Lithium batteries cause more air freight headaches than almost any other commodity. Partly because the rules change every year, partly because half the industry doesn't fully understand them, and partly because airlines each have their own additional restrictions on top of IATA's baseline rules.

If you're shipping lithium batteries from India in 2026, here's what you actually need to know.

Two Types, Very Different Rules

Lithium ion (rechargeable) and lithium metal (non-rechargeable) batteries are both Class 9 dangerous goods, but they have different UN numbers and different packing instructions:

• Lithium ion cells: UN3480, PI 965
• Lithium ion batteries packed with equipment: UN3481, PI 966
• Lithium ion batteries contained in equipment: UN3481, PI 966
• Lithium metal cells: UN3090, PI 968
• Lithium metal batteries packed with equipment: UN3091, PI 969

The packing instruction is not interchangeable. A phone shipped with its battery inside is UN3481, PI 966 — contained in equipment. The same phone shipped separately from a spare battery becomes two line items with different PIs.

State of Charge Matters

For Section II lithium ion batteries shipped alone (UN3480), the state of charge must not exceed 30% of rated capacity. This is actively enforced. Some airlines ask for test documentation proving SOC compliance. If you're shipping EV batteries or large format cells, this becomes a significant logistics consideration — someone needs to discharge them to 30% before packaging.

Passenger vs. Cargo Aircraft

Many lithium battery shipments are restricted to cargo aircraft only (CAO). Section II quantities under PI 965 can go on passenger aircraft in limited quantities, but Section IA (above the 300 Wh per battery threshold for cells) is cargo aircraft only without exception.

Check your PI section before booking. If your airline doesn't know the difference between Section IA, IB, and II for PI 965, find a different airline or a different ground handler.

Indian Export Reality

India is a major exporter of electronic goods, EV components, and power storage systems — all involving lithium batteries. IGI Airport's DG acceptance desk sees lithium battery shipments daily. The most common rejection reason we encounter: wrong Section under PI 965/966, or missing test summary (required for Section IA).

The test summary is a manufacturer document certifying the battery meets the UN 38.3 test series. Without it, Section IA shipments don't fly. Period.

Airline-Specific Restrictions

IATA DGR gives you the baseline. Airlines add their own layers. Air India has specific restrictions on lithium battery quantities per flight. Emirates limits certain large-format batteries entirely. Some carriers require advance notification 48-72 hours before arrival.

We always check airline-specific DGR addenda before booking a lithium battery shipment. What flew on IndiGo last week may not fly on Air India today.

Domestic vs. International

For domestic flights within India, DGCA's CAR Section 8 applies. The rules broadly align with IATA DGR but there are differences. Most Indian domestic carriers have additional internal policies. If you're shipping lithium batteries domestically by air, confirm acceptance in writing before drop-off.

Nine classes. Dozens of sub-divisions. Hundreds of UN numbers. The DG classification system can feel overwhelming at first, but once you understand the logic behind it, it becomes surprisingly navigable.

Here's a practical breakdown of all nine classes — focused on what Indian shippers and exporters actually encounter.

Class 1 — Explosives

Six divisions, from 1.1 (mass explosion hazard, like dynamite) to 1.6 (extremely insensitive articles). In commercial air freight from India, Class 1 is rare. Fireworks, pyrotechnic devices, safety fuses, and certain ammunition are the typical items. All require DGCA permits and are usually restricted to cargo aircraft only. Most airlines decline them entirely unless pre-arranged.

Class 2 — Gases

Three types: flammable (like LPG, butane), non-flammable non-toxic (nitrogen, argon, CO2), and toxic (chlorine, ammonia). Aerosols also fall under Class 2. The main practical issue for Indian exporters: fire extinguishers, gas cylinders, and camping stoves are Class 2, and they come up frequently in e-commerce exports. Each has specific quantity limits and PI requirements.

Class 3 — Flammable Liquids

This is one of the busiest DG classes in air freight. Paint, adhesives, perfumes, hand sanitiser (above 24% alcohol), solvents, and fuels are all here. The flash point determines packing group. Below 23°C = PG I or II. 23°C to 60°C = PG III. Above 60°C is generally not Class 3 at all. Perfume exporters from India need to pay close attention here — many luxury fragrance shipments trigger Class 3 requirements.

