the cargo. | Packaging standards and quantity restrictions cannot be confirmed. | Review packaging requirements and quantity limits together. |
| Packaging Standards | Ensure the packaging meets air transport standards. | May require repacking or face acceptance denial after airport in-gate. | Avoid using packaging designed for maritime transport as-is. |
| Quantity Limits | Confirm quantity limits per package, per shipment, and loading limits are met. | Shipment may not be loaded on the reserved flight. | Check passenger aircraft acceptance and cargo-only aircraft conditions. |
| Passenger vs. Cargo Aircraft | Verify if the shipment can be carried on passenger aircraft or is restricted to cargo aircraft only. | Cannot be loaded if booked on a passenger flight when cargo aircraft only. | Confirm whether shipment is allowed on Passenger Aircraft or Cargo Aircraft Only. |
| Dangerous Goods Declaration | Check if a declaration is required, and that its content matches the SDS and physical cargo labeling. | Shipment may be held during airline document verification. | Cross-check SDS, invoice, packing list, and cargo photos. |
| Airline and Courier Company Restrictions | Verify any company-specific acceptance conditions, prohibited items, or additional requirements. | Although regulations permit, the actual carrier may refuse acceptance. | Confirm acceptance status with the carrier before quotation and collection. |
Differences from the IMDG Code
The IMDG Code governs the transport of dangerous goods by sea, while the IATA Dangerous Goods Regulations apply to air transport.
Even for identical cargo, packaging, quantity limits, labeling, and acceptance criteria may differ between sea and air transport. Cargo accepted for sea transport cannot automatically be switched to air transport as is.
| Comparison Item | IMDG Code | IATA Dangerous Goods Regulations | Notes for Freight Forwarders in Practice |
|---|---|---|---|
| Transport Mode | Sea transport. | Air transport. | Dangerous goods classification and acceptance must be reassessed when changing transport modes. |
| Transport Environment | Review assuming ship, container, CFS, and port storage conditions. | Review assuming aircraft, airport warehouse, pressure changes, temperature variations, and aircraft space constraints. | Fire, pressure, and temperature restrictions may be stricter in air transport. |
| Packing Standards | Check packaging standards suitable for sea transport. | Check packaging standards suitable for air transport. | Packaging acceptable by sea standards may be prohibited in air transport. |
| Quantity Restrictions | Confirm container loading and sea transport-specific restrictions. | Confirm air transport-specific quantity limits such as per package, per shipment, passenger aircraft, and cargo-only aircraft. | Even slight changes in quantity can affect acceptance. |
| Labels and Markings | Verify sea dangerous goods labels, UN numbers, and marine pollutant markings. | Verify air dangerous goods labels, Cargo Aircraft Only markings, lithium battery-related labels, and others. | Sea labels alone may be insufficient for air transport requirements. |
| Documentation | Focus on sea dangerous goods declarations and confirmations from shipping lines, NVOCCs, and CFS. | Focus on air dangerous goods declarations, airline acceptance confirmations, and airport warehouse checks. | Screening by the airline’s documentation review may cause delays. |
| Acceptance Criteria | Depends on shipping line, NVOCC, CFS, and port regulations. | Depends on airline, flight, aircraft type, passenger vs. cargo aircraft distinction, and courier company restrictions. | Even if regulations permit, the airline may refuse acceptance. |
| Lead Time | Watch for dangerous goods verification and CFS in-gate deadlines. | Longer than usual due to dangerous goods checks, prior airline approval, document verification, and warehouse in-gate conditions. | Dangerous goods information must be confirmed from the quotation stage. |
Notably, cargo such as lithium batteries, aerosols, paints, adhesives, fragrances, alcohol-containing goods, reagents, and pharmaceuticals may be relatively easy to arrange for sea transport but face stringent restrictions in air transport.
Relationship with SDS
The transport information section of the SDS may include details such as the UN number, official transport name, hazard class, and packaging group. Freight forwarders use the SDS as a basis to verify whether the cargo qualifies as dangerous goods for air transport.
