Altor guide · 2026-08-27

Passenger vs cargo aircraft: the quantity check desks skip

The drums are the same size as last week. The UN number is the same. The net quantity on the paper is the same. Last week the freight left. This week it sits at the cargo terminal with a discrepancy report. The booking is a passenger aircraft. The quantity is a cargo aircraft number.

That is the check desks skip. They treat the cargo terminal as if it were a cargo aircraft.

What the regulation actually requires

Passenger aircraft and cargo aircraft are two different quantity systems.

ICAO TI Table 3-1, implemented in the IATA DGR List of Dangerous Goods in Section 4.2, gives each entry a passenger packing instruction and a passenger maximum net quantity per package, and a cargo packing instruction and a cargo maximum net quantity per package. The two columns can disagree on the packing instruction, the number, or both. Some passenger cells are simply forbidden.

A worked example from the current table. UN 1090 Acetone, Class 3, Packing Group II. Passenger aircraft: packing instruction 353, 5 L per package. Cargo aircraft: packing instruction 364, 60 L per package. A 10 L package of acetone sits inside the cargo maximum and over the passenger maximum. Same UN. Same packing group. Different column.

The pattern is not unique to acetone. UN 2794, batteries, wet, filled with acid, keeps packing instruction 870 on both sides and still splits the quantity: 30 kg on passenger aircraft, 400 kg on cargo aircraft. UN 3480 lithium ion batteries shipped alone have no passenger quantity at all. Passenger aircraft: forbidden. Cargo aircraft: packing instruction 965.

For a US originating air shipment, 49 CFR 172.101 carries the same split in its air quantity columns. 49 CFR 173.27 is the aircraft packaging and quantity rule. Meeting the IATA column does not excuse a miss against 49 CFR 173.27, and the reverse is also true. The operator will read both.

The Shipper's Declaration has to show which system you used. IATA DGR 8.1.6 is the completion standard. Nature and quantity, including packing instruction, package count, and net quantity, go on the form per IATA DGR 8.1.6.9 and 8.1.6.9.2. The form also records passenger and cargo aircraft, or cargo aircraft only. 49 CFR 172.204(c)(3) is the air certification: the offeror is declaring that the articles are permitted on aircraft and packed to the air rules, including 49 CFR 173.27. The operator then runs the acceptance check under IATA DGR 9.1.3 and, for US air operators, 49 CFR 175.30.

When the consignment is cargo aircraft only, the packages need the cargo aircraft only mark. 49 CFR 172.448 is the US label. IATA DGR Section 7 is marks and labels. A cargo aircraft only mark on a passenger booking is a mismatch. A missing mark on a cargo only entry is a mismatch. Neither mark changes the quantity column.

The mistake people make

Desks fill the quantity first and the aircraft type last.

The freight is sitting at a cargo terminal, so cargo limits feel obvious. Combination carriers still put dangerous goods in the belly of passenger aircraft. The terminal is a building. The aircraft type is on the booking.

The SKU went last week on a freighter at 10 L, so this week's passenger booking gets 10 L. Section 14 of the safety data sheet lists a transport quantity and says nothing about which column that number came from. The default tick on the form is Passenger and Cargo Aircraft, which people read as permission to use the larger number. It is not. If the flight is a passenger aircraft, the passenger column is the only column that counts.

The other skip is treating the table number as a consignment total. The 5 L acetone limit is per package. Two packages of 5 L can be legal on passenger aircraft. One package of 10 L is not. Copying a consignment total into the net quantity field fails IATA DGR 9.1.3 even when the UN number is right.

Forbidden on passenger gets the same treatment as a quantity. UN 3480 rides along on the passenger flight the rest of the freight occupies, because the lithium line usually goes. The passenger column for that entry is empty. There is no quantity that makes it legal.

How to fix it

Lock the aircraft type from the booking before anyone writes a packing instruction or a net quantity.

Open the current IATA DGR Section 4.2 list for this UN number and this packing group. If the flight is passenger, read the passenger packing instruction and the passenger maximum per package. If the flight is cargo aircraft only, read the cargo column. Then read 49 CFR 173.27 for a US originating air offering. Write the packing instruction that belongs to the column you are actually using. Acetone on passenger aircraft is packing instruction 353, not 364. Enter package count and net quantity per IATA DGR 8.1.6.9.2, per package, not as a consignment lump.

If the passenger column is forbidden, do not book a passenger aircraft. Rebook cargo, or change what is in the box. A cargo aircraft only mark does not convert a passenger booking into a legal one.

Walk the packages against the paper in the same order IATA DGR 9.1.3 will. Confirm the aircraft type on the declaration matches the booking. Confirm the cargo aircraft only mark is present only when the entry or the quantity requires cargo aircraft. The table is a ceiling, and the booking is the column.

If you cannot stand behind the aircraft type line under 49 CFR 172.204 and IATA DGR 8.1.6.12, fix the line. Then sign.

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