Class 4 — Flammable Solids, Self-Reactives, and Pyrophorics

Three divisions: 4.1 (flammable solids, including matches and desensitised explosives), 4.2 (spontaneously combustible — catches fire in air), and 4.3 (dangerous when wet — reacts with water to produce flammable gas). White phosphorus and certain metal powders are 4.2 and 4.3 respectively. These are relatively uncommon in general export but critical to recognise when present.

Class 5 — Oxidising Substances and Organic Peroxides

Oxidisers (5.1) accelerate combustion — hydrogen peroxide, ammonium nitrate, bleaching powder. Organic peroxides (5.2) are both oxidisers and potential fuels. Organic peroxides often need temperature control during transport, adding another layer of complexity. Hair bleaches, certain industrial chemicals, and textile treatment agents fall here.

Class 6 — Toxic and Infectious Substances

Division 6.1 is toxic substances — poisons, pesticides, heavy metal compounds. Division 6.2 is infectious substances: Category A (can cause permanent disability or fatal disease — Ebola, anthrax) and Category B (diagnostic samples, patient specimens). The distinction between Category A and B determines the packaging specification dramatically. Getting this wrong isn't just a regulatory problem — it's a public health risk.

Class 7 — Radioactive Material

The most heavily regulated class. Medical isotopes, industrial gauges, and research samples. Requires AERB and DGCA clearance in India. Type A and Type B packages, transport indices, radiation level labels — all specific to the isotope and activity level. We have a full dedicated article on this if you're shipping Class 7.

Class 8 — Corrosives

Battery acid (sulphuric acid), caustic soda, hydrochloric acid, and many industrial cleaning agents. Corrosives are defined by their ability to irreversibly damage skin or steel. Packing group is based on the degree of that damage. Wet cell batteries are Class 8. A common surprise for Indian exporters: certain eco-friendly cleaning products still qualify as Class 8 depending on pH.

Class 9 — Miscellaneous Dangerous Goods

Everything that doesn't fit neatly elsewhere. Lithium batteries are the biggest Class 9 category in air freight. Dry ice (UN1845, used for cold chain) is Class 9. Magnetised material, elevated temperature substances, and environmentally hazardous substances (marine pollutants) are also Class 9. Don't underestimate this class — it generates more cargo rejections than most others simply because shippers don't recognise it as DG at all.

A lot of Indian companies discover they have a DG compliance problem only when a shipment gets rejected at the airport. By then, the customer is waiting, the export deadline has passed, and everyone is scrambling. There's a better way to handle this.

Here's a clear-eyed look at what IATA DGR compliance actually requires from an Indian shipper — no jargon, just the practical reality.

Start With a DG Assessment

Before anything else, you need to know whether your products are dangerous goods. This sounds obvious but it's genuinely where many companies fall short. The classification isn't based on how dangerous the product seems to you — it's based on specific physical and chemical properties tested against UN criteria.

Batteries, paints, adhesives, fragrances, aerosols, cleaning chemicals, medical samples, printed circuit boards containing lithium batteries — all are DG. We've seen companies shipping these for years through air freight not knowing they were non-compliant, because nothing had been rejected yet. "Nothing went wrong" is not the same as "we were compliant."

Your Obligations as a Shipper

Under IATA DGR Section 1.3, the shipper is responsible for classifying the goods correctly, selecting the right packing instruction, using UN-certified packaging, preparing the Shipper's Declaration, and ensuring all staff involved in the process are trained.

You cannot delegate your shipper's responsibility to a freight forwarder. You can get help — and you should — but the legal responsibility under Aircraft Act 1934 and DGCA CAR Section 8 sits with the person whose name is on the Shipper's Declaration.

Documentation That Must Be Right

Three documents matter most: the Shipper's Declaration for Dangerous Goods (SHDG), the Air Waybill (which must reference the DG), and the packing list. The SHDG must be completed in English, in the exact format specified in IATA DGR, with no abbreviations not defined in the regulations, and signed by a currently certified DG professional.