However, SDSs are often focused primarily on maritime transport, and the conditions for air transport may not be fully described. Additionally, even if the SDS indicates non-dangerous status, airlines or courier companies may request further confirmation.
| SDS Status | Practical Considerations | Actions | Parties to Confirm With |
|---|---|---|---|
| SDS includes UN number and class | Does not necessarily mean acceptance for air transport as is. | Check packaging standards, quantity limits, passenger vs. cargo aircraft distinction, and airline acceptance per IATA DGR. | Shipper, Manufacturer, Airline |
| SDS is primarily focused on maritime transport | Air transport conditions may be insufficiently defined. | Obtain additional confirmation of classification basis, packaging standards, and quantity limits for air transport. | Shipper, Manufacturer, Airline, Dangerous Goods Specialist |
| SDS indicates non-dangerous goods | Airlines or courier companies may request additional verification of product name, components, and usage. | Obtain non-dangerous goods certificates, manufacturer’s confirmation letters, and product specifications. | Shipper, Manufacturer, Airline, Courier Company |
| Product name on SDS does not match invoice | There may be a risk of using an SDS for a different product. | Cross-check product name, model number, manufacturer name, and components. | Shipper, Manufacturer |
| Transport information section of SDS is blank | Cannot judge air dangerous goods status. | Obtain manufacturer’s confirmation, dangerous goods assessment documents, or non-dangerous goods certificates. | Shipper, Manufacturer, Dangerous Goods Specialist |
| SDS and physical labels do not match | Could be due to outdated SDS, SDS for a different product, or labeling errors. | Compare photos of the physical product, product model number, and latest SDS. | Shipper, Manufacturer, Warehouse |
Relationship with Dangerous Goods Declaration
In air dangerous goods shipments, a dangerous goods declaration may be required.
The dangerous goods declaration includes the UN number, proper shipping name, hazard class, subsidiary risks, packing group, quantity, packaging, labels, and emergency contact details.
Freight forwarders need to verify that the dangerous goods declaration matches the SDS, invoice, packing list, actual labels, and exterior markings. Discrepancies in documentation could lead to airline acceptance refusal, cargo loading denial, or shipment delays.
When SDS and Dangerous Goods Declaration Contradict
If the content of the SDS and the dangerous goods declaration do not match, the freight forwarder should not submit them as-is to the airline.
| Example of Contradiction | Issue | Response Approach | Documents and Contacts to Confirm |
|---|---|---|---|
| Different UN numbers between SDS and declaration | Could indicate different cargo, different classification, or outdated documents. | Clarify which classification is correct for transport. | Shipper, manufacturer, latest SDS, dangerous goods classification documents |
| SDS lists sea transport details, declaration lists air dangerous goods | Insufficient basis for air transport conditions may exist. | Confirm classification basis, packing standards, and quantity limits for air transport. | Shipper, manufacturer, airline, dangerous goods specialists |
| SDS classifies as non-dangerous, declaration treats as dangerous goods | Lack of document consistency may cause airline refusal. | Obtain manufacturer confirmation or classification documents and confirm which classification to proceed with. | Shipper, manufacturer, airline |
| Quantity or packaging description in declaration differs from actual cargo | Packing standards and quantity limits cannot be verified. | Compare packing list, photos of cargo, and packaging details and correct the declaration. | Shipper, warehouse, packer |
| Mismatch in dangerous goods class or subsidiary risks | Determining required labels, segregation, and handling conditions is impossible. | Cross-check SDS, declaration, and airline conditions. | Shipper, manufacturer, airline |
| Missing container grading or packing standard descriptions | Cannot judge if packing is suitable for air transport. | Confirm packing instructions, packing specifications, and quantity limits. | Shipper, packer, dangerous goods specialists |
In cases of contradiction, the SDS, dangerous goods declaration, physical cargo, and manufacturer confirmation documents should be cross-checked to finalize the classification and conditions for air transport before proceeding with arrangements.
Passenger Aircraft Carriage and Cargo Aircraft Only
In air dangerous goods transport, some cargo can be carried on passenger aircraft, while others are restricted to cargo aircraft only.
When cargo is designated as Cargo Aircraft Only, this restriction must be indicated, which may limit the available flights and airlines. Failure to confirm this may result in the cargo not being accepted on the booked flight, leading to route changes, delays, or additional costs.
