Non-Hazardous Goods Certificate
Interlink編集部What Is a Non-Dangerous Goods Certificate?
A Non-Dangerous Goods Certificate is a practical document prepared by the shipper, manufacturer, exporter, or related party to confirm that the cargo does not qualify as dangerous goods for transportation purposes. In English, it may be referred to as a Non-Dangerous Goods Certificate, Non-DG Certificate, or Non-Dangerous Goods Declaration.
In freight forwarding practice, the Non-Dangerous Goods Certificate is an important verification document, but it should not be solely relied upon to finalize a dangerous goods determination. It is necessary to confirm consistency with the SDS, product specifications, ingredients, mode of transport, packaging condition, and acceptance requirements of airlines, shipping lines, and CFS facilities.
The Non-Dangerous Goods Certificate serves as supporting documentation to explain that the cargo is not dangerous goods. However, having this document does not automatically mean the cargo is free from transport-related issues. Freight forwarders should treat the Non-Dangerous Goods Certificate as part of the overall dangerous goods verification process, rather than as a means for liability exemption.
Particularly for lithium batteries, aerosols, liquid chemicals, cleaning agents, paints, fragrances, reagents, sample cargo, and equipment containing such items, the Non-Dangerous Goods Certificate alone may be insufficient for a safe determination. In such cases, it is important to review the SDS, product specifications, battery information, packaging photos, mode of transport, and acceptance conditions together.
Scope Covered in This Article
| Item | Contents Covered in This Article | Contents Covered in Other Articles |
|---|---|---|
| Basics of Non-Dangerous Goods Certificates | Explains that a Non-Dangerous Goods Certificate is a supplemental document confirming that the cargo does not qualify as dangerous goods for transport. | The overall flow of dangerous goods transport is covered in the Dangerous Goods Transport article. |
| Key Details to Verify on the Certificate | Covers issuance party, relevant cargo, model numbers, components, transport mode, issue date, signatures, and basis for non-dangerous goods classification. | Formats of individual company certificates and internal approval procedures are left to each company’s operations. |
| Reliability of the Issuer | Organizes how the weight of verification varies depending on whether the issuer is the manufacturer, shipper, trading company, agent, logistics agent, or unknown. | Final legal responsibility should be confirmed based on contractual relationships and expert advice. |
| Relation to SDS | Discusses verification of consistency between the SDS transport information section, component details, physico-chemical properties, applicable laws section, edition number, and the Non-Dangerous Goods Certificate. | How to read SDS or SDS preparation obligations are covered in the SDS article. |
| When SDS and Certificate Contradict | Handles discrepancies such as conflicting UN numbers, hazard classes, marine pollutant status, transport modes, or product name mismatches. | Details of Dangerous Goods Declaration forms are covered in the Dangerous Goods Declaration article. |
| Differences Between Air and Sea Transport | Explains that verification points differ for air, sea, and domestic delivery, and cautions about reusing certificates across these modes. | Details on IATA Dangerous Goods Regulations and IMDG Code are addressed in their respective articles. |
| Relation to Lithium Batteries | Emphasizes the need to verify battery alone, with equipment, built-in configurations, capacity, quantity, and packaging conditions. | Detailed conditions for lithium battery transport are covered in the Lithium Batteries article. |
| Relation to Aerosols, Liquids, and Chemicals | Notes that additional verification is required for aerosols, liquid chemicals, detergents, paints, fragrances, reagents, and similar. | Dangerous goods classifications for individual products should be confirmed with the SDS, manufacturer, or hazardous materials specialists. |
| Verification at CFS, Warehouses, and Airlines | Covers cases where CFS, warehouse, airline, or shipping lines may require additional documents even when a Non-Dangerous Goods Certificate is provided. | Internal rules of individual CFS, airlines, and shipping lines are subject to case-by-case confirmation. |
Basic Role of a Non-Hazardous Goods Certificate
A Non-Hazardous Goods Certificate is a document that confirms the cargo does not qualify as dangerous goods. It may be required for chemical products, liquids, powders, aerosol items, battery-containing products, machinery parts, samples, cleaners, cosmetics, resin raw materials, and similar cargo.
In particular, for cargo whose hazardous nature is difficult to assess based solely on the invoice description, airlines, shipping lines, CFS facilities, warehouses, customs brokers, and freight forwarders may request a Non-Hazardous Goods Certificate as supplementary verification.