The DGR edition year matters. If you're using a template from 2022 and the format changed in 2024, it can be rejected. This happens more than you'd think.

Training Is Not Negotiable

Every person who prepares or approves a Shipper's Declaration must hold a valid IATA DG Category 6 training certificate or equivalent. Valid means completed within the last 24 months. The training provider must be IATA-approved.

In India, approved training centres operate in Delhi, Mumbai, Bangalore, and Hyderabad. The Dangerous Goods Advisory Council (DGAC) India also offers certified courses. Cost ranges from Rs 8,000 to Rs 25,000 for a standard Category 6 initial course.

What Airlines Check Beyond the Declaration

Airlines don't just check your paperwork. The acceptance agent physically inspects the package. They check that hazard labels are correctly oriented (they shouldn't be upside down — yes, this gets flagged). They check that the handling label matches the class. They check net quantities against PI limits. They check that the outer packaging shows no leakage, damage, or contamination.

On certain routes and carriers, acceptance can take 45-60 minutes per consignment. Factor that into your cut-off time calculations.

When You Have Multiple DG in One Shipment

Dangerous goods of different classes can't always be packed together. The IATA DGR Segregation Table (Table 9.3.A) specifies which classes are compatible and which must be separated. Class 1 and Class 3 together, for instance, is forbidden. Getting segregation wrong means the entire consignment gets rejected.

You've identified that your product is a dangerous good. You need UN-certified packaging to ship it by air. Now what? This is the part most guides skip — the actual process of getting compliant packaging for your specific product in India.

What You Need to Know Before You Call a Supplier

Before approaching any packaging supplier, you need three pieces of information: the UN number of your product, the packing group (I, II, or III), and the packing instruction from IATA DGR (or ADR/IMDG for surface transport). Without these, you can't verify whether a supplier's product is actually suitable for your application.

Get these from IATA DGR Table 4.2 (the DG list) or from a qualified DG consultant. Don't rely on the supplier to determine your packing group — that's your responsibility as the shipper.

The Testing Standards That Apply

UN packaging is tested against Chapter 6.1 of the UN Model Regulations. The tests are rigorous: a drop test (from 1.8m for PG I, 1.2m for PG II, 0.8m for PG III), a stacking test (24 hours under load equivalent to 3m stack height), a leakproof test for liquids, and hydraulic pressure tests for inner receptacles.

Temperature cycling tests apply for certain materials. If your product is shipped in extreme temperatures (common for India's summer conditions), the packaging must hold up across the full temperature range it will encounter.

Approved Test Laboratories in India

In India, UN packaging certification for domestic manufacturers is issued through CPCB (Central Pollution Control Board) approved test laboratories. These include labs in Delhi, Mumbai, Pune, and Chennai. The lab tests the packaging and issues a test certificate — that certificate, along with the UN marking on the box itself, is what makes your packaging compliant.

If you're importing packaging from a foreign manufacturer, their certification from their home country's competent authority is generally acceptable. Ask for the original test report, not just a marketing certificate.

Common Package Types and Their Codes

• 1A1/1A2 — Steel drums (closed head / open head)
• 3A1/3A2 — Aluminium drums
• 4G — Fibreboard box (most commonly used for combination packages)
• 4H2 — Solid plastic box
• 6HA1 — Composite packaging, plastic receptacle in steel drum

The code on the package must match the code specified in your packing instruction. If PI 364 for your UN number specifies 4G/Y, only 4G boxes marked Y (suitable for PG II and III) will be accepted.

Combination Packaging — Understand the System

Most DG shipments use combination packaging: an outer UN-certified container with one or more inner receptacles. The inner receptacles (glass vials, plastic bottles, metal cans) do not themselves need UN certification — but the combination of inner plus outer is what gets tested as a system.

This means you can't swap out inner containers arbitrarily. If the test was done with 100ml glass vials and you switch to 150ml plastic bottles, the certification may no longer apply. When in doubt, ask the packaging manufacturer whether your specific inner packaging is covered by their test report.