| Decision Criteria | What to Confirm | Practical Notes | Actions if Issues Arise |
|---|---|---|---|
| Dangerous Goods Class | Confirm whether the class and conditions allow carriage on passenger aircraft. | Check not only the class but also quantity and packaging conditions. | If carriage on passenger aircraft is not allowed, consider cargo aircraft flights or alternative transport modes. |
| Quantity | Verify quantity limits per package, per shipment, or per condition relevant to passenger aircraft carriage. | Changes in quantity may affect passenger aircraft carriage eligibility or declaration requirements. | Consider splitting quantities, repackaging, or changing flights. |
| Container Grade & Packaging Standards | Ensure compliance with packaging standards for air transport. | Packaging suitable for sea transport may be insufficient for air transport. | Consider repackaging or arranging for professional hazardous goods packaging. |
| Packaging Form | Confirm whether the cargo is standalone dangerous goods, packed with equipment, incorporated into equipment, or qualifies for limited or excepted quantity status. | Handling can differ by packaging form even for the same item. | Confirm the packaging form with the shipper and revise the declaration if necessary. |
| Airline Acceptance Conditions | Check restrictions set by airline, flight, aircraft type, transit points, and courier companies. | Even if regulations allow carriage, the carrier may refuse acceptance. | Consider alternative airlines, routes, or cargo aircraft flights. |
| Labels and Documentation | Confirm Cargo Aircraft Only marks, dangerous goods declarations, labels, and markings. | Missing or incorrect marks or documents can lead to refusal of acceptance. | Correct and confirm with the airline prior to in-gate. |
Whether cargo can be carried on passenger aircraft is not determined solely by its status as dangerous goods. It requires a combined check of dangerous goods class, quantity, packaging standards, packaging form, and airline acceptance conditions.
Precautions for Lithium Battery Cargo
Lithium batteries require particular attention when handled as air dangerous goods.
The handling of lithium batteries varies significantly depending on battery type, Wh rating, lithium content, quantity, packaging condition, whether installed in equipment, and the airline’s acceptance criteria.
Since specific numeric thresholds and packaging instructions may be revised, it is essential in practice to always verify the latest regulations, airline conditions, and shipper-provided documents.
| Battery Type / Form | Typical Classification | Items to Confirm | Practical Considerations |
|---|---|---|---|
| Standalone Lithium-Ion Battery | Cargo consisting solely of batteries not installed in equipment. | Confirm UN number, Wh rating, quantity, charge state, packaging standards, passenger aircraft carriage availability, and airline acceptance criteria. | Some airlines may impose their own acceptance restrictions. |
| Lithium-Ion Battery Included with Equipment (Packed Together) | Batteries packed in the same shipment as equipment but not installed within the equipment. | Check the relationship between battery and equipment, quantity, packaging, short-circuit prevention, labeling, and documentation requirements. | Ensure distinction between packed together and installed batteries. |
| Lithium-Ion Battery Installed in Equipment | Batteries physically installed inside the equipment. | Verify battery fixed status inside equipment, quantity, Wh rating, packaging, labeling, and documentation needs. | Confirm equipment model number, battery specifications, and quantity. |
| Standalone Lithium Metal Battery | Cargo consisting solely of lithium metal batteries. | Check lithium content, quantity, packaging standards, passenger aircraft carriage availability, and airline acceptance criteria. | Acceptance may be subject to strict verification. |
| Lithium Metal Battery Included with Equipment (Packed Together) | Lithium metal batteries packed in the same shipment as equipment but not installed. | Confirm battery quantity, lithium content, relationship to equipment, short-circuit prevention, and labeling requirements. | Clearly distinguish packed together from installed batteries. |
| Lithium Metal Battery Installed in Equipment | Lithium metal batteries installed within equipment. | Verify installation status, battery quantity, packaging, labeling, and documentation requirements. | Confirm details with manufacturer documents or product specifications. |
For lithium batteries, the distinctions between “standalone battery,” “packed with equipment,” and “installed in equipment” are critical. Even if the shipper describes the cargo as “products containing batteries,” the air transport conditions will differ depending on whether it is standalone batteries, batteries packed together with equipment, or batteries installed inside equipment.
Summary of UN Numbers for Lithium Batteries
Lithium battery cargo is categorized into different UN numbers depending on the battery type and form.
| Category | Typical UN Number | Practical Considerations | Documents to Check |
|---|---|---|---|
| Lithium-ion Batteries (Stand-alone) | UN3480 | Handled as stand-alone batteries. It is especially important to verify airline acceptance conditions and whether carriage on passenger aircraft is permitted. | SDS, battery specifications, UN38.3-related documents, airline responses |
| Lithium-ion Batteries Packed with or Installed in Equipment | UN3481 | Check the relationship with the equipment, whether the batteries are packed with or installed in the equipment, quantity, and packaging conditions. | Product specifications, packing list, battery specifications, photos |
| Lithium Metal Batteries (Stand-alone) | UN3090 | Confirm lithium content, quantity, packaging standards, and acceptance conditions. | SDS, battery specifications, manufacturer documents, airline responses |
| Lithium Metal Batteries Packed with or Installed in Equipment | UN3091 | Verify relationship with the equipment, battery quantity, packaging, and marking requirements. | Product specifications, battery specifications, packing list, photos |
Decisions should not be based on the UN number alone. Battery type, form, Wh rating or lithium content, quantity, packaging, and airline conditions must be considered together.
