Altor guide · 2026-09-01

State and operator variations: the layer above the DGR

The UN number matches IATA DGR Section 4.2. The packing instruction is right. The net quantity sits inside the column. Then the acceptance desk at the cargo terminal parks the freight anyway. The destination State has a variation. Or the operator you booked published one. Neither of those lives in the list you just closed.

That is the layer above the DGR. The list can be clean and the consignment still fail.

What the regulation actually requires

ICAO TI Table 3-1, implemented in the IATA DGR List of Dangerous Goods in Section 4.2, has a state variations column. The codes in that column are pointers, not the rule. The text of those State restrictions, and the operator restrictions that never appear in the table at all, sit in IATA DGR 2.8.

State variations are additional or different conditions notified by a country. They can attach to origin, destination, or a known transit State, depending on the variation. Operator variations are additional restrictions notified by an airline. They attach to the operator you booked. A packing instruction that names a few codes is not a complete list. Open IATA DGR 2.8 for the route and the operator every time.

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. The extract lists no state variation against that entry. A clean acetone line still has to be read against the operator variations in IATA DGR 2.8 for the carrier on the booking. An empty cell in the table is not a waiver of 2.8.

Lithium is where the column is not empty. UN 3480 lithium ion batteries shipped alone, passenger aircraft forbidden, cargo packing instruction 965, lists US 3. Both UN 3481 entries list US 3 as well. Packed with equipment is packing instruction 966, 5 kg passenger and 35 kg cargo. Contained in equipment is packing instruction 967 at the same limits. UN 3090 lithium metal batteries shipped alone, and both UN 3091 entries, list US 2 and US 3. Passenger aircraft remains forbidden for UN 3090. Those codes tell you to open the United States variations in IATA DGR 2.8 for this route.

UN 3077, Environmentally hazardous substance, solid, n.o.s., Class 9, packing group III, packing instruction 956 at 400 kg, lists DE 5 and US 4. UN 3082, the liquid counterpart, packing instruction 964 at 450 L, lists the same pair. A Germany origin, destination, or transit can put DE 5 in play even when the US paper already looks finished.

For a US originating air shipment, using the ICAO Technical Instructions is an authorization, not an exit from 49 CFR. 49 CFR 171.22(a) is that authorization. 49 CFR 171.22(b) still requires conformance with the international standard and with Subpart C. 49 CFR 171.24(b)(3) requires the conditions of a United States variation when the ICAO Technical Instructions specify one. 49 CFR 171.22(g) still keeps emergency response information, training, security, and incident reporting on the US offering. 49 CFR 173.22 still puts classification on the offeror. 49 CFR 172.204 and IATA DGR 8.1.6.12 still make the signature a certification. The operator then runs IATA DGR 9.1.3, and for US air operators 49 CFR 175.30.

The mistake people make

Desks treat a matching Section 4.2 line as a finished declaration.

They lock UN, packing group, packing instruction, and quantity, then stop. The state variations column is unread. Operator variations are treated as a carrier preference, something the cargo terminal will sort out. Last week's operator is not this week's operator.

The other skip is reading only the origin State. A variation can attach to the destination or to a transit State. UN 3077 listing DE 5 does not matter on a domestic acetone run. It matters when the route actually involves Germany. Copying a US domestic lithium template onto an export booking without opening 2.8 is the same skip in the other direction.

The acceptance desk is not improvising. IATA DGR 9.1.3 includes the variations that apply to that operator and that route. A missed variation is a paperwork failure that parks freight. What to do after a rejection sits at https://altor.consulting/rejected.html.

How to fix it

Lock the route and the operator before anyone treats the list line as done.

Write origin, destination, known transit States, and the operator code from the booking. Open the current IATA DGR Section 4.2 line for this UN and packing group. Note the state variation codes. Then open IATA DGR 2.8. Read the State variations for those codes, and the State variations that apply to every State on the route even when the table cell was empty. Then read the operator variations for the operator you actually booked.

Apply the stricter condition. If a variation forbids the commodity, changes a quantity, requires extra documentation, or wants extra handling information on the declaration, write that on the paper. IATA DGR 8.1.6 is the completion standard. Nature and quantity still go on per IATA DGR 8.1.6.9.

For a US originating air offering, confirm 49 CFR 171.24(b)(3) against the current United States variations. UN 1090 still uses packing instruction 353 at 5 L on passenger aircraft. UN 3481 packed with equipment still uses packing instruction 966, not 967. US 3 on those lithium lines is still a 2.8 read, not a slogan on the template.

Walk the packages against the paper in the same order IATA DGR 9.1.3 will. If you cannot stand behind the route and the operator under 49 CFR 172.204 and IATA DGR 8.1.6.12, fix the line. Then sign.

Altor pre-checks completed Dangerous Goods Declarations line by line against the current regulations and returns a written report, with every finding cited, within one business day. You keep the pen. altor.consulting

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