However, a Non-Hazardous Goods Certificate is not a comprehensive substitute for the SDS or other dangerous goods classification documentation. When the SDS includes information such as the UN number, hazard class, packing group, marine pollutant status, or lithium battery details, it is essential to confirm that the contents of the Non-Hazardous Goods Certificate do not conflict with this data.
Key Details to Verify in a Non-Dangerous Goods Certificate
The main caution with a Non-Dangerous Goods Certificate is that it may be formally correct but substantively inadequate. Even if it contains the company name and signature, if the cargo details, basis, transport mode, or issue date are unclear, the document is insufficient as practical verification evidence.
| Verification Item | Reason for Verification | Risks if Insufficient | Response if Issues Detected |
|---|---|---|---|
| Issuer | To identify who is declaring the cargo as non-dangerous. | Unclear accountability may result in rejection by airlines, shipping lines, or CFS facilities. | Confirm official company name, department, signatory, and contact details. |
| Cargo Name, Model Number, Part Number | To precisely identify the cargo in question. | The certificate may be mistaken for another product’s documentation. | Cross-check against invoice, packing list, SDS, and actual product part numbers. |
| Composition, Material, Use | Serves as the basis for confirming non-dangerous goods status. | Additional checks may be required for chemicals, liquids, powders, or products containing batteries. | Obtain SDS, composition lists, and product specifications. |
| Consistency with SDS and Specifications | To ensure there are no contradictions with other documents. | If the SDS contains dangerous goods information, the certificate alone is insufficient for judgment. | Compare SDS, certificate, and manufacturer’s statement. |
| Transport Mode | To confirm whether the certificate applies to maritime or air transport. | Cargo acceptable by sea may be refused for air transport. | Check IMDG Code, IATA Dangerous Goods Regulations, and carrier requirements. |
| Basis for Non-Dangerous Goods Classification | To verify the reasons why the cargo is not classified as dangerous goods. | Simply stating “Non-DG” may lack sufficient justification. | Request SDS, test reports, manufacturer confirmation, or dangerous goods assessment documents. |
| Issue Date | To confirm alignment with the current product specifications and SDS. | An outdated certificate may not reflect ingredient changes or SDS revisions. | Check the latest SDS and a newly issued certificate. |
| Signature, Company Name, Contact Information | To secure a point of contact for further verification if needed. | Lack of this information may cause rejection by shipping lines, airlines, or CFS facilities. | Verify signatory’s name, issuing department, and inquiry contacts. |
A Non-Dangerous Goods Certificate should be evaluated not by its appearance but by whether the cargo details and transport conditions match. If the product name is vague, model numbers are missing, contradictions with the SDS exist, transport mode is unclear, the issue date is old, or the signatory is unidentified, additional verification is necessary.
Verification of the Issuer’s Reliability
The significance of a Non-Dangerous Goods Certificate varies depending on who issued it. When the manufacturer issues the certificate based on full knowledge of product specifications and composition, the verification requirements differ from cases where an agent prepares it based on the shipper’s explanation.
| Issuer | Practical Perspective | Points for Verification | Actions if Issues Are Found |
|---|---|---|---|
| Manufacturer | The issuer is likely to have a comprehensive understanding of the ingredients, specifications, and SDS. | Confirm the product model number, SDS number, issue date, and consistency with the transportation mode. | Check the latest version of the SDS, specification sheets, and transportation conditions assumptions. |
| Shipper / Exporter | Acts as the shipment responsible party but may require manufacturer confirmation for technical details. | Cross-reference the SDS, specification sheets, and manufacturer documentation. | Request manufacturer-issued documents as needed. |
| Trading Company / Agent | Acts as the issuer for the transaction but may not have actual ingredient information. | Require submission of manufacturer-issued documents and SDS for verification. | Do not proceed based on agent explanations alone; confirm information with the manufacturer. |
| Customs Broker / Logistics Agent | May prepare the certificate based on shipper information. | Technical basis may be weak; SDS and manufacturer confirmation are necessary. | Verify the preparation basis, shipper confirmation materials, and manufacturer documentation. |
| Unknown Issuer | The responsible party cannot be identified. | Using as-is may lead to refusal by shipping lines, airlines, or CFS facilities. | Request official issuer name, signature, contact details, and supporting documents. |
Freight forwarders should always verify the issuer’s position, the cargo in question, the supporting documentation, and the transportation mode—even when receiving a Non-Dangerous Goods Certificate. If the issuer appears responsible but the certificate conflicts with the SDS or actual cargo information, it is crucial not to proceed without further verification.