Limited Quantities, Exceptions, and Quantity Restrictions
In air dangerous goods transport, limited quantities, exceptions, and quantity restrictions may apply.
However, these do not mean that small quantities can be treated as regular cargo without precautions. Even for small quantities in air transport, packaging, labeling, documentation, and acceptance conditions should be confirmed.
| Category | Practical Meaning | Points to Note | Parties to Confirm With |
|---|---|---|---|
| Limited Quantity | A concept treating dangerous goods that meet specific conditions as limited quantities. | Quantity, packaging, labeling, and air transport acceptability should be checked. | Shipper, airline, dangerous goods specialist |
| Excepted Quantity | A category allowing simplified handling under certain conditions for very small quantities of dangerous goods. | This does not mean the cargo becomes regular goods; conditions must be confirmed. | Shipper, airline, courier company |
| Small Samples | Cargo shipped in small quantities for research, testing, or sales samples. | Not determined by use or quantity, but must confirm components, hazards, and transport regulations treatment. | Shipper, manufacturer, airline |
| Airline-Specific Conditions | Even if allowed by regulations, airlines or courier companies may impose their own restrictions. | Acceptance or refusal should be checked with the carrier in advance. | Airline, courier company, agent |
Details regarding limited quantities and exceptions depend on the cargo content, quantity, packaging, transport mode, and airline conditions. Freight forwarders should not rely solely on the shipper’s explanation that "small quantity means no problem."
Comparison Table of Freight Forwarder Involvement Scope
| Situation | Supportable Actions | Actions to Avoid Definitive Judgments | Practical Handling |
|---|---|---|---|
| When confirming the possibility of dangerous goods at the quotation stage | Request submission of SDS, product name, composition, quantity, and packaging details. | Avoid concluding goods are regular cargo based only on product name or small quantity explanations. | If there is a possibility of dangerous goods, withhold quotation terms and continue verification. |
| When receiving an SDS | Check product name, latest version, transport information section, UN number, and class. | Do not assume transport by air is possible just because an SDS is provided. | Verify packaging standards, quantity restrictions, and airline conditions under IATA DGR. |
| When switching from maritime to air transport | Reconfirm dangerous goods conditions applicable for air transport. | Do not judge acceptance by air just because it was accepted for sea transport. | Reconfirm acceptance eligibility with the airline and air agent. |
| When receiving a dangerous goods declaration | Check consistency between SDS, invoice, packing list, and actual cargo markings. | Do not assume content verification is unnecessary simply because a declaration was submitted. | Correct any discrepancies prior to submission. |
| When receiving lithium battery cargo | Confirm battery type, UN number, Wh rating, lithium content, and whether included or installed. | Do not make handling judgments based only on “battery-contained product” descriptions. | Check product specifications, battery documentation, and airline conditions. |
| When confirming passenger aircraft carriage eligibility | Confirm if shipment is allowed on Passenger Aircraft or only Cargo Aircraft. | Do not assume dangerous goods accepted will be carried on regular passenger flights. | Check flight, aircraft type, airline conditions, and quantity restrictions. |
| Before airport in-gate | Verify labels, markings, dangerous goods declaration, and packaging condition. | Do not assume deficiencies can be easily corrected at the warehouse. | Make corrections before in-gate and reconfirm with the airline if necessary. |
| When rejection or loading refusal occurs | Organize reasons for refusal, possibilities for re-application, alternate flights, freighter-only flights, or switching to sea transport. | Do not make immediate judgments on cost responsibility or liability. | Record causes, circumstances, and responses from all involved parties. |
Common Practical Issues
| Case | Key Issue | Documents/Parties to Check | Recommended Actions |
|---|---|---|---|
| Booking air freight using sea freight assumptions | Cargo accepted by sea may be rejected or conditionally accepted by air carriers. | SDS, UN number, airline response | Verify packaging standards, quantity limits, and airline conditions specific to air transport. |
| SDS lacks sufficient information on air transport conditions | Cannot determine packaging requirements or acceptance criteria for air transport. | SDS, manufacturer’s confirmation, dangerous goods classification materials | Request additional confirmation from the shipper, manufacturer, airline, or dangerous goods specialists. |
| Insufficient information on UN number, class, or container grade | Classification of dangerous goods and acceptance conditions cannot be confirmed. | SDS, dangerous goods classification materials, manufacturer’s confirmation | Obtain necessary documents before confirming with the airline. |
| Inconsistency between dangerous goods declaration and SDS | High risk of rejection during airline document review. | Dangerous goods declaration, SDS, invoice, photos of cargo | Cross-check UN number, proper shipping name, class, quantity, and packaging; correct and resubmit as needed. |
