Altor guide · 2026-08-24

Why DG shipments get rejected: the paperwork failure modes

The drums are closed. The labels look current. The booking is confirmed. Then the acceptance desk at the cargo terminal stops the freight, and the discrepancy report cites the declaration, not the packaging.

That is the usual failure. Dangerous goods shipments get parked because the paper cannot survive the first pass of an operator acceptance checklist. The cargo sits. The slot is lost. The customer conversation starts. None of that required a new drum. It required a declaration that matched the current rules.

What the regulation actually requires

A US originating air shipment sits under two rulebooks at once. 49 CFR Part 172, Subpart C, states what a hazardous materials shipping paper must contain. The IATA Dangerous Goods Regulations, Section 8, state how the Shipper's Declaration for Dangerous Goods must be completed before an operator will take the consignment.

49 CFR 172.202 sets the basic description and the order it appears: identification number, proper shipping name, hazard class or division, and packing group when one is assigned. Quantity and packaging type belong on that same paper. 49 CFR 172.203(k) requires the technical name, shown in parentheses, when the proper shipping name is an n.o.s. entry or another generic description flagged by the letter G in the Hazardous Materials Table at 49 CFR 172.101.

The signature is a certification, not a courtesy. 49 CFR 172.204 is the shipper's certification. The signer is stating that the goods are correctly classified, described, packaged, marked, and labeled, and that they are in proper condition for transport. 49 CFR 173.22 places that duty on the person who offers the shipment. The forwarder can prepare a draft. The carrier can refuse a bad one. Neither of them becomes the shipper of record.

On the air side, IATA DGR 8.1 requires the Shipper's Declaration. IATA DGR 8.1.6 is the completion standard. Nature and quantity are entered in the sequences in IATA DGR 8.1.6.9, including package count and net quantity at 8.1.6.9.2. The certification block is IATA DGR 8.1.6.12. The operator then runs a formal acceptance check under IATA DGR 9.1.2 and 9.1.3. For US air operators, 49 CFR 175.30 is the inspection and acceptance duty that sits next to that checklist.

Those IATA provisions implement the ICAO Technical Instructions. Documentation is ICAO TI Part 5, Chapter 4. Acceptance is ICAO TI Part 7, Chapter 1. Quantity limits and packing instructions split passenger aircraft from cargo aircraft in ICAO TI Table 3-1 and in the IATA DGR List of Dangerous Goods in Section 4.2. 49 CFR 173.27 is the aircraft specific packaging and quantity rule for US offerings. A quantity that is legal on a freighter can be forbidden on the passenger flight the booking actually occupies.

The mistake people make

Desks copy Section 14 of the safety data sheet onto the declaration and treat the job as finished.

Section 14 is transport information. It is not a shipping paper. GHS wording on an SDS can disagree with the transport classification, the packing group, or the current proper shipping name. 49 CFR 173.22 still lands on the shipper. If the SDS shows Packing Group III and the current table requires Packing Group II, the declaration that copied the SDS fails at acceptance.

The other failures we see are paper failures. The UN number and the proper shipping name do not match the current list, and acceptance staff stop at the first line of IATA DGR 9.1.3. An n.o.s. entry is missing the technical name required by 49 CFR 172.203(k) and IATA DGR 8.1.6.9. The packing instruction does not match the quantity, the packing group, and the aircraft type. The shipment is booked on a passenger aircraft and declared as cargo aircraft only. The marks on the box do not match the paper. Someone other than the shipper of record treats the signature as a formality, even though 49 CFR 172.204 and IATA DGR 8.1.6.12 still name the shipper.

Old templates sit under all of those. Marks, packing instructions, and lithium battery notes have moved across recent editions. A form that was correct two editions ago will still print. The operator is working from the current edition.

How to fix it

Treat the declaration as a current edition document, not a saved form.

Before anyone signs, confirm UN number, proper shipping name, class, and packing group against the current IATA DGR List of Dangerous Goods, and against 49 CFR 172.101 when the US description governs. Confirm them for this consignment, not for last year's similar product. If the name is n.o.s. or otherwise generic, add the technical name in parentheses on the paper, then make the package marks agree.

Choose passenger or cargo aircraft before you choose a packing instruction and a quantity. Write that choice on the declaration. Confirm the quantity sits inside the limit for that column in IATA DGR Section 4.2, and that 49 CFR 173.27 is satisfied for a US air offering. Enter package count and net quantity per IATA DGR 8.1.6.9.2.

Run the same checks the operator will run. IATA publishes the non-radioactive acceptance checklist that implements 9.1.3. Use it before tender. Walk the paper against the packages in the same order the checklist does. Keep the SDS, the declaration, and the package marks in one pile and compare them. Disagreement is a finding, not a wording preference. If you cannot stand behind a line under 49 CFR 172.204 and IATA DGR 8.1.6.12, fix the line.

A forwarder can be excellent and you should still know your own declarations are right. That is not distrust. That is how 49 CFR 173.22 reads.

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.

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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