Relationship with the SDS
When verifying a Non-Dangerous Goods Certificate, it is important to ensure consistency with the SDS. If the SDS transport information section includes details such as the UN number, hazard class, packaging group, or marine pollutant status, it is necessary to confirm that these details do not conflict with the contents of the Non-Dangerous Goods Certificate.
If the SDS appears to classify the cargo as dangerous goods but only a Non-Dangerous Goods Certificate has been submitted, it should not be accepted as is. Instead, confirmation of the classification basis from the shipper or manufacturer is required.
| Verification Item | Key Details to Check | Points of Caution | Actions if Issues Arise |
|---|---|---|---|
| SDS Transport Information Section | Confirm the UN number, proper shipping name, hazard class, packaging group, and whether the cargo is a marine pollutant. | If dangerous goods information appears here, check for any contradictions with the Non-Dangerous Goods Certificate. | Request confirmation of classification basis from the shipper or manufacturer. |
| SDS Composition Details | Verify components related to flammability, corrosiveness, toxicity, oxidizing properties, or environmental hazards. | If the certificate lacks component descriptions, further confirmation is needed. | Obtain component list, specifications, and manufacturer clarifications. |
| SDS Physicochemical Properties | Check flash point, boiling point, pH, physical state, volatility, and related data. | This is especially important for liquids, sprays, cleaning agents, and paints. | Request data supporting dangerous goods classification or relevant test results. |
| SDS Applicable Legislation Section | Verify relevance under domestic laws such as the Fire Services Act and Industrial Safety and Health Act. | Note that non-dangerous goods status for transport may differ from domestic legal classifications. | Obtain Japan-specific SDS, Fire Services Act classification confirmation, and manufacturer verification. |
| SDS Revision Number and Issue Date | Confirm it is the latest edition and applies to the same product as indicated on the certificate. | Old or product-mismatched SDS cannot be used for evaluation. | Request the latest SDS and reissuance of the certificate. |
When SDS and Non-Dangerous Goods Certificates Conflict
If the SDS and the Non-Dangerous Goods Certificate contradict each other, do not prioritize the certificate alone. Instead, verify against the actual cargo, the latest SDS, manufacturer information, transport mode, and applicable dangerous goods regulations.
| Conflict Pattern | Possible Causes | Documents or Parties to Verify | Recommended Response |
|---|---|---|---|
| The SDS includes a UN number, but the Non-Dangerous Goods Certificate indicates Non-DG | The SDS may be outdated, product specifications may have changed, the certificate might cover a different product, or the transport mode might differ. | Latest SDS, applicable product code, manufacturer confirmation, transport mode | Confirm whether the reference is for maritime or air transport and replace with the correct documents. |
| The SDS shows a hazardous class, but the certificate states non-applicability for dangerous goods | Changes in concentration, confusion with Limited Quantities (LQ) or Excepted Quantities (EQ), or transcription errors are possible. | SDS, dangerous goods assessment report, LQ/EQ conditions, manufacturer responses | Clarify whether the cargo is classified as regular dangerous goods, LQ, EQ, or non-dangerous goods. |
| The SDS mentions marine pollutants but the certificate makes no reference | Possible oversight of environmental hazards or neglecting the maritime transport section. | Transport information section in SDS, environmental impact section, Dangerous Goods Declaration (DGD), carrier requirements | Confirm marine pollutant status, marking, and dangerous goods details for maritime transport. |
| The certificate is meant for air transport but is being used for maritime transport | Misunderstanding or mix-up of transport modes. | Certificate, SDS, IMDG Code, CFS acceptance conditions | Verify the dangerous goods classification for maritime transport, IMDG Code classification, and CFS acceptance criteria. |
| The certificate is intended for maritime transport but is being used for air transport | Packing, quantity limits, and loading conditions for air transport have not been confirmed. | Certificate, SDS, IATA conditions, airline confirmations | Confirm compliance with IATA Dangerous Goods Regulations, airline-specific requirements, and conditions for batteries, liquids, and aerosols. |
| Product name on the certificate does not match the invoice or actual cargo | May involve different products, old product names, different model numbers, or only a product series name is listed. | Invoice, packing list, photos of actual cargo, model number, SDS number | Identify the cargo by model number, product code, and SDS number, and request reissuance of the certificate if necessary. |
If discrepancies exist, do not arbitrarily adopt one document over the other. Instead, confirm with the shipper or manufacturer and replace with the correct documentation before submitting to shipping lines, airlines, or CFS facilities.