| Insufficient confirmation of lithium battery type and capacity | Cannot determine UN number, packaging standards, passenger aircraft carriage eligibility, or airline acceptance conditions. | Battery specification sheet, Wh rating, lithium content, product specifications | Confirm whether batteries are standalone, packed with equipment, or installed in equipment. |
| Overlooking airline or courier company-specific restrictions | Even if regulations allow, the actual carrier may refuse acceptance. | Airline conditions, courier company conditions, agent responses | Confirm acceptance with the carrier before quotation and pickup arrangements. |
| Rejection due to defective exterior labels or markings | May require relabeling, repackaging, or return after airport gate-in. | Photos of exterior packaging, dangerous goods declaration, labels, CAO markings | Confirm labels, UN numbers, and markings before cargo gate-in. |
| Booking normal flights for cargo prohibited on passenger aircraft | Cargo cannot be loaded on the booked flight, causing rerouting or shipment delays. | Airline response, flight details, dangerous goods declaration | Confirm passenger aircraft carriage eligibility, freighter-only conditions, alternative flights, and any additional costs. |
Response According to Discovery Timing
Responses to discrepancies in air dangerous goods vary depending on when they are discovered.
| Discovery Timing | Common Issues | Response Approach | Information to Convey to the Shipper |
|---|---|---|---|
| Quotation Stage | Insufficient dangerous goods information prevents finalizing the quote and route. | Obtain SDS, UN number, dangerous goods class, quantity, and packaging details before finalizing quotation conditions. | Explain that quotes and flight confirmations cannot be completed without dangerous goods information. |
| Before Pickup | Defects found in dangerous goods declaration, labels, or packaging. | Correct issues before pickup, then reconfirm airline acceptance. | Inform that pickup and in-gate may be put on hold until corrections are completed. |
| After Pickup | Discrepancies found in labels or documents at the warehouse or cargo shed. | Check the possibility of document replacement, re-labeling, repackaging, return shipment, and storage charges. | Explain the potential additional costs and schedule impacts. |
| After Airport In-gate | Rejected acceptance or refusal to load confirmed by the airline. | Consider alternative flights, cargo-only flights, different airlines, or switching to maritime transport. | Explain the reasons the cargo cannot be loaded on the scheduled flight and propose alternatives. |
| Just Before Loading | Unable to load due to aircraft, flight, or acceptance conditions. | Arrange delay notifications, alternative routes, additional charges, storage costs, and explanations to the shipper. | Provide information distinguishing confirmed details from those still uncertain. |
4-Column Judgment Checklist
| Verification Scenario | Party to Confirm With | Items to Confirm | Actions if Issues Are Found |
|---|---|---|---|
| When receiving a quote request for air transport | Shipper / Manufacturer | Check SDS, product name, components, quantity, packaging, and dangerous goods applicability. | If dangerous goods information is insufficient, place the quote conditions on hold and request submission of relevant documents. |
| If the SDS lists a UN number | Shipper / Airline / Dangerous Goods Specialist | Confirm official transport name, hazard class, container type, packing standards, and quantity limits. | Confirm acceptance with the airline and avoid proceeding as general cargo. |
| If the SDS primarily references maritime transport | Shipper / Manufacturer / Airline | Verify classification basis for air transport, packing conditions, and quantity limits. | Hold booking and collection until air transport conditions are confirmed. |
| When receiving a dangerous goods declaration | Shipper / Dangerous Goods Declarant / Airline | Cross-check consistency with SDS, invoice, packing list, and physical labels. | If discrepancies exist, request correction before submission. |
| When handling lithium battery cargo | Shipper / Manufacturer / Airline | Check battery type, UN number, watt-hour (Wh) rating, lithium content, and whether batteries are standalone, packed with equipment, or installed. | Confirm airline conditions and consider separate shipments or transport modes if necessary. |
| When confirming passenger aircraft carriage eligibility | Airline / Air Agent | Confirm whether transport is allowed on Passenger Aircraft or Cargo Aircraft Only, quantity limits, and flight/aircraft conditions. | If carriage is prohibited on regular flights, consider cargo flights, alternative airlines, or different routes. |
| Final check before airport in-gate | Warehouse / Delivery Company / Airline | Verify labels, markings, dangerous goods declarations, packaging condition, and in-gate acceptance conditions. | If deficiencies are found, correct them before in-gate and confirm again. |
| When acceptance is rejected or carriage is refused | Airline / Shipper / Warehouse / Dangerous Goods Specialist | Confirm rejection reasons, possibility of resubmission, alternative flights, cargo-only flights, or switch to sea transport. | Organize schedule impacts, additional costs, and alternatives to explain to the shipper. |
Case Example 1: Attempt to Switch Paint from Sea to Air Transport
This case involves a shipper who requested to switch paint, originally scheduled for sea transport, to air transport to shorten the delivery lead time.
