Updated State Variations
International shippers of dangerous goods by air have one advantage over shippers by other modes. The International Civil Aviation Organization (ICAO) includes in its Technical Instructions for the Safe Transport of Dangerous Goods by Air a list of “state variations”. These indicate which countries have additional restrictions and requirements placed upon dangerous goods traveling to, from, or through those countries. Being aware of such variations can save shippers significant time and money – if your goods must travel through, say, Norway, your shipment might be stopped or even seized if Norwegian regulations don’t allow it.
Of course, as regulations and related information develop over time, these variations will change, sometimes faster than the actual Technical Instructions themselves. On May 19th, ICAO published an addendum to the state variations that were published in the 2017-2018 edition of the Technical Instructions. While there have not been a lot of changes, some of these are significant for shippers who must obtain permits or exemptions from state authorities, and one eases the requirements for shipping engines by aircraft in the United States.
The changed variations in the Addendum include the following:
Belgium – Variations BE1 specifies the regulation in which to find the Belgian definition of “explosive.” BE2 gives new contact numbers for the government department responsible for prior authorization for shipments of explosives, while BE4 gives new contact numbers for authorization of radioactive substances. Finally, variation BE5, regarding approvals for dangerous goods carriers, has been deleted
Germany – DE4 gives new contact information for applications for exemptions.
Italy – IT5 updates requirements for obtaining authorization for shipping explosives, weapons, and ammunition to, from, or through Italy.
Saudi Arabia – SA4 gives new contact details when applying for prior permission for shipping explosives and munitions of war through that country.
United States – UN3528 (Engine, internal combustion, flammable liquid powered or Engine, fuel cell, flammable liquid powered or Machinery, internal combustion, flammable liquid powered or Machinery, fuel cell, flammable liquid powered)
and UN3529 (Engine, internal combustion, flammable gas powered or Engine, fuel cell, flammable gas powered or Machinery, internal combustion, flammable gas powered or Machinery, fuel cell, flammable gas powered) are no longer considered subject to the loading restrictions in the variation US13(d). This will make load planning easier for airlines.
The full list of ICAO state variations (including the updates) can be found at:
If you have questions about the worldwide transport of dangerous goods by air, please contact our regulatory staff at ICC Compliance Center at 1.888.977.4834 (Canada) or 1.888.442.9628 (USA).