By Landy Yao    Photo：CANVA

1. Background: Why "General Cargo" Also Gets Stopped

Air freight is held to a far higher safety standard than ocean freight, especially when cargo rides in the belly hold of a passenger aircraft. The hold is enclosed and exposed to reduced air pressure and temperature changes, so any leak, heat source or magnetic interference can escalate into a serious incident. IATA's Dangerous Goods Regulations (DGR) are revised every year, with updates to classification, packaging and declaration requirements.

The industry applies one simple test: goods whose hidden hazards cannot be ruled out, or that cannot be correctly classified and identified, usually need air transport identification. Reports such as the Identification and Classification Report for Air Transport of Goods are issued by third-party laboratories with the relevant qualifications or accreditation, such as CMA or CNAS. The findings establish whether the goods qualify as general cargo or must be handled as a specified class of dangerous goods.

Six categories that commonly require it:

1. Powders: metal powder, protein powder, plant extracts, resin powder. Identification is generally required to assess transport hazards such as spontaneous combustion and explosion.
2. Chemicals: liquid, paste and solid chemicals, inks, adhesives, additives. Even "ordinary chemicals" need a general-cargo identification to evidence their non-hazardous nature.
3. Liquids and gases: perfume, alcohol-based personal care products, mercury thermometers, barometers, sealed cans.
4. Oil-containing cargo: engines with residual oil, carburettors, camping equipment containing kerosene or petrol.
5. Battery-powered cargo: lithium batteries, power banks, devices with installed batteries. Lithium batteries fall under Class 9. Prepare UN38.3 test information and any air transport identification required by the carrier. Standalone lithium-ion batteries (UN3480) must be offered at no more than 30% state of charge and are restricted to cargo aircraft. From 2026, the 30% limit also applies to lithium-ion batteries packed with equipment under PI 966, Section I, and to cells or batteries over 2.7 Wh under Section II. For batteries installed in equipment under PI 967, reduced charge remains a recommendation; the PI 966 rule does not apply to all installed batteries.
6. Magnetic cargo: magnets, speakers, motors, headphones, magnetic accessories. Under current PI 953, check for classification as Class 9 magnetized material (UN2807) when the fully packed shipment causes compass deflection of more than 2° at 2.1 m. The field strength at 4.6 m must not exceed 0.418 A/m. If it does, shield and re-test; a shipment still above the limit is not accepted through the normal air cargo process, with special approvals handled separately. SN/T 2169-2008, still listed as current, uses ≥0.159 A/m at 2.1 m in its test criteria, and the figure remains common in practice. Exceeding it alone does not establish classification under current PI 953.

Genuinely ordinary cargo, such as cotton garments, plain plastic items and hardware with no special composition, normally needs no identification, provided it contains no powder, liquid, magnetism or battery and its MSDS shows no hazardous properties.

2. The Five-Step Process

Step 1: Self-assessment. Pull the latest MSDS and focus on Section 14 (UN number, proper shipping name, packing group) and Section 2 (GHS pictograms). A flame, corrosive or skull-and-crossbones symbol calls for a dangerous-goods assessment before offering the goods as general cargo. Use the transport classification, not the GHS symbol alone, to determine the category.

Step 2: Choose the lab. Pick a laboratory that holds the relevant qualifications or accreditation, such as CMA or CNAS, and is accepted by your carrier and the departure airport or cargo terminal. Have your forwarder check the accepted scope before applying. A report from a laboratory the carrier does not accept is one of the most common causes of refusal.

Step 3: Prepare documents. Application form (tick "air"), bilingual MSDS, composition sheet with CAS numbers and percentages, product specification, business licence. For lithium batteries, prepare UN38.3 test information and provide the report, test summary or other evidence required for acceptance. Where the applicable packing instruction requires 1.2 m drop capability, prepare the relevant packaging evidence; this is not a blanket requirement for every battery-powered device.

Step 4: Submit samples. Roughly 50 to 200 g for solids, 100 to 200 ml for liquids; samples must match the actual shipment in composition, model and specification. Magnetic testing is special: it must be done on the fully packed consignment, measuring all six faces in its real shipping packaging. Bare-unit readings are invalid.