Even if the shipping line confirmed acceptance for sea transport, it is necessary to reconfirm packaging standards for flammable liquids, quantity restrictions, passenger aircraft carriage restrictions, and airline acceptance conditions for air transport.
The freight forwarder checks the SDS transport information section, UN number, dangerous goods class, packaging group, quantity, packaging type, and the need for a dangerous goods declaration before inquiring with the airline about acceptance.
If air transport is not accepted or limited to cargo aircraft only, the freight forwarder proposes options to the shipper such as using cargo-only flights, another airline, maintaining sea transport, splitting quantities, or delaying shipment.
Example 2: Case Where the Form of Lithium Battery-Containing Products Was Unclear
A quote request for air transport was received from a shipper describing the cargo only as a "lithium battery-containing product."
With this description alone, it is impossible to determine whether it is a lithium-ion battery or a lithium metal battery, whether the battery is standalone, packed with equipment, or installed in equipment, or which UN number among UN3480, UN3481, UN3090, or UN3091 applies.
The freight forwarder should confirm the product specifications, battery specifications, Wh rating, lithium content, quantity, packaging condition, short-circuit prevention measures, and airline acceptance conditions.
If a quotation and collection are processed as general cargo before these confirmations, there is a risk that after airport in-gate, acceptance could be refused, requiring repacking, return shipment, or shipment delays.
Example 3: Case Where the UN Number on the Dangerous Goods Declaration Differs from the SDS
There is a case where the shipper has submitted a dangerous goods declaration, but the UN number listed in the transport information section of the SDS does not match the UN number on the declaration.
Submitting such documents to the airline may lead to delays during document verification. Possible causes include an SDS for a different product, an outdated SDS, classification errors, or mistakes in preparing the declaration.
The freight forwarder should confirm with the shipper or manufacturer to determine the correct product, the latest version of the SDS, the accurate UN number, the official transport name, the hazard class, and the packaging group.
After corrections, the freight forwarder should re-check the dangerous goods declaration, SDS, invoice, packing list, and physical labeling before submitting the documents to the airline.
Example 4: Case of Booking on a Passenger Flight Cargo That Cannot Be Carried on Passenger Aircraft
This is a case where cargo was booked on a passenger flight assuming it could be accepted as dangerous goods, but airline confirmation revealed it was classified as Cargo Aircraft Only, making it ineligible for transport on the booked passenger flight.
For air dangerous goods, it is essential not only to confirm whether the cargo can be accepted as dangerous goods, but also whether it can be carried on a passenger aircraft, if it is restricted to cargo aircraft only, and whether it meets quantity limitations.
In such cases, the freight forwarder considers options such as cargo-only flights, alternative airlines, different routes, splitting shipment quantities, or switching to maritime transport.
The freight forwarder should clearly explain to the shipper the reasons why the cargo cannot be loaded on the planned flight, the lead times for alternatives, possible additional costs, and potential storage charges.
Points to Confirm with the Shipper
Even if the shipper explains "It's a small quantity, so it's okay" or "It's just a sample, so it's okay," dangerous goods status in air transport cannot be determined solely by quantity or intended use.
- Is the latest version of the SDS available?