Differences Between Air and Sea Transport
Non-Dangerous Goods Certificates are reviewed differently depending on whether the transport mode is air or sea. Cargo that poses no issue in sea transport may still be rejected for air carriage, and documentation acceptable for air transport may not be valid for sea transport or CFS intake.
| Category | Air Transport | Sea Transport | Practical Points |
|---|---|---|---|
| Main Regulations Checked | Verification of the IATA Dangerous Goods Regulations, airline-specific variations, and conditions required by warehouses and consolidation operators. | Verification of the IMDG Code, shipping line requirements, and acceptance conditions at CFS and hazardous goods warehouses. | Confirm which transport mode the certificate is intended for. |
| Common Cargo Types Checked | Lithium batteries, aerosols, liquids, cosmetics, reagents, samples, and equipment with built-in devices. | Chemicals, liquids, paints, cleaning agents, resin raw materials, marine pollutants, and LCL consolidated cargo. | Additional checks may vary depending on the mode of transport, even with the same Non-DG explanation. |
| Typical Points Reviewed | Battery details, capacity, quantity, packaging, presence of liquids or aerosols, and carriage eligibility. | UN number, dangerous goods class, marine pollutant status, CFS acceptance, and mix consolidation approval. | Documentation requirements by airlines, shipping lines, and CFS may differ. |
| Consequences of Deficiencies | Rejected by airline for loading, warehouse refusal, flight changes, repackaging, and requests for additional documents. | Rejected at CFS intake, halted shipping line confirmation, shipment delays, and rearrangement of hazardous goods warehouse. | When changing transport modes, do not reuse certificates indiscriminately; reconfirm conditions. |
| Practical Considerations | Even with a non-dangerous certificate, airlines may require additional documentation. | If conflicting with SDS or CFS requirements, cargo may not be accepted as general cargo. | Verify certificate, SDS, cargo condition, packaging, and acceptance criteria together. |
When using a Non-Dangerous Goods Certificate, always confirm which transport mode it assumes. Since the verification requirements differ for air, sea, and domestic delivery, reusing certificates without checking can cause problems.
Do Not Rely Solely on the Non-Dangerous Goods Certificate
The Non-Dangerous Goods Certificate is essentially explanatory documentation provided by the shipper or manufacturer. It does not imply that the freight forwarder is conducting a technical hazardous materials assessment. However, if the content is clearly inconsistent or if the product name does not align with the documentation, the verification process should be halted.
For example, when the product name includes terms such as battery, spray, chemical, liquid, paint, cleaner, adhesive, or sample, it is important to review not only the Non-Dangerous Goods Certificate but also the SDS, ingredient list, product specifications, and hazardous materials classification documents.
Even if the paperwork states Non-DG, if the cargo’s actual nature may involve lithium batteries, aerosols, flammable liquids, corrosive substances, toxic materials, or marine pollutants, checks should be conducted for each mode of transport accordingly.
Relation to Lithium Batteries
For cargo containing lithium batteries, relying solely on a non-dangerous goods certificate is risky. Handling requirements vary depending on whether the battery is standalone, contained within equipment, built into equipment, its capacity, quantity, testing requirements, and packaging conditions.
Even if the shipper explains that the lithium batteries are “just built into the equipment and therefore non-dangerous,” confirmation may still be required for air and sea transport. Freight forwarders need to verify the presence of batteries, type, capacity, quantity, installation status, presence of spare batteries, and packaging condition.
For lithium battery-related cargo, in addition to the non-dangerous goods certificate, the product specifications, battery information, test data, packaging details, and airline or shipping line acceptance conditions should be confirmed. Particular attention is required for air transport due to variations in requirements among airlines.