Where to Source DG Packaging in India

Several manufacturers in India produce UN-certified packaging: companies in the industrial packaging hubs around Mumbai (Thane, Bhiwandi), Delhi NCR (Bahadurgarh), and Pune. For export-grade fibreboard boxes, look specifically for manufacturers who hold CPCB test certificates and can provide reports on request.

We can recommend suppliers based on your specific UN number and packing group if you reach out to us. It's faster than testing random suppliers yourself.

Class 7 radioactive material air cargo in India is handled by a very small number of entities who understand the overlapping requirements of IATA DGR, IAEA safety standards, AERB regulations, and DGCA's CAR Section 8. Most freight forwarders simply don't touch it. Here's an inside look at how it actually works.

Who Ships Class 7 in India

Three main segments dominate Class 7 air cargo movements in India:

Nuclear medicine hospitals and radiopharmacies — shipping short-lived isotopes like Tc-99m, I-131, and Ga-68. These move domestically by air between radiopharmacy production centres and hospitals, and internationally for export of radiopharmaceuticals.

Industrial radiography companies — using Ir-192 and Se-75 sources for NDT inspections of welds and pipelines. These companies operate across India, moving sources between job sites.

Research institutions — universities and research labs occasionally ship radioactive sources for calibration or research purposes, typically under AERB research reactor licences.

The Regulatory Stack in India

This is where it gets complicated. Shipping Class 7 by air in India requires compliance with all of the following simultaneously:

• IATA DGR — International transport standards
• IAEA Safety Standards (TS-R-1 / SSR-6) — UN-level requirements for radioactive material packaging
• AERB — Transport authorisation from Atomic Energy Regulatory Board under AERB Safety Code No. AERB/NRF-TS/SC-1
• DGCA CAR Section 8 — Aviation-specific DG requirements in India
• Aircraft Act 1934 — Overarching legal framework

Missing any one of these is enough to get the shipment stopped.

AERB Transport Consent — The Critical Document

Every radioactive material shipment in India requires AERB transport consent before it can legally move. For air transport, this means AERB reviews the package design, the source activity, the route, and the shipper's transport management plan.

For Type A packages (lower activity, like most medical isotopes), this process is relatively streamlined for registered consignors. For Type B packages (higher activity industrial sources), the process involves formal package design review and can take weeks to months for first-time applicants.

The consent is valid for a defined period and number of consignments. It must be renewed when it expires.

Labelling That's Unique to Class 7

Unlike other DG classes, Class 7 packages carry radiation category labels specific to surface radiation dose rates and transport indices:

• Category I White — Surface dose rate ≤ 0.005 mSv/h, Transport Index = 0
• Category II Yellow — Surface dose rate up to 0.5 mSv/h, TI ≤ 10
• Category III Yellow — Surface dose rate up to 2 mSv/h, TI ≤ 10

The transport index directly affects how many packages can be on a single aircraft. There are cumulative TI limits per compartment per flight. Airlines load Class 7 packages separately from other cargo for this reason.

The Time Pressure on Medical Isotopes

Tc-99m has a half-life of 6 hours. I-131 has a half-life of about 8 days. These are not the same planning problem. Tc-99m needs to be at the hospital scanner within hours of production. Getting a flight booking wrong — or having a shipment held at acceptance for paperwork — can waste the entire dose.

We have standing protocols with the acceptance teams at CSIA Mumbai and IGI Delhi for medical isotope shipments. Pre-notification, pre-cleared documentation, and priority handling are standard procedure for us, not exceptions.

The Shipper's Declaration for Dangerous Goods (SHDG) is the document that everyone in DG air freight talks about — and yet it remains the single most common cause of shipment rejection. Usually not because people don't know it exists, but because they get the details wrong under time pressure.

Here's a step-by-step walkthrough, written for someone who has to actually complete one.

What the Declaration Is and Isn't

The SHDG (IATA calls it the "Shipper's Declaration for Dangerous Goods," some airlines call it the DGD) is your formal attestation to the airline that the shipment is fully compliant with all applicable regulations. It's a legal document. Signing it incorrectly — or signing it when it isn't compliant — is a criminal offence under most national aviation laws, including India's Aircraft Act 1934.

