Altor guide · 2026-09-14

Dry ice: the dangerous good everyone forgets is one

The cooler looks like a food shipment. The dock packed dry ice around the contents and taped the seams. No UN number. No net kilograms. No Class 9 diamond. The booking is an aircraft. The acceptance desk at the cargo terminal does not grade ice. It grades UN 1845. IATA DGR 9.1.3 walks the carton against the current list. A refrigerant the warehouse treated as packaging is a Class 9 dangerous good on the aircraft.

What the regulation actually requires

49 CFR 173.22 keeps classification, description, packaging, marks, and labels on the offeror. Dry ice is carbon dioxide, solid. The current ICAO TI Table 3-1 extract lists it as UN 1845, Class 9, no packing group. Proper shipping name: Dry ice, or Carbon dioxide, solid. Labels: Miscellaneous. Passenger packing instruction 954 at 200 kg. Cargo packing instruction 954 at 200 kg. Excepted quantity: E0. Special provisions A48 and A151.

49 CFR 172.101 prints the same UN with A and W in column 1, so the Hazardous Materials Regulations apply when the material is offered by aircraft or by vessel. Column 9 is 200 kg passenger and 200 kg cargo. Column 8 points packaging to 49 CFR 173.217. Column 6 is none, which is why a truck carton often has no diamond. The cargo terminal grades IATA DGR 9.1.3, not that highway column. 49 CFR 175.30 is the US air acceptance rule next to it.

49 CFR 173.217 is the dry ice packaging section. Packagings offered by aircraft or water have to let carbon dioxide gas escape. A sealed cooler is not that packaging. They must meet 49 CFR Part 173 Subpart B and do not have to meet 49 CFR Part 178. IATA DGR 4.4 special provision A48 is the matching air note: UN specification packaging is not required for this entry. For air, 173.217(c)(1) requires the net mass of the dry ice on the outside of the package. 173.217(c)(2) requires the shipper to make arrangements with the operator. 49 CFR 175.900 is the operator handling rule next to it.

IATA packing instruction 954 is the air packing instruction for UN 1845. The IATA DGR Section 4.2 labels column is Miscellaneous, which on the carton is the Class 9 miscellaneous diamond. When dry ice is used only as a refrigerant for goods that are not dangerous goods, packing instruction 954 does not require a Shipper's Declaration. The air waybill still has to carry UN 1845, the proper shipping name, the number of packages, and the net quantity in each package. 49 CFR 173.217(c)(4) is the matching US shipping paper exception if that same written information is supplied. When dry ice is the commodity, or when it refrigerates other dangerous goods, UN 1845 belongs on the Shipper's Declaration with packing instruction 954 and the net quantity.

IATA DGR 4.4 special provision A151 and 49 CFR 173.217(c)(3) drop those per package limits only for a unit load device that is identified to the operator and can vent, when dry ice refrigerates other than hazardous materials. 49 CFR 173.217(c)(5) excepts not over 2.5 kg (5.5 pounds) per package used as a refrigerant, if the package still vents and carries the required dry ice marks.

A worked example from the current list. One fibreboard box, 50 kg of dry ice, packing instruction 954, passenger aircraft. Class 9, no packing group. Fifty kilograms sits inside the 200 kg passenger maximum. The box still has to vent, show the net mass, carry the miscellaneous Class 9 label for air, and be known to the operator.

The mistake people make

Desks treat dry ice as ice. They tape every seam so the cooler looks tight. Carbon dioxide gas then has nowhere to go. They skip the net mass mark, or copy yesterday's kilograms after some of the dry ice has already sublimated. They write a packing group on UN 1845. They use a packing instruction other than 954. They offer a highway carton with no Class 9 diamond on an air booking because 49 CFR 172.101 Column 6 is none.

They remember the air waybill exception and apply it to dry ice that is cooling other dangerous goods. UN 1845 still belongs on the Shipper's Declaration with those other lines. They treat 173.217(c)(5) as a blanket 2.5 kg free pass, then skip the marks that exception still requires. They never call the operator, so 173.217(c)(2) is not met. E0 means excepted quantity is not authorized.

The paper can be silent and the box still fail. IATA DGR 9.1.3 compares them. Disagreement parks the freight. What to do after a rejection sits at https://altor.consulting/rejected.html.

How to fix it

Ask whether there is dry ice in the package. If there is, the line is UN 1845, Class 9, no packing group, packing instruction 954. Confirm the net quantity is at or under 200 kg unless A151 and 173.217(c)(3) actually apply to a unit load device. Vent the packaging. Mark the proper shipping name, UN 1845, and the net mass in kilograms. For air, apply the miscellaneous Class 9 label.

If dry ice only refrigerates goods that are not dangerous goods, put UN 1845, the proper shipping name, the package count, and the net quantity on the air waybill per packing instruction 954 and 49 CFR 173.217(c)(4), and make the operator arrangements in 173.217(c)(2). If dry ice is the commodity, or if it refrigerates other dangerous goods, add UN 1845 to the Shipper's Declaration. Walk the packages against the paper in the same order IATA DGR 9.1.3 will. If you cannot stand behind the dry ice line under 49 CFR 172.204 and IATA DGR 8.1.6.12, fix the carton and the paper, then sign.

Do not offer a taped cooler as an undeclared refrigerant.

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