Shipping Cosmetics by Air: Dangerous Goods Checks in 5 Steps

When shipping cosmetics by air, whether a product counts as dangerous goods depends on its properties, such as flammability or compressed gas, and perfumes, alcohol-based mists, aerosol sprays and nail products are the usual suspects.

Perfumery products are commonly UN1266 (Class 3 flammable liquid) and aerosols UN1950, and items like these can only fly if they are classified, packed, marked and declared under the IATA Dangerous Goods Regulations.

Ordinary creams and lotions are usually not dangerous goods, but carriers and forwarders still ask for a safety data sheet (SDS) as evidence.

Undeclared dangerous goods are not just rejected at the airport; the shipper can be prosecuted. Work through these five steps.

Step 1: Before shipping cosmetics by air, sort out likely dangerous goods

The International Civil Aviation Organization divides dangerous goods into nine classes, as Hong Kong’s Civil Aviation Department explains on its dangerous goods page¹. For cosmetics, Class 2 (gases) and Class 3 (flammable liquids) are the ones that come up most.

Swipe sideways to see the whole table.

The UN1266 entry can be checked in the Hong Kong Fire Services Department’s dangerous goods database², and the classification of aerosols (UN1950) in Divisions 2.1 and 2.2 appears in US regulation 49 CFR 173.27³. The same type of product can classify differently depending on its formula, so the final decision rests on each product’s SDS and the regulations.

Step 2: Read the transport section of the SDS

Hong Kong’s Civil Aviation Department advises shippers who are unsure whether goods are dangerous to get the material safety data sheet from the supplier or manufacturer, check the physical and chemical properties, and ask the forwarder or airline for advice.

In the SDS, section 14 (transport information) should show the UN number, proper shipping name, transport hazard class and packing group, or state that the product is not regulated for air transport.

Our guide to MSDS for cosmetics explains how to read an SDS and who issues it.

Step 3: Prepare packaging, marks and labels

Cosmetics classified as dangerous goods must be packed to the IATA Dangerous Goods Regulations (DGR): the prescribed combination of inner and outer packaging, with the UN number, proper shipping name, hazard labels and handling labels on the outer package.

Limited quantity provisions can apply to small inner packagings, but quantity limits and packaging conditions vary by entry, so check them in the current DGR.

IATA publishes a new edition of the DGR every year. Do not reuse last year’s packing specification without checking it against the edition in force when you ship.

Step 4: Have a trained person complete the Shipper’s Declaration

For dangerous goods, the shipper completes a Shipper’s Declaration for Dangerous Goods and hands it to the airline with the cargo.

• Korea: Article 70 of the Aviation Safety Act⁴ requires a permit from the Minister of Land, Infrastructure and Transport to carry dangerous goods by aircraft, and requires anyone packing, loading, storing, carrying or handling them to follow the procedures the Minister publishes. Article 72 requires dangerous goods training, with an exception for training completed at institutions recognised by ICAO or IATA.
• Hong Kong: the Civil Aviation Department states that under the Dangerous Goods (Consignment by Air) (Safety) Regulations (Cap. 384 subsidiary legislation)⁵, shippers and freight forwarders must ensure dangerous goods are properly classified, packed, marked, labelled and documented before offering them for air transport. Breaches carry a fine of HKD 250,000 and two years’ imprisonment.

Step 5: Book with a carrier and forwarder that accept dangerous goods

Not every airline or express service accepts dangerous goods. Before booking, check:

• whether the airline and route accept that UN number and class;
• whether the item may go on passenger aircraft or only on cargo aircraft;
• whether the forwarder will help prepare the declaration and check the packaging.

If dangerous goods restrictions bite or volumes are large, sea freight may be the better option; see air vs sea freight for cosmetics.

Related reading: MSDS for cosmetics · Air vs sea freight for cosmetics

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