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By Dave Brennan
From 1 January 2027, the 68th Edition of the IATA Dangerous Goods Regulations (DGR) will become the industry reference for the transport of dangerous goods by air.
The new edition incorporates amendments adopted into the 2027 to 2028 ICAO Technical Instructions, including changes arising from the 24th Revised Edition of the United Nations Model Regulations, together with air transport specific provisions agreed by the ICAO Dangerous Goods Panel.
This article examines the changes affecting Section 5 (Packing), Section 6 (Packaging Specifications and Performance Tests), and Section 7 (Marking and Labelling). Future articles in this series will explore the remaining sections of the DGR and explain what the changes mean for different participants across the air cargo supply chain.
Section 5: Packing
Section 5 sets out the requirements for packing dangerous goods, including the applicable packing instructions for all classes except Class 7 radioactive material.
While the broad packing principles remain aligned with the United Nations Model Regulations to support consistency across all modes of transport, many of the detailed packing instructions are unique to air transport.
The 2027 edition introduces several important amendments.
5.0 General
5.0.6 Format of Packing Instructions
Paragraph 5.0.6.4 has been amended to align with changes adopted by the United Nations Subcommittee.
The revised wording updates the provisions specifying packagings that must not be used where substances transported are liable to become liquid during transport.
Although primarily an alignment change, packaging manufacturers, shippers and dangerous goods specialists should ensure existing procedures reflect the revised wording.
5.1 Packing Instructions for Class 1 Explosives
Packing Instruction 130
A new provision permits small arms ammunition and cartridges for tools assigned to UN 0012 and UN 0014 to be packed in metal outer packagings without requiring internal cushioning, fittings, coatings or liners.
This provides greater flexibility for these specific articles while maintaining the required level of transport safety.
5.2 Packing Instructions for Class 2 Gases
Packing Instruction 222
Packing Instruction 222 applies to articles containing non flammable, non toxic gas.
Previously, the instruction permitted the inclusion of lithium cells or batteries complying with Section II of PI 967 or PI 970.
The 2027 edition now extends this allowance to include sodium ion cells and batteries that comply with Section II of PI 978.
The same amendment has also been made to Packing Instruction 975, covering articles containing environmentally hazardous substances.
This reflects the growing use of sodium ion battery technology throughout the transport industry.
5.4 Packing Instructions for Class 4
Packing Instruction 459
Following amendments adopted by the United Nations Subcommittee, additional packing requirements for self reactive substances and polymerising substances now include two important provisions.
- Cushioning materials must not be readily combustible.
- Metal packagings meeting the internal hydraulic pressure test criteria for Packing Group I must not be used where unnecessary confinement of liquids could occur.
Shippers should consult packaging manufacturers to confirm whether metal packagings satisfy the Packing Group I hydraulic pressure requirements before use.
5.5 Packing Instructions for Class 5
Packing Instruction 570
Additional packing requirements for organic peroxides have also been updated.
To avoid unnecessary confinement of liquids, metal packagings meeting the internal hydraulic pressure test criteria for Packing Group I must not be used.
As with Packing Instruction 459, consultation with the packaging manufacturer is recommended where uncertainty exists regarding packaging performance.
5.9 Packing Instructions for Class 9 Miscellaneous Dangerous Goods
Packing Instruction 955
Several changes have been introduced.
The examples of articles regarded as life saving appliances have been expanded to include:
- Personal flotation devices
- Self inflating protective equipment
In addition, the provisions covering Division 2.2 gases now recognise cylinders fitted with Class 9 safety devices (UN 3268).
Packing Instruction 962
Packing Instruction 962 has been revised to clarify that apparatus, articles or machinery containing dangerous goods may also contain:
- Lithium batteries complying with Section II of PI 967 or PI 970, or
- Sodium ion batteries complying with Section II of PI 978,
provided the applicable requirements are met.
Packing Instruction 964
One of the more practical amendments is the introduction of a transitional provision for environmentally hazardous substances assigned to UN 3082.