Relation to Aerosols, Liquids, and Chemicals
Aerosol products, liquid chemicals, cleaning agents, adhesives, paints, fragrances, cosmetics, and reagents may sometimes require a Non-Hazardous Goods Certificate. However, if the items are flammable, corrosive, toxic, oxidizing, or environmentally hazardous, they could be classified as dangerous goods.
Freight forwarders should not rely solely on the product name or intended use. It is necessary to verify the SDS, ingredients, flash point, packaging, quantity, and mode of transport. Especially for samples or small shipments, shippers may underestimate the need for dangerous goods verification.
Even items labeled as cosmetics, cleaning agents, fragrances, or samples may contain alcohol, solvents, aerosols, acids or alkalis, oxidizers, or environmentally hazardous substances. It is important not to proceed based solely on the Non-Hazardous Goods Certificate, but to confirm with the SDS and product information.
Precautions at CFS and Warehouses
At CFS and warehouses, even if a non-hazardous goods certificate is provided, additional verification may be requested based on the cargo's appearance, product name, SDS, and packaging. If cargo suspected of being hazardous is brought in as general cargo, acceptance may be refused or the cargo may be temporarily held.
It is especially important to present documentation to the CFS or warehouse and confirm acceptance in advance for chemicals, liquids, spray products, battery-containing items, odorous cargo, and goods with leakage risk.
In LCL consolidation, insufficient hazard verification of a single shipment could impact the entire consolidated cargo arrangement. Even with a non-hazardous goods certificate, the CFS or consolidation operator may request the SDS, photos, packing details, or evidence supporting the non-hazardous classification.
Comparison Table of Freight Forwarders’ Involvement
| Category | What Can Be Assisted | What Should Not Be Concluded | Practical Response |
|---|---|---|---|
| Initial Certificate Check | Confirm the issuer, subject cargo, issue date, signature, and mode of transport. | Assuming dangerous goods verification is complete solely because a certificate exists. | Cross-check the certificate against the SDS, invoice, packing list, and the actual cargo information. |
| Issuer Confirmation | Identify whether the certificate is issued by the manufacturer, shipper, agent, or logistics representative. | Treating all issuers as having the same technical reliability. | Request manufacturer-issued documents or SDS as needed. |
| Cross-Checking with SDS | Compare transport information, ingredient details, physicochemical properties, and applicable legal sections in the SDS. | Prioritizing the certificate alone when the SDS lists a UN number or dangerous goods class. | If inconsistencies arise, verify the classification basis with the shipper or manufacturer. |
| Mode of Transport Confirmation | Determine whether the certificate is based on air, sea, or domestic transport requirements. | Using a sea transport certificate as is for air transport. | Verify IATA requirements, IMDG Code, airline, and shipping line conditions separately. |
| Lithium Battery Verification | Confirm presence, type, capacity, quantity, installed status, and presence of spare batteries. | Assuming a non-dangerous goods certificate alone suffices because batteries are built into equipment. | Check product specifications, battery information, packaging conditions, and airline and shipping line requirements. |
| Verification of Liquids, Aerosols, Chemicals | Confirm SDS, components, flash point, container type, quantity, and aerosol classification. | Deciding the cargo is general based solely on descriptions such as sample, cosmetics, or cleaning agent. | Review SDS, hazardous goods assessment documents, and packaging photos. |
| CFS, Airline, Shipping Line Verification | Check acceptance conditions, additional documentation, allowance for in-gate, and mixed cargo acceptance. | Assuming all parties will accept cargo simply because a certificate exists. | Submit documentation beforehand and confirm acceptance or rejection. |
| When Doubts Remain | Hold shipment arrangements and consult the shipper, manufacturer, or hazardous materials specialist. | Proceed with air loading, CFS in-gate, or ship loading prioritizing deadlines despite unclear issues. | Submit corrected SDS, certificates, and classification documents before proceeding. |
Common Practical Issues
Insufficient verification of non-dangerous goods certificates can lead to denial of air transport loading, refusal of CFS intake, shipment delays, repackaging, and additional document requests. Special attention is required for chemicals, liquids, aerosols, products containing batteries, and sample cargoes.
