Altor guide · 2026-10-30
Dangerous goods in excepted quantities: the 30 mL bottle still has a rule
A 30 mL bottle of acetone is offered as dangerous goods in excepted quantities, and the Shipper's Declaration stays in the drawer.
What dangerous goods in excepted quantities still require
49 CFR 173.4a, eCFR as of 28 October 2026. The amendment note runs through 27 December 2022.
Paragraph (a) lifts most of the subchapter off materials other than articles. Articles such as aerosols sit outside that line. 49 CFR 173.22 classification stays, with incident reporting under 49 CFR 171.15 and 171.16, Class 7 excepted package rules, and the 49 CFR 173.27(c) pressure differential where retention of liquid is a basic function. 49 CFR 173.27(f)(1) points an aircraft excepted quantity at 173.4a.
Paragraph (b) requires passenger aircraft authorization. Allowed: Division 2.2 with no subsidiary hazard, aerosol excluded; Class 3; Class 4 packing groups II and III, self-reactive material excluded; Division 5.1 packing groups II and III; Division 5.2 only in a chemical kit, a first aid kit, or a polyester resin kit; Division 6.1 other than packing group I Hazard Zone A or B; Class 7 radioactive material in an excepted package; Class 8 packing groups II and III except UN 2803 and UN 2809; Class 9 except UN 1845 and lithium batteries and cells.
Paragraph (c): 30 g or 30 mL per inner packaging, except 1 g or 1 mL for a Division 6.1 primary or subsidiary hazard in packing group I or II. Gas water capacity is 30 mL. Paragraph (d), other than Division 2.2 or Division 5.2: packing group I 300 g or 300 mL, packing group II 500 g or 500 mL, packing group III 1 kg or 1 L. Division 2.2 is 1 L. Division 5.2 is 500 g or 500 mL. Two hazardous materials in one outer packaging take the lower aggregate.
Paragraph (e), three layers: inner receptacle of plastic, glass, porcelain, stoneware, earthenware, or metal; intermediate packaging with cushioning; strong rigid outer packaging. Plastic holding liquid is at least 0.2 mm thick. Wire, tape, or another positive means holds a removable closure. Molded screw threads need a leakproof threaded cap. The closure must not react chemically with the material. Absorbent takes the entire liquid contents and must not react dangerously with the material. 49 CFR 173.21 still governs what may share the package. The package stays closed in commerce.
Paragraph (f) requires documented drops from 1.8 m (5.9 feet) onto a solid unyielding surface, with inner packagings filled to not less than 95 percent of capacity for a solid or 98 percent for a liquid. The test passes only with no breakage or leakage of any inner packaging and no significant reduction in effectiveness. A box is dropped flat on the bottom, flat on the top, flat on the longest side, flat on the shortest side, and on a corner at the junction of three intersecting edges. A drum is dropped diagonally on the top chime, diagonally on the base chime, and flat on the side. 49 CFR 178.606(c) is the compressive load. Each test may be run on a different but identical package. The record is not a UN specification mark.
Paragraph (g): a square at least 100 mm by 100 mm, hatching black or red on a contrasting ground. Class or division replaces the single star. Shipper or consignee name replaces the double star when not already printed. On aircraft the whole mark is on one side. An overpack carries the mark when the package mark is hidden. Paragraph (g)(4) does not require the word OVERPACK. Paragraph (h): no shipping paper on highway or rail. On air, no shipping paper unless a document such as an air waybill accompanies the shipment, and that document then uses the statement the paragraph sets and shows the package count. A vessel needs that statement and the count on a shipping paper. Paragraph (i): each person who offers or transports these quantities must know the requirements of this section. Paragraph (j) bars checked and carry-on baggage.
IATA DGR 67th Edition section 2.6 is the air excepted quantity section. UN 1090 Acetone is Class 3, packing group II, code E2: passenger packing instruction 353 at 5 L, limited quantity Y341 at 1 L, cargo packing instruction 364 at 60 L. The 173.4a ceilings for this liquid are 30 mL inner and 500 mL outer, because it is not the Division 6.1 case in paragraph (c)(1). E0 means excepted quantity is not authorized: UN 1845, UN 2809, UN 2803 (named with UN 2809 in the Class 8 exclusion), UN 3480 (forbidden on a passenger aircraft), and UN 1950 rows that print a code.
The mistake people make
Y341 at 1 L, reached on air through 49 CFR 173.27, is a different mark from the square in 173.4a(g). 49 CFR 173.4 is the small quantity rule for domestic highway and rail, and the mark has to name that section and those modes. Lithium batteries and cells are not eligible under 173.4(d). Under 49 CFR 173.4b, an authorized packing group II or III Class 3 package that meets the section does not meet the 171.8 hazardous material definition. Inner 1 mL or 1 g. Aggregate 100 mL or 100 g. A 30 mL inner packaging does not fit. 49 CFR 172.204 and IATA DGR 8.1.6.12 are the fully regulated signature. The shipper signs.
The fix
Class under 173.22 and paragraph (b). Stop on E0. Over either ceiling on UN 1090, use Y341, 353, or 364 at the printed maximum.
If acceptance returned the freight, start here: https://altor.consulting/rejected.html
Altor pre-checks the declaration, cites the section for every finding, and the shipper signs, at altor.consulting.
Catch the rejection before the carrier does
Send your completed declaration before you tender it. A line by line advisory report comes back within 24 hours, every finding cited. $95 flat, one click, and you keep the pen.
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