IATA Memo on Wrongful Rejections of Hazmat Cargo

The International Air Transport Association (IATA) issued a memo in February to correct a misconception held by some carriers that caused dangerous goods shipments to be rejected over “trivial” documentation issues. IATA is concerned about the perception among air carriers that the Dangerous Goods Declaration (DGD) form presented by shippers must be identical to the example(s) shown in the Dangerous Goods Regulations (DGR). This is not the case.

The memo clarifies that small variations in “format” on the Dangerous Goods Declaration (DGD) do not violate IATA’s requirements, provided they do not compromise safety. In the memo, IATA specifically calls attention to the text found in the DGR, Part 9.1.3 Note 4, which reads: 
 

“Minor discrepancies… are not considered as errors if they do not compromise safety and should not be considered a reason for rejecting a consignment.”  

Dangerous Goods Declaration—Rejections for Minor Discrepancies. IATA. February 5, 2025.

Many air carrier personnel use a dangerous goods acceptance checklist to verify compliance with the IATA regulations. These checklists refer to the DGD being in “IATA format.” This does not mean that the document must be identical to the examples in the DGR, however. 

Minor Discrepancies on a DG Declaration

The memo highlights several “inconsequential” DGD formatting variations used by shippers, stressing that these are not errors and not reasons to hold up a hazmat package: 

• Inclusion of additional information, e.g., the title of the signer or the place of signing 
• Use of different font size or font style
• Use of dashed lines instead of solid lines
• Use of the word “risk” instead of “hazard” 

IATA ends the guidance to hazmat air carriers with this note, in bold text:
 

"The process of accepting of dangerous goods is an important function which contributes to aviation safety. The rejection of shipments for trivial reasons may have adverse consequences for business, commerce and safety."

Dangerous Goods Declaration—Rejections for Minor Discrepancies. IATA. February 5, 2025.

Uncertainty and IATA DGR Updates 

At least some of the confusion stems from changes made to the DGR in recent years. IATA publishes a new edition of the regulation manual every year. New editions of the DGR can contain substantial revisions to the shipping regulations, IATA Packing Instructions (PI), special provisions, State and operator requirements, and so on.

IATA also makes minor typographical and editorial changes to the DGR to fix spelling and punctuation, remove outdated info, and keep language consistent throughout the text.

For the 2019 DGR, for example, IATA replaced the term “subsidiary risk” with “subsidiary hazard” on the DGD. They also removed placeholders for two previously optional fields, “Title” and “Place” of signatory. Third, when updating the images of example DGD Forms shown in the DGR, IATA made “inconsequential changes” to font size, font style, and line style (dashed line vs. solid line).

IATA considers changes like these are insignificant and believes they do not affect transportation safety. Since the changes in 2019, however, some shippers have experienced rejection of hazmat cargo due to noncomformance with the exact wording or formatting of the Dangerous Goods Declaration. These unnecessary rejections can cause a domino effect of delays in the supply chain for products like pharmaceuticals, fuels, chemicals, batteries, and countless other products regulated as hazardous materials in transportation. 

IATA DGR Training—Hazmat Air Shipper Certification 

The February 5 memo from IATA provides shippers with a useful tool for righting a wrongful rejection of hazardous materials by air carrier acceptance personnel. While shippers have some flexibility to vary the "format" of the DG Declaration in the ways listed above, doing so has clearly caused delays in some cases.

The fact that carriers rejected shipments over minuscule details shows that even insignificant changes to the IATA regulations can affect stakeholders in substantial ways. To avoid delays, inefficient repetition of work, or even being mistakenly reported, shippers of dangerous goods must remain aware of revisions to US and international regulations from year to year. This is especially true for shippers of hazmat by air and vessel.  

Do your DG shipments comply with the latest IATA DGR requirements, in effect as of January 1, 2025? Are you prepared for more substantial changes coming in 2026? Attend the IATA Hazmat Air Shipper Certification Webinar to expand your knowledge about international air shipping regulations, and feel confident about meeting your responsibilities for compliance with the IATA regulations.