It is not a customs document. It is not an invoice. It doesn't replace the Air Waybill. It exists alongside these documents as the DG-specific declaration.

The Format Requirements

The SHDG must be:

• In English
• Printed on paper (not completed by hand for air freight)
• In the standard two-column format specified in IATA DGR Chapter 8
• Completed using the exact proper shipping names from IATA DGR — no abbreviations, no trade names
• Signed by a currently certified DG professional (certification valid within 24 months)

Electronic submission is now accepted by some carriers, but the data elements remain identical. If you're using an e-freight system, it must be configured to produce a compliant SHDG output.

Filling It In — Field by Field

Shipper / Consignee: Full name and address. No abbreviations. The name must match the Air Waybill.

Two blank boxes at top: Check "Radioactive" or "Non-Radioactive." Most shipments are Non-Radioactive. Mark it. Leaving it blank is an error.

Airport of Departure / Destination: IATA airport codes are acceptable here. DEL, BOM, SIN, LHR.

UN or ID No.: The full UN number. UN3480, not just "3480." The "UN" prefix is mandatory.

Proper Shipping Name: From Column 2 of IATA DGR Table 4.2. Exactly as written. "LITHIUM ION BATTERIES" not "Li-ion batteries." Capitalisation matters for some systems.

Class or Division: The primary hazard class. For UN3480, it's "9." For dual-hazard substances, additional hazard class appears in brackets.

Packing Group: I, II, or III. Or "—" if not assigned (applicable to Class 7 and some Class 2).

Quantity and Type of Packing: This is where most errors happen. You must state the number of packages and the net quantity per package — not total shipment weight. "3 packages, 500g net per package" is correct. "1500g total" is not.

Packing Instruction: The PI number from IATA DGR. PI 965, PI 306, PI 650 — depends on your substance and class.

Authorization: If your goods require a State or competent authority approval (Class 7, certain Class 1), the reference number goes here.

Passenger vs. Cargo Aircraft

You must check either "Passenger and Cargo Aircraft" or "Cargo Aircraft Only." Never leave this unchecked, never check both. The PI for your substance specifies which is permitted.

The Signature Block

The signatory must be an individual — not a company stamp — who holds current DG training certification. Their name should be printed clearly under the signature, and the date of signing is mandatory. Some carriers also ask for the training certificate number in this field.

If your certification expired two months ago and you sign a declaration, the airline will reject the shipment at acceptance and may report the violation to DGCA.

One Final Practical Note

Prepare the declaration early. Don't complete it at the acceptance counter under time pressure. Errors made in haste cause rejections, missed flights, and detention charges. Keep a template for your regular DG lines, but review it against the current DGR edition at least once a year.

Delhi's Indira Gandhi International Airport handles one of the highest volumes of DG air cargo in India. It's also where we see the most complex acceptance situations — partly because of the volume, partly because IGI serves as a hub for both domestic and international DG movements.

If you're planning to ship dangerous goods from Delhi, here's what the process actually looks like on the ground.

The Cargo Terminals at IGI

IGI Airport has multiple cargo complexes. The main international cargo hub is operated by Delhi International Airport Limited (DIAL) through cargo handlers like CELEBI Delhi Cargo Terminal, AI Airport Services (Air India's ground handling arm), and others. For DG specifically, each airline's ground handler operates its own DG acceptance facility.

You bring your DG shipment to the specific handler for the airline you're booked on — not a general cargo reception. Getting this wrong can cost you two to three hours and a missed cut-off. Know your airline and their ground handler before you arrive.

Typical Cut-Off Times

DG cargo at IGI generally requires acceptance 3-4 hours before departure for international flights, and 2-3 hours for domestic. These are minimums — not comfortable targets. Bring DG early. The acceptance process includes a physical inspection, documentation review, and sometimes supervisor sign-off. It takes time.

Night-before drop-off is possible for many DG shipments if the airline offers it. For time-sensitive materials like medical isotopes, we always try to get the shipment accepted the evening before the flight rather than on the day.