| Case | Key Issue | Documents / Parties to Check | Recommended Response |
|---|---|---|---|
| Non-dangerous goods certificate exists, but the SDS includes a UN number | Possible mismatch between SDS and certificate product scope, failure to update SDS, or differences in transport mode. | Latest SDS, model number, manufacturer confirmation letter, certificate | Reassess dangerous goods applicability and replace with correct documents. |
| Certificate product name does not match invoice or actual product | Confusion among product name, model number, and series name. | Invoice, packing list, model number, item number, SDS number, product photos | Identify the actual cargo and request reissuance of the certificate if necessary. |
| Airline requested additional documents | Concerns involving batteries, liquids, aerosols, or chemicals. | SDS, product specifications, battery information, packaging photos, hazardous goods assessment documents | Submit additional documents to meet airline requirements. |
| CFS refused acceptance of cargo declared as non-hazardous | Concerns raised by product name, odor, liquid content, or SDS information indicating possible dangerous goods. | CFS response, SDS, exterior photos, packing details, shipper’s response | Return to intake confirmation and switch to dangerous goods handling or arrange alternative warehouse. |
| Only an outdated certificate is available | May not reflect changes in ingredients, SDS revisions, or product specifications. | Latest SDS, current specification sheet, manufacturer confirmation letter | Request a new certificate or manufacturer confirmation letter. |
| Certificate issuer is an agent, with unclear basis | Certificate may have been prepared based on commercial explanation rather than manufacturer data. | Manufacturer-issued documents, SDS, ingredient lists, specifications | Confirm with manufacturer documents before proceeding. |
| Used a marine transport certificate for air transport | Transport mode differences were not confirmed. | IATA regulations, airline responses, SDS, certificate | Verify packaging, quantity, and loading conditions suitable for air transport. |
| Processed lithium battery-containing products as Non-DG | Failure to confirm presence, capacity, quantity, installation status of batteries, and presence of spare batteries. | Product specifications, battery information, packing details, airline and shipping line responses | Verify lithium battery transport conditions and add necessary documents. |
4-Column Verification Checklist
| Verification Scenario | Party to Verify With | Items to Confirm | Action If Issues Are Found |
|---|---|---|---|
| Upon receiving a Non-Dangerous Goods Certificate | Shipper / Issuer | Confirm the issuer, applicable cargo, model number, issue date, signature, transport mode, and basis for non-dangerous goods classification. | If unclear, request re-issuance or additional documentation. |
| When an SDS is available | Shipper / Manufacturer | Ensure consistency between the transport information section, ingredient details, physicochemical properties, applicable regulations on the SDS, and the certificate. | If discrepancies exist, confirm with the manufacturer and replace with correct documents. |
| When the product name indicates chemicals, liquids, sprays, or products containing batteries | Shipper / Manufacturer / Dangerous Goods Specialist | Check for dangerous goods status, ingredients, flash point, battery information, aerosol classification, and packaging condition. | Do not rely solely on the Non-Dangerous Goods Certificate; conduct additional verification using the SDS and specifications. |
| When arranging air transport | Airline / Air Freight Forwarder / Shipper | Verify IATA conditions, airline-specific differences, battery, liquid, aerosol regulations, and carriage permissibility. | If air transport documentation is insufficient, obtain additional documents before arranging shipment. |
| When arranging maritime transport | Shipping Line / NVOCC / CFS / Shipper | Confirm compliance with the IMDG Code, CFS acceptance criteria, marine pollutant status, and LCL consolidation acceptance. | If the CFS or shipping line requests additional documentation, submit SDS or classification evidence as needed. |
| If the certificate issuer is an agent or logistics provider | Issuer / Shipper / Manufacturer | Verify technical basis, manufacturer’s documentation, SDS, and consistency with the applicable product. | If the basis is weak, request documentation issued by the manufacturer. |
| When handling products containing lithium batteries | Shipper / Manufacturer / Airline / Shipping Line | Confirm battery presence, type, capacity, quantity, installation status, spare batteries, and packaging conditions. | Prepare necessary documentation and packaging according to lithium battery regulations. |
| When delivering to a CFS or warehouse | CFS / Warehouse / Consolidation Operator | Check Non-Dangerous Goods Certificate, SDS, packaging photos, product name, odor, risk of leakage, and acceptance criteria. | If not accepted, consider handling as dangerous goods or using an alternative CFS or warehouse. |
Example 1: Case Where a Non-DG Certificate Was Submitted Despite the Presence of a UN Number on the SDS
A non-dangerous goods certificate was submitted by the shipper, and the documents indicated Non-DG, while the transport section of the SDS included a UN number and hazardous materials class.
