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Perfume. Lithium batteries. Aerosol cans. Paint. Hand sanitiser. Nail polish. Agricultural samples. Each of these is a dangerous good under the IATA Dangerous Goods Regulations. Each has specific restrictions on how it can be carried by air, in what quantities, in what packaging, and with what documentation. Each has been the subject of misdeclaration incidents that have resulted in cargo fires, diversions, and fatalities.

The maritime dangerous goods regime — the IMDG Code — is the one traders tend to know, if they know either. The IATA DGR is less familiar, and it is stricter. The penalty for getting it wrong includes refusal of the shipment, return of the cargo at the shipper's expense, and civil or criminal liability depending on jurisdiction.

Why air is different

An aircraft is an enclosed pressurised environment at altitude. Pressure changes, temperature variations, and vibration affect packages and containers in ways that do not apply to a container on a vessel deck. A substance that is stable at sea level may leak, expand, or react at cruising altitude. The consequences of a fire or a toxic release in an aircraft hold are more severe than the equivalent event on a ship, because there is nowhere to go.

These physical realities drive a regulatory regime that classifies substances and articles into nine hazard classes, assigns UN numbers to specific materials, and prescribes — for each combination of hazard class, quantity, and passenger or cargo aircraft type — the permitted packaging, the permitted quantity per package, the labelling requirements, the marking requirements, and the documentation requirements.

The nine classes

The IATA DGR follows the UN dangerous goods classification system: explosives (Class 1); gases (Class 2); flammable liquids (Class 3); flammable solids and related (Class 4); oxidisers and organic peroxides (Class 5); toxic and infectious substances (Class 6); radioactive material (Class 7); corrosives (Class 8); and miscellaneous (Class 9).

Lithium batteries — the most common dangerous goods issue in modern air freight — fall under Class 9, miscellaneous. They are subject to their own specific rules under IATA, with restrictions on state of charge, packaging, and labelling that change with almost every annual edition of the DGR.

Common products that catch traders off guard

Lithium batteries and devices containing them. Laptops, mobile phones, power banks, and electric vehicles all contain lithium batteries. The rules distinguish between lithium ion and lithium metal batteries, between batteries shipped alone and batteries contained in or packed with equipment, and between different watt-hour thresholds.

Flammable liquids. Perfumes, colognes, and personal care products containing alcohol are Class 3 flammable liquids. Small quantities in passenger baggage have their own exemptions; commercial shipments do not.

Aerosols. Any aerosol — regardless of its contents — is a Class 2 dangerous good. Hairspray, insect repellent, and cooking spray are all regulated.

Paint and ink. Most paints, lacquers, varnishes, and inks are Class 3 flammable liquids or Class 8 corrosives. Commercial quantities require full DGR compliance.

Agricultural and biological samples. Soil samples, plant material, and biological specimens may be regulated as infectious substances (Class 6.2) or as environmentally hazardous substances (Class 9) depending on their nature and origin.

The shipper's responsibility

Under the IATA DGR, the shipper — the entity that tenders the goods for air carriage — is responsible for compliance. The shipper must correctly classify the goods, use approved packaging, apply the correct labels and marks, and prepare a Shipper's Declaration for Dangerous Goods where required.

The freight forwarder passes on what the shipper declares. The airline accepts or rejects based on documentation and visible compliance. If misdeclared goods cause an incident, the shipper bears primary liability.

Excepted quantities and limited quantities

The DGR provides relief for small quantities of many substances through the "excepted quantities" and "limited quantities" provisions. These allow transport of small amounts of certain dangerous goods with reduced documentation requirements, provided the quantity per package does not exceed the specified limit. For many commercial samples and consumer goods shipments, these provisions offer a workable path.

What to do before the next air shipment

If you ship goods by air that include any of the categories described above — or any substance with a UN number, a hazard diamond, or a safety data sheet — verify compliance with the current edition of the IATA DGR before dispatch. The DGR is updated annually; a procedure that was compliant last year may not be compliant this year.

IATA offers training courses for shippers. The Civil Aviation Safety Authority (CASA) in Australia oversees dangerous goods by air domestically. Airlines' dangerous goods desks are a practical first point of contact for specific shipment questions.


— John W Gates, Brisbane

Dangerous goods, perishables and pharmaceuticals by air are covered in Air Cargo Carriage: Law and Practice for Traders, Book 7 of the International Trade and Transport Law Library. See the Library.