What the Acceptance Team Will Ask For

Arrive with: the Shipper's Declaration (two copies — one for the airline, one returned to you as receipt), Air Waybill, packing list, any required competent authority approvals (for Class 1, Class 7), and if applicable, the MSDS (Material Safety Data Sheet) for the substance. Some carriers also request a copy of the shipper's DG training certificate for verification.

The acceptance agent checks documents, then physically inspects the package. They look at labelling, orientation arrows if required, package condition, and that all required marks are present and legible.

The DGCA FICV System

India's DGCA operates a Freight and Import/Export Control Verification (FICV) system for certain DG categories. For Class 7 and Class 1, and in some cases for new routes or new shippers, FICV verification may be required before acceptance. This involves DGCA's aviation security staff physically verifying the shipment against the declaration.

For regular DG shippers on established lanes, this is usually a smooth process. For first-time DG shippers from IGI, build in extra time.

Common Rejections at IGI We See

From our experience at IGI: the top rejection reasons are mismatched quantities between the declaration and physical contents, outdated DGR edition on the declaration template, missing or incorrect radiation labels (for Class 7), and lithium battery state-of-charge documentation not available. Secondary reasons include wrong packaging — certified for PG III but product is PG II — and improper orientation labels on liquid packages.

Working With a DG-Qualified Forwarder

Having your own certified DG staff is ideal. But for companies that ship DG occasionally, working with a forwarder who has DG-qualified acceptance staff at IGI is a practical alternative. Not all forwarders do. Ask specifically whether their IGI operations team includes IATA DG Category 6 certified personnel before handing over your shipment.

We handle DG acceptance and documentation at IGI as part of our standard service. Reach out if you're shipping something you're not sure about — better to ask before the airport than at the airport.

India is the world's largest supplier of generic medicines and one of the top exporters of vaccines globally. Most of this cargo moves by air, and a growing proportion of it is temperature-sensitive. Getting pharma cold chain right is not just about regulatory compliance — a damaged batch of biologics can mean a patient somewhere doesn't get treatment.

This is what we've learned from years of handling temperature-sensitive pharma shipments out of Hyderabad, Ahmedabad, and Mumbai.

The Regulatory Framework for Pharma Cold Chain

Temperature-sensitive pharma air cargo sits at the intersection of multiple regulatory requirements. The IATA Temperature Control Regulations (TCR) provide the baseline. GDP (Good Distribution Practice) guidelines from WHO and the EU govern the quality management side. The destination country's import health requirements add another layer.

In India, CDSCO (Central Drugs Standard Control Organisation) requirements apply to the shipper. If your product is a Schedule X drug or a controlled substance under NDPS, additional permits are needed at both export and import.

Validated Packaging vs. Assumed Packaging

This is the biggest source of risk we see in practice. A validated packaging system has been tested — under summer profile and winter profile conditions — to maintain its temperature range for a defined duration. The test is documented in a validation report from the packaging manufacturer.

An assumed packaging system is one where someone decided it "should be fine" based on past experience or intuition. In a business as regulated as pharma logistics, assumption is not a valid quality management approach.

When we onboard a new pharma client, one of the first things we ask for is their packaging validation documentation. If they don't have it, we help them procure validated solutions before the first shipment moves.

The Hyderabad-to-Europe Problem

Many of India's major pharma manufacturers are based around Hyderabad (Genome Valley) and export to Europe. The typical routing is Hyderabad to Frankfurt or Amsterdam via a hub like Dubai or Istanbul. Total transit time: 12-18 hours plus ground handling time at both ends.

A 2-8°C shipment in passive insulated packaging typically has a qualified autonomy of 48-96 hours depending on the packaging system. That sounds like plenty of buffer. But consider: if there's a weather delay in Dubai, if the shipment misses a connection, if customs clearance in Frankfurt takes longer than expected — that buffer disappears fast.

We route high-value pharma with deliberate buffers built in. Conservative choice of routing, conservative choice of packaging performance, pre-booked priority handling at transit points.

