Altor guide · 2026-09-13

Marks and labels: current edition or it comes back

The Shipper's Declaration already matches the current list. The fibreboard already has a Class 9 diamond. The acceptance desk at the cargo terminal still stops the freight. The diamond on the box is the generic miscellaneous Class 9. The current list wants the lithium batteries Class 9 label. IATA DGR 9.1.3 walks the carton against this year's specification, not against last year's drawer. A label from the previous edition comes back as a discrepancy report.

What the regulation actually requires

49 CFR 173.22 keeps classification, description, packaging, marks, and labels on the offeror. 49 CFR Part 172 Subpart D is marking. Subpart E is labeling. ICAO TI Part 5, Chapter 2 is marking for air, Chapter 3 is labelling, and IATA DGR Section 7 implements those chapters. The operator still runs IATA DGR 9.1.3. 49 CFR 175.30 is the US air acceptance rule next to it.

Start with the list. IATA DGR Section 4.2, and ICAO TI Table 3-1 behind it, print a labels column for every entry. 49 CFR 172.101 Column 6 does the same for a US offering. The diamond on the carton has to be the one in that column, from the current edition.

49 CFR 172.400 requires the labels specified for the material. 49 CFR 172.407 is the specification: durable, weather resistant, a diamond at least 100 mm on each side, with an inner border. 49 CFR 172.406 is placement. Affix the label on a surface other than the bottom, on the same surface as the proper shipping name when the package is large enough. For aircraft, the entire label has to appear on one side. Primary and subsidiary labels sit next to each other, within 150 mm. 49 CFR 172.402(a) is subsidiary hazard labels from Column 6. 49 CFR 172.402(c) is the Cargo Aircraft Only label when the package is authorized on cargo aircraft only. 49 CFR 172.448 is that orange rectangle.

Marking sits next to the diamonds. 49 CFR 172.301 requires the proper shipping name and the identification number, preceded by UN, on a non-bulk package. Characters at least 12 mm high, or 6 mm on packages of 30 L or 30 kg or less. 49 CFR 172.304 wants those marks durable, in English, on a contrasting background, and unobscured. 49 CFR 172.312 requires orientation arrows on two opposite vertical sides of a non-bulk combination package with liquid inner packagings.

A worked example from the current list. UN 1090 Acetone, Class 3, packing group II. Labels: flammable liquid. Passenger packing instruction 353 at 5 L. Cargo packing instruction 364 at 60 L. The carton needs the Class 3 diamond, the proper shipping name Acetone, UN 1090 at the required height, and orientation arrows if 172.312 applies.

A second line. UN 2924 Flammable liquid, corrosive, n.o.s., Class 3 with a Class 8 subsidiary, packing group II. Labels: flammable liquid and corrosive. Passenger packing instruction 352 at 1 L. Cargo packing instruction 363 at 5 L. Both diamonds are required. Because the name is n.o.s., 49 CFR 172.301(b) also wants the technical name on the outer packaging in parentheses.

A third line, the one that parks lithium freight. UN 3480 Lithium ion batteries, Class 9. The labels column is not the generic miscellaneous Class 9. It is the lithium batteries Class 9 label. 49 CFR 172.447 is that specification: the lower half shows the battery group, one broken and emitting flame, with the class number 9. 49 CFR 172.446 is the generic Class 9, stripes and a 9, no battery. Passenger aircraft: forbidden. Cargo aircraft: packing instruction 965. 49 CFR 172.402(c) and 172.448 put Cargo Aircraft Only on that package. IATA DGR 7.1.5.5 is the battery mark when the packing instruction requires it. Do not invent a cargo maximum from a blank cell.

The mistake people make

Desks treat last year's sticker roll as current. The lithium carton gets a generic Class 9 because the shop has always used that diamond for Class 9. The dual hazard carton gets only the primary diamond. UN 3480 leaves the cargo terminal without Cargo Aircraft Only. The UN number on the box does not match the Shipper's Declaration. The identification number is 4 mm high on a 20 L outer packaging, below the 6 mm floor in 172.301. 49 CFR 172.401 is prohibited labeling, including a leftover diamond from a previous commodity. Highway limited quantity often drops the hazard label, then the same carton is booked on an aircraft, where the label comes back.

The paper can pass 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

Open the current edition before anyone peels a sticker. Read the labels column for this UN number, this packing group, and this aircraft type. Then look at the carton. If the diamond is not the one in that column, change the diamond. For UN 3480, that means 49 CFR 172.447, not 172.446. For UN 2924 packing group II, that means Class 3 and Class 8 next to each other.

Confirm size and durability under 172.407, placement under 172.406, the proper shipping name and identification number under 172.301 and 172.304, orientation arrows under 172.312 when liquid inner packagings apply, Cargo Aircraft Only when 172.402(c) applies, and the battery mark when IATA DGR 7.1.5.5 requires it.

Walk the packages against the paper in the same order IATA DGR 9.1.3 will. If you cannot stand behind the marks and labels under 49 CFR 172.204 and IATA DGR 8.1.6.12, fix the carton, then sign.

Do not offer last year's diamonds on this year's list.

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