Dangerous goods by air: an IATA DGR primer for shippers

The carriage of dangerous goods by air is governed by the IATA Dangerous Goods Regulations (DGR), based on the ICAO Technical Instructions and reissued every year. Airlines and ground handlers must apply them; in Turkey the framework is supported by the Directorate General of Civil Aviation (SHGM).

Dangerous goods are articles or substances that can endanger flight safety, health, property or the environment; paint, perfume, hand sanitiser, devices with lithium batteries and dry ice are all in scope. Undeclared or misdeclared dangerous goods expose the shipper to severe penalties, and the usual cause is not concealment but not knowing that a product is regulated.

The nine classes with examples

For classes 3, 4.1, 4.2, 4.3, 5.1, 6.1, 8 and some class 9 substances the degree of danger is shown by a packing group (PG I high, PG II medium, PG III low), which sets the permitted packaging and the maximum quantity per package. Every substance is identified by a four-digit UN number and a Proper Shipping Name, for example UN1263 Paint or UN3480 Lithium ion batteries.

Documents: the Shipper's Declaration and the SDS

The Shipper's Declaration for Dangerous Goods (DGD) is the signed document in which the shipper declares that the consignment is correctly classified, packed, marked and labelled. The red-hatched standard form carries shipper and consignee details, AWB number, airports, aircraft limitation, UN number, proper shipping name, class, packing group, quantity and packaging per package, packing instruction and an emergency telephone number. At least two copies are issued, or an electronic e-DGD; only DGR-trained staff may prepare it.

The SDS/MSDS (Safety Data Sheet) is not a transport document, but its section 14 (Transport information) gives the UN number, class and packing group and is the basis for classification; forwarders and airlines ask for it whenever in doubt.

Marks, labels and packaging

• Hazard labels: the diamond-shaped class label (minimum 100 × 100 mm), plus a second label for any subsidiary hazard.
• Handling labels: Cargo Aircraft Only (orange), the Lithium Battery mark, orientation arrows for liquids, Keep Away From Heat, Cryogenic Liquid.
• Marks: UN number and proper shipping name, full name and address of shipper and consignee, net quantity where required, and the UN specification packaging code (for example 4G/Y25/S/…).
• UN specification packaging: most dangerous goods require tested packaging bearing the printed UN code; the packing instruction (PI) defines which inner and outer packagings may be used and in what quantities.
• Limited quantities (LQ): small inner packagings, up to 30 kg gross per package, under the 'Y' packing instructions; no UN specification packaging, but a DGD, the LQ mark with 'Y' and the hazard label are required.
• Excepted quantities (EQ): very small amounts (inner packagings generally up to 30 g/mL); the EQ mark replaces the DGD and hazard label, with an entry on the AWB.
• Overpack: several packages in one outer enclosure; inner marks and labels not visible from outside are repeated on it with the word 'OVERPACK'.

Lithium batteries

Lithium batteries are the most common dangerous goods in air cargo and ship under four class 9 UN numbers: UN3480 lithium ion batteries (stand-alone), UN3481 lithium ion batteries packed with or in equipment, UN3090 lithium metal batteries (stand-alone) and UN3091 lithium metal batteries packed with or in equipment. E-bikes and e-scooters have their own entry, UN3556.

Key rules: UN3480 and UN3090 are forbidden as cargo on passenger aircraft and may only fly on freighters (CAO). UN3480 must be shipped at a state of charge not exceeding 30% of rated capacity; a similar limit for UN3481 is being phased in, so check the current DGR edition and operator variations. Damaged, defective or recalled batteries may not be carried by air at all.

Small batteries (lithium ion cells up to 20 Wh, batteries up to 100 Wh; lithium metal cells up to 1 g, batteries up to 2 g of lithium) packed with or in equipment may travel under Section II of PI 966/967 and 969/970 without a DGD, with only the Lithium Battery mark. That relief ended for stand-alone batteries in 2022: UN3480 and UN3090 always need a DGD, the class 9 label and the CAO label.

Cargo Aircraft Only (CAO)

Some substances are forbidden on passenger aircraft, others allowed only in smaller quantities; each packing instruction gives separate per-package limits for the two aircraft types. Freighter-only packages carry the orange 'Cargo Aircraft Only' label and the 'Passenger and Cargo Aircraft' option is struck out on the DGD. CAO cargo must be booked with airlines operating freighters, which affects capacity and transit time.

Who is responsible for what?

The shipper is responsible for classification, UN specification packaging, marks and labels, the DGD and the DGR training of its staff (CBTA). It must provide a signed DGD, the SDS, the UN 38.3 test summary for lithium batteries, an emergency contact and any state or operator approvals.

The forwarder and GSSA check every package against the paperwork with the DGR section 9 acceptance checklist: UN number, proper shipping name, class and packing group; quantity per package within the packing instruction limit; packaging code; legible labels; segregation; state and operator variations; CAO eligibility and the dangerous goods entry on the AWB. General cargo is also screened for hidden dangerous goods, typically machinery parts, samples and vehicle parts.

The NOTOC (Notification to Captain) is the written notice to the pilot-in-command listing the dangerous goods on board with UN number, class, quantity, loading position and CAO status, prepared by the airline or ground handler. The shipper's data travels all the way to the NOTOC, which is why errors in the declaration are a flight-safety issue, not merely a commercial one.

Limit Trans checks shipper documentation with DGR-trained staff before tendering dangerous goods to the airline, and advises on the variations of the carriers it represents at booking stage.