Data Loggers Are Non-Negotiable

A data logger inside every shipment is standard practice. Not optional. Some regulated markets like the EU and the US FDA-regulated market will ask for logger data as part of import documentation. Even where it's not required, a temperature excursion without a logger record means you can't determine when the breach happened, how severe it was, or who was responsible.

Use calibrated loggers with a valid calibration certificate. A Rs 200 disposable logger from a stationery shop is not a calibrated instrument. It will not satisfy a GDP audit.

When Dry Ice Is Involved

Dry ice (solid CO2) is a Class 9 dangerous good — UN1845. The maximum quantity per package varies by packing instruction, and the Air Waybill must declare it. Airlines limit total dry ice weight per flight.

Dry ice sublimates during transport, which means the package weight changes and the CO2 concentration in a confined cargo space builds up. This is why there are ventilation requirements for dry ice shipments. If you're packaging with dry ice, your packaging must accommodate the sublimation and prevent dry ice from contacting any biological product directly.

Temperature-Controlled Trucking Within India

The cold chain often breaks down before the airport, not during the flight. Pre-carriage from a manufacturing plant to the cargo terminal needs temperature control too. We operate reefer vehicles with real-time temperature monitoring for pre-carriage of pharma cargo.

The data logger record should cover the entire door-to-door journey — plant to airport to final destination. Gaps in the record are gaps in compliance.

After years of handling DG cargo — and receiving calls from panicked clients after their shipments get rejected — certain mistakes come up again and again. These aren't obscure edge cases. They're common errors that cost companies money, delay shipments, and sometimes create regulatory liability.

Here are the five we see most often.

Mistake 1: Not Classifying at All

The most common and most expensive mistake. A company ships paints, solvents, adhesives, batteries, or chemical samples for years through air freight and nobody ever checks whether they're DG. Often it goes fine — until an alert acceptance agent or a new airline's stricter checks flag it.

At that point, the company discovers their entire export process has been non-compliant. Retroactively, every previous shipment was also a violation. Under Aircraft Act 1934, this can result in serious penalties.

The fix: do a DG assessment for every product you ship by air. It takes a few hours with a qualified consultant and it eliminates years of potential liability.

Mistake 2: Using Outdated Packing Instructions

IATA DGR is revised every year. Packing Instructions change. Quantity limits change. Section numbers change. A company that set up its DG process when they first started exporting and hasn't updated it since is almost certainly using outdated PIs for at least some of their products.

We've seen this most frequently with lithium batteries — the rules changed significantly between the 62nd and 65th Editions — and with infectious substances, where Category A/B thresholds were revised.

The fix: review your DG compliance documentation against the current edition of IATA DGR every January when the new edition releases. At minimum, have a qualified DG person do the review.

Mistake 3: Expired Training Certificates

IATA DG training is valid for 24 months. After that, the person cannot legally sign a Shipper's Declaration. But in busy operations, renewal dates get missed. The person keeps signing. The airline has no way to verify on the spot — they check the date on the certificate if asked, but they're not always asked.

This works until it doesn't. If a rejected shipment triggers a DGCA inquiry, expired training certification compounds the violation significantly.

The fix: keep a training register with expiry dates. Set calendar reminders 3 months before expiry. Treat DG training renewal like a licence — because that's what it is.

Mistake 4: Wrong Packaging for the Packing Group

A company sources "UN-certified packaging" and assumes it works for everything. But UN certification is specific to a packing group. A box marked "Z" is only suitable for Packing Group III substances. If your substance is PG II, you need a "Y" or "X" rated box.

This is particularly common with companies that pack a range of products — some PG II, some PG III — and use the same box type for all of them.

The fix: read the UN mark on your packaging. Check the suitability letter (X, Y, or Z) against the packing group of every substance you pack in it. If there's a mismatch, source the right packaging before shipping.

Mistake 5: Assuming the Forwarder Handles Compliance

We hear this one often: "We gave it to our freight forwarder — aren't they responsible for DG compliance?" No. Under IATA DGR and all national aviation laws, the shipper is responsible for classifying the goods, preparing the Shipper's Declaration, and ensuring packaging compliance. A forwarder who takes over the paperwork is acting as the shipper's agent — the legal responsibility remains with the shipper.