Step 5: Receive and use the report. For standard processing, generally allow 3 to 5 working days; where expedited service is available, 1 to 2 days may be feasible. Additional testing takes extra time. The report gives the classification and any applicable UN number, packing instruction and restrictions. In mainland China, annual air transport reports are generally valid until 31 December of the year they cover. Changes to formulation, model or packaging must remain within the report's scope; a changed magnetic packing configuration requires re-testing.

3. Common Mistakes and Cautionary Cases

Mistake 1: Using a sea report for air. Air follows IATA DGR, sea follows IMDG. The same consignment can perfectly well be "general cargo by sea, dangerous goods by air." A report covering sea transport alone cannot replace an air transport assessment.

Mistake 2: Substituting MSDS for the report. MSDS is a product safety data sheet, not a substitute for a third-party identification. Where a formal report is required for acceptance, an MSDS alone is not enough.

Mistake 3: Assuming small magnets pass. One small magnet is weak; a carton densely packed with them produces a stacked field that exceeds the limit. After shielding, you must re-test: airport instruments do not accept "I wrapped it in two layers of sheet metal."

Mistake 4: One report for dual-sensitivity goods. A Bluetooth speaker contains both a driver and a lithium cell. Check both its magnetic properties and battery transport conditions, and prepare the assessment documents required for acceptance. Checking one does not cover the other.

Case A: Concealment costs far more than freight. A Shenzhen company exported sensors with built-in lithium cells. The forwarder booked them as general cargo and declared them as "sensor accessories." Security opened the carton, found the batteries, detained the entire shipment and launched a misdeclaration investigation. The company lost RMB 78,000 in logistics costs and its end customer claimed 15% of the contract value.

Case B: The worst-case scenario. In July 2020 at Shanghai Pudong, an Ethiopian Airlines Boeing 777F freighter caught fire and was written off. The investigation concluded the most likely cause was self-ignition of undeclared chlorine dioxide disinfectant tablets in a hot, humid environment. Media estimated the aircraft's price at roughly RMB 2.3 billion; that figure was not an assessed accident loss.

Penalties. Under China's civil aviation dangerous goods rules, a shipper or its agent that fails to disclose dangerous goods or submits information inconsistent with the cargo can receive a warning or a fine of up to RMB 50,000, rising to RMB 50,000 to 100,000 in serious cases. Shipping prohibited dangerous goods, or restricted dangerous goods without meeting the requirements, can attract RMB 20,000 to 100,000. Criminal liability applies where a crime is constituted. Carriers may also recover losses, charge agreed contractual penalties or restrict future acceptance under their transport terms.

4. Practical Advice and Pre-Shipment Checklist

Build in lead time. Start chemicals, powders, magnetic and battery cargo at least 10 to 15 working days ahead, and avoid the year-end rush. New DGR editions take effect on 1 January; annual identification reports need to cover the year of transport. Arrange the next year's report before committing to the shipping schedule.

Keep five documents consistent. Product name, model, composition and other key information on the identification report, MSDS, customs declaration, air waybill and carton labels must correspond to the same cargo. Each document need not repeat every field, but conflicting identities, models or compositions must be corrected before shipment.

Never conceal or mix in sensitive items. If concealment or undeclared items are found, the carrier or its ground handling agent must refuse acceptance and carriage and report the finding as required. The whole shipment can be held up, so do not assume that removing the undeclared items will let the rest move as booked. The shipper may also be held liable.

Pre-shipment checklist:

• Does the cargo contain powder, liquid, paste, gas or residual fuel?
• Does it contain lithium or coin cells? Have you distinguished the battery chemistry and whether batteries are standalone, packed with equipment or installed in it? Is the required UN38.3 information and air identification ready? Where the mandatory 30% rule applies, is the state of charge compliant?
• Does it contain magnets, motors or speakers? Is the magnetic test report valid and was the packed configuration re-tested?
• Does MSDS Section 14 state the transport classification? For dangerous goods, are the UN number and proper shipping name correct?
• Does the report cover the year of transport, the goods and their models, with information corresponding to the customs declaration?
• Air or sea: does the report version match the mode?
• Has the electronic copy been sent to the forwarder and one copy shipped with the goods for re-check at transit and destination?

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