In this case, the non-dangerous goods certificate alone should not be prioritized to proceed as general cargo. It is necessary to verify whether the SDS is outdated, the certificate applies to a different product, there is a difference in the mode of transport, or whether concentration or specifications have changed.
The freight forwarder should confirm the latest SDS, model number, product number, SDS reference number, manufacturer’s confirmation document, and the applicable transport mode.
Until the contradiction is resolved, do not submit the cargo as general cargo to airlines, shipping lines, or CFS. Arrange transport only after replacing the documents with the correct ones.
Example 2: Attempting to Treat Equipment Containing Lithium Batteries as Non-Dangerous Goods
The shipper explained that "since the battery is only built into the equipment, it is non-dangerous goods," and submitted only a non-dangerous goods certificate.
Lithium batteries require varying transport conditions depending on whether they are standalone, included with equipment, built-in, their capacity, quantity, presence of spare batteries, and packaging condition. A non-dangerous goods certificate alone may not be accepted by airlines or shipping lines.
The freight forwarder should verify the product specifications, battery type, capacity, quantity, installation status, presence of spare batteries, packaging photos, and the requirements of the airline and shipping line.
If necessary, additional documentation, labeling, packaging, and airline confirmation based on lithium battery transport regulations should be completed.
Example 3: Attempt to Use a Non-Dangerous Goods Certificate for Maritime Transport in Air Cargo
This case involves trying to use a non-dangerous goods certificate prepared for maritime transport as-is when switching to air transport to shorten the delivery time.
The criteria for dangerous goods confirmation differ between maritime and air transport. Cargo acceptable for sea transport may require additional checks or may be rejected in air transport due to factors such as liquids, aerosols, batteries, quantity, packaging, and whether the cargo can be loaded.
Freight forwarders should verify the IATA Dangerous Goods Regulations, airline-specific differences, SDS, product specifications, packaging condition, quantity, and the airline’s acceptance criteria.
If the documentation is insufficient for air transport, certificates, SDS, and dangerous goods assessments based on air transport requirements should be newly obtained before shipment.
Example 4: Case of Rejection of Non-Dangerous Goods at a CFS
This case involved an attempt to deliver a liquid detergent to a CFS as general cargo, supported by a Non-Dangerous Goods Certificate.
However, the CFS identified concerns based on the product name, odor, liquid state, and SDS information, suspecting it might be hazardous material, and temporarily withheld acceptance as general cargo.
The freight forwarder should verify the SDS, Non-Dangerous Goods Certificate, packaging photos, composition, flash point, marine pollutant status, and CFS acceptance criteria before delivery.
If necessary, the freight forwarder should switch to handling as hazardous goods, use a different CFS, arrange for a hazardous goods warehouse, repackage, or reconfirm with the shipping line.
Items to Confirm with the Shipper
When receiving a Non-Dangerous Goods Certificate, the freight forwarder should confirm the following information with the shipper at an early stage.
- Who issued the Non-Dangerous Goods Certificate.
- Whether the product name, model number, part number, and SDS number of the cargo are accurately identified.
- Whether the most current SDS is available.
- Whether the transport section of the SDS lacks any UN number, dangerous goods class, packaging group, or marine pollutant indication.
- Whether the Non-Dangerous Goods Certificate matches the SDS, invoice, packing list (P/L), and actual product markings.
- Whether the certificate is intended for air transport, sea transport, or domestic inland delivery.
- Whether the cargo excludes lithium batteries, aerosols, liquids, powders, chemicals, paints, cleaning agents, fragrances, or reagents.
- For products containing batteries, whether the battery type, capacity, quantity, installation status, and presence of spare batteries have been confirmed.
- Whether the issue date is recent and reflects any product specification changes or SDS revisions.
- Whether the airline, shipping line, CFS, or warehouse requires any additional documentation.
- Whether the manufacturer has confirmed the basis for determining the cargo does not qualify as dangerous goods.