Some forwarders do offer full DG compliance services as an added service. That's helpful. But it doesn't transfer liability. If the declaration is wrong, DGCA looks at the company whose name is on the document, not the forwarder's company name.

The fix: own your DG compliance. Understand what's required, ensure your team is trained, and don't outsource your legal responsibility even if you outsource the paperwork execution.

When Indian companies ask about DG shipping by air, there's a specific question that comes up regularly: "Do I need to follow DGCA rules, or IATA rules, or both?" The answer is both — but understanding what each one covers, where they overlap, and where they differ makes the whole picture much clearer.

The Short Answer

IATA DGR is the international standard used by airlines globally. DGCA CAR Section 8 is India's aviation regulator's requirement, which has the force of law in India. When you ship DG by air from India, both apply simultaneously. Where they differ, the stricter requirement wins.

IATA DGR — What It Is and Who Uses It

The International Air Transport Association publishes the Dangerous Goods Regulations annually. It's not a law in itself — it's a technical standard that IATA member airlines agree to implement. But because virtually every international airline is an IATA member, IATA DGR has effectively become the global operating standard for air DG.

IATA DGR covers classification, packing instructions, quantity limits, marking, labelling, documentation, and handling. It's updated every January, incorporating changes from ICAO's Technical Instructions (Doc 9284), which is the UN-level standard that IATA DGR is based on.

DGCA CAR Section 8 — What It Is

DGCA's Civil Aviation Requirements Section 8 is the Indian government's regulatory framework for dangerous goods transport by air. It's published by the Directorate General of Civil Aviation under the Aircraft Act 1934. Violation of CAR Section 8 is a violation of Indian law.

CAR Section 8 is largely aligned with ICAO Technical Instructions and by extension IATA DGR. But it includes India-specific additions — particularly around certain substances that need prior clearance from Indian authorities (AERB for Class 7, relevant ministry permits for certain controlled substances), and around domestic carrier requirements.

Where They're the Same

For the vast majority of DG air shipments — Class 3 flammable liquids, Class 8 corrosives, Class 9 lithium batteries, most Class 6.2 infectious substances — the IATA DGR requirements and CAR Section 8 requirements are effectively identical. Classification criteria, packing instructions, documentation requirements, training requirements — same standard, same outcome.

Where They Differ — The Practical Differences

Domestic vs. International: IATA DGR primarily governs international air transport. For domestic flights within India (Delhi to Bangalore, Mumbai to Chennai), DGCA CAR Section 8 and the airline's own DG manual govern. Some Indian carriers are more restrictive than IATA DGR for domestic operations — IndiGo, for example, has specific limitations on DG quantities per flight that go beyond the IATA baseline.

Radioactive Material: This is where the difference is most significant. IATA DGR covers the international transport standards for Class 7. CAR Section 8 adds the AERB and DGCA permit requirements that are unique to India. No AERB transport consent = shipment cannot move, regardless of IATA DGR compliance.

Narcotics and Controlled Substances: Pharmaceutical products containing narcotics or psychotropic substances need NDPS permits from India's Narcotics Control Bureau on top of standard DG compliance. This is a CAR Section 8 and domestic legal requirement, not something addressed in IATA DGR.

Training Recognition: IATA DGR specifies training requirements (Categories, recurrency intervals) and DGCA recognises these. However, DGCA may in some cases require additional documentation of training from DGCA-approved providers for Indian operators and ground handlers.

Practical Implication for Your Shipments

For most routine DG shipments from India — batteries, chemicals, flammable liquids — meeting IATA DGR compliance also means meeting CAR Section 8 compliance. You don't need to run two separate compliance processes.

Where you do need to look specifically at CAR Section 8 in addition to IATA DGR: anything involving Class 7, anything involving controlled substances, any domestic India air movement, and any situation where a DGCA inspector is involved (like an audit or a post-incident investigation).

If you're setting up a DG compliance programme for your organisation, build it on IATA DGR as the foundation, then check for India-specific additions under CAR Section 8 for your specific product categories and routes. That covers you on both fronts.