- Does it qualify as dangerous goods for air transport?
- Are the UN number, proper shipping name, hazard class, and packaging group confirmed?
- Does the packaging meet the standards required for air transport?
- Does it contain lithium batteries, aerosols, alcohol, flammable liquids, gases, or corrosive substances?
- Is a dangerous goods declaration required?
- Is it permitted on passenger aircraft, or is it restricted to cargo aircraft only?
- Has acceptance by the airline or courier company been confirmed?
- If it is not classified as dangerous goods, is there supporting documentation for this?
- Do the physical labels, external markings, invoice, packing list, and SDS match consistently?
Common Misconceptions
| Misconception | Practical Consideration | What Should Be Checked |
|---|---|---|
| If cargo is accepted for sea transport, it will also be accepted for air transport | Packing, quantity limits, and acceptance criteria differ between sea and air transport. | Check IATA DGR, airline conditions, packing standards, and quantity limits. |
| If the SDS shows a UN number, air transport is allowed | Having a UN number alone is insufficient; packing standards, quantity limits, and acceptance conditions are also required. | Confirm passenger aircraft acceptance, cargo-only aircraft conditions, and airline acceptance criteria. |
| Small quantities or samples can be handled as general cargo | Quantity and intended use alone cannot determine air dangerous goods applicability. | Check composition, SDS, UN number, hazard class, and exemption provisions. |
| All products with lithium batteries can be handled the same way | Lithium battery handling varies depending on battery type and whether batteries are standalone, contained with equipment, or installed. | Verify UN number, Wh rating, lithium content, quantity, and packaging configuration. |
| If a dangerous goods declaration is submitted, cross-check with the SDS is unnecessary | If the declaration and SDS do not match, the airline’s documentation review may result in shipment rejection. | Cross-check UN number, official shipping name, class, quantity, and packaging details. |
| If allowed by regulations, the airline must accept the cargo | Airlines and courier companies may impose their own restrictions on acceptance. | Confirm airline conditions, flight, aircraft type, transit points, and courier company conditions. |
| Cargo Aircraft Only shipments can be booked on regular flights | Cargo Aircraft Only (CAO) shipments are limited to certain flights and airlines. | Confirm freighter flights, CAO markings, quantity limits, and alternative routing options. |
| Labels or documents can be corrected after airport delivery | Discovering deficiencies after delivery can lead to refusal of acceptance, returns, storage fees, or shipment delays. | Verify labels, markings, dangerous goods declarations, and packaging condition before delivery. |
Points Freight Forwarders Should Be Aware Of
The IATA Dangerous Goods Regulations are an essential operational standard that freight forwarders must comply with when handling air dangerous goods.
- Confirm air dangerous goods at the quotation stage.
- Cross-check the SDS, dangerous goods declaration, invoice, and physical markings.
- Avoid confusing the requirements for maritime and air transport.
- Pay special attention to lithium batteries, spray cans, paints, adhesives, fragrances, and reagents.
- Verify individual restrictions imposed by each airline and courier company.
- Confirm whether the cargo is permitted on passenger aircraft or restricted to freighter-only conditions.
- Do not submit dangerous goods declarations that conflict with the SDS without resolution.
- When in doubt, conduct advance confirmation with the shipper, manufacturer, airline, and dangerous goods specialists.
Summary
The IATA Dangerous Goods Regulations are practical rules that specify classification, packaging, labeling, quantity limits, and documentation requirements to ensure the safe air transport of dangerous goods.
Cargo accepted for maritime transport may be rejected or only conditionally accepted for air transport. Therefore, it is essential to avoid confusion between the IMDG Code and the IATA Dangerous Goods Regulations and to verify conditions according to the transport mode.
Particular attention should be given to lithium batteries, aerosols, paints, adhesives, fragrances, alcohol-containing products, and reagents. It is important to check their UN numbers, dangerous goods classes, packaging standards, quantity limits, passenger aircraft carriage restrictions, and airline acceptance conditions.
The key is not simply to know the rule’s name, but to cross-check the SDS, UN number, dangerous goods class, container type, packaging standards, dangerous goods declaration, and airline acceptance conditions to ensure the cargo is properly prepared for safe air transport.
The main takeaway from this article is to treat the IATA Dangerous Goods Regulations not merely as the name for air dangerous goods rules but as practical confirmation standards that influence quotations, cargo collection, airport in-gate, airline acceptance, and carriage authorization.