Common Misconceptions
With Non-Dangerous Goods Certificates, there is often the misconception that "having the document means everything is fine." In actual logistics practice, what matters is not just the presence of the document but whether the cargo content and transport conditions are appropriate.
| Misconception | Practical Consideration | What Should Be Checked |
|---|---|---|
| Having a Non-Dangerous Goods Certificate means the SDS is unnecessary | The Non-Dangerous Goods Certificate is a supporting document and may require cross-checking with the SDS and product specifications. | Check the SDS, product specifications, ingredient list, and transport information section. |
| If "Non-DG" is stated, dangerous goods confirmation is complete | It is necessary to verify that the product name, ingredients, mode of transport, SDS, packaging status, and acceptance conditions do not conflict. | Cross-check the certificate, SDS, invoice, packing list, and physical markings. |
| Certificates issued by agents have the same reliability as those issued by manufacturers | The strength of the evidential basis varies depending on the issuer’s position. | Verify manufacturer documents, SDS, ingredient lists, and specifications. |
| Maritime non-dangerous goods certificates are valid for air transport as well | For air transport, IATA Dangerous Goods Regulations, airline differences, and special conditions for batteries, liquids, and aerosols must be separately confirmed. | Confirm transport mode, airline requirements, and air transport documentation. |
| Non-dangerous goods certificates alone suffice for lithium battery-equipped products | The battery type, capacity, quantity, installation method, presence of spare batteries, and packaging conditions must be checked. | Review product specifications, battery information, packaging documents, and airline/carrier conditions. |
| Samples can be handled with only a Non-Dangerous Goods Certificate | Even samples of chemicals, liquids, reagents, aerosols, and battery-powered products may require dangerous goods confirmation. | Check the SDS, ingredients, flash point, container, quantity, and mode of transport. |
| Older certificates can be used if it is the same product | Changes in ingredients, SDS revisions, regulatory updates, or product specification changes may not be reflected. | Confirm issuance date, latest SDS version, and manufacturer confirmation. |
| CFS or airlines will always accept cargo if a certificate is presented | CFS operators, airlines, and shipping lines may request SDS, photos, packing details, or additional documentation. | Pre-check acceptance conditions, need for additional documents, and in-gate requirements. |
Practical Points to Note
- The Non-Dangerous Goods Certificate should be treated as auxiliary documentation for hazardous materials verification.
- Dangerous goods determination should not rely solely on the Non-Dangerous Goods Certificate.
- Cross-check with the SDS, product specifications, composition sheets, invoice item descriptions, and packaging conditions.
- Confirm whether the issuer is the manufacturer, shipper, agent, or logistics provider.
- Verify whether the mode of transport is maritime or air.
- Additional checks should be conducted for lithium batteries, aerosols, liquids, chemicals, paints, cleaning agents, fragrances, and reagents.
- If there is a discrepancy between the SDS and the Non-Dangerous Goods Certificate, verify with the manufacturer.
- CFS, warehouses, airlines, and shipping lines may request supplementary documentation.
- Do not use outdated certificates or certificates with unclear applicable products as-is.
- In case of doubt, confirm with the shipper, manufacturer, or hazardous materials specialists.
Summary
A Non-Dangerous Goods Certificate is a practical document used to explain that cargo does not fall under dangerous goods for transport purposes. However, having a Non-Dangerous Goods Certificate does not guarantee that the cargo is truly without transport risks.
Freight forwarders, even when in possession of a Non-Dangerous Goods Certificate, should cross-check the SDS, product specifications, ingredients, invoice description, packaging condition, mode of transport, and the conditions set by the airline, shipping line, or CFS. Special caution is needed for lithium batteries, aerosols, liquids, chemicals, paints, cleaning agents, fragrances, reagents, and sample cargo.
The Non-Dangerous Goods Certificate is not a document to omit dangerous goods verification. Rather, it serves as supplementary evidence to organize the basis for the cargo not qualifying as dangerous goods. Confirming that the cargo content and transport conditions match the certificate, rather than relying on the document format itself, is critical to avoid misdeclaration, gate-in rejection, loading refusal, or shipment delay.
The key point of this article is that a Non-Dangerous Goods Certificate should not be treated as a standalone determination document, but as part of the dangerous goods verification process by cross-checking the SDS, product specifications, issuer, transport mode, packaging condition, and airline, shipping line, and CFS requirements.