Until 31 December 2034, liquid environmentally hazardous substances may be packed in non UN specification open head plastic drums exceeding 5 litres but not more than 20 litres, provided those drums successfully pass the stacking test specified in paragraph 6.3.6.
This change was adopted by the United Nations Subcommittee to support the continued transport of products such as printing inks, paints and related materials while industry develops more sustainable packaging solutions.
Packing Instructions 967, 970 and 978
A new explanatory note has been added to clarify the battery mark exception.
Where equipment contains one or more button cells in addition to larger cells or batteries, the button cells are not counted when determining package or consignment limits for applying the battery mark.
Although relatively minor, this clarification should remove uncertainty when applying the battery marking provisions to many common electronic devices.
Operational Considerations
While many of these amendments appear incremental, they collectively affect a wide range of dangerous goods operations.
Shippers should review packing procedures and packaging specifications to ensure they reflect the revised requirements.
Freight forwarders and dangerous goods acceptance staff should familiarise themselves with the revised packing instructions, particularly those affecting battery powered equipment, environmentally hazardous substances and explosives.
Packaging manufacturers should also assess whether existing packaging designs continue to satisfy the revised performance requirements introduced in the 68th Edition.
Section 6: Packaging Specifications and Performance Tests
Section 6 sets out the specifications, performance standards and testing requirements for UN specification packagings, cylinders, aerosols, packagings for refrigerated liquefied gases and limited quantity packagings.
Unlike Section 5, which focuses on how dangerous goods are packed, Section 6 focuses on the packaging itself, ensuring it has been designed, tested and manufactured to perform safely under transport conditions.
The changes adopted for 2027 are largely aligned with amendments made in Part 6 of the 24th Revised Edition of the United Nations Model Regulations.
Initial Inspection and Testing of Closed Cryogenic Receptacles
An editorial amendment has been made to paragraph 6.4.1.5.2, updating the wording relating to the initial inspection and testing of closed cryogenic receptacles.
The paragraph now refers to a “recognised technical code”, aligning the wording with the latest United Nations Model Regulations.
While this is principally a terminology update, organisations involved in the manufacture, inspection or certification of cryogenic receptacles should ensure their documentation and procedures reference the current terminology.
Updated ISO Standards
Section 6 also includes revisions to the ISO standards referenced for:
- UN cylinders
- Closed cryogenic receptacles
These updates ensure the IATA Dangerous Goods Regulations remain aligned with current internationally recognised manufacturing and testing standards.
For packaging manufacturers, inspection bodies and certification organisations, it is important that internal documentation references the current editions of the applicable ISO standards.
Although these amendments are not expected to significantly change day to day freight operations, they reinforce the importance of maintaining current technical documentation throughout the packaging approval process.
Why Section 6 Matters
Many dangerous goods incidents are prevented long before a shipment reaches an aircraft.
The performance testing requirements contained within Section 6 provide assurance that approved packagings will perform as intended during normal transport conditions.
While the 2027 amendments are relatively modest, organisations responsible for manufacturing, certifying or maintaining UN specification packagings should review the updated references to ensure ongoing compliance.
Section 7: Marking and Labelling
Section 7 establishes the requirements for marks and hazard labels applied to packages and overpacks containing dangerous goods.
The 2027 amendments continue the alignment with Part 5 of the 24th Revised Edition of the United Nations Model Regulations, while also providing additional clarification for battery marking requirements.
7.1.5.5 Lithium and Sodium Ion Batteries
Paragraph 7.1.5.5.2(a) has been amended by adding a new sentence addressing equipment that contains both button cells and larger batteries.
The new provision states:
Where equipment contains one or more button cells in addition to cells or batteries, there is no requirement for the UN number identifying the button cell or cells to be included on the battery mark.
This formalises what has often been accepted in practice.
For example, where equipment such as a laptop computer contains both a lithium ion battery and a lithium metal button cell, there is no requirement for the battery mark to display both UN 3481 and UN 3091.
The clarification simplifies battery marking requirements while maintaining the necessary safety information.
New Paragraph 7.1.5.5.4
A completely new paragraph has been introduced covering the placement of the battery mark.
Where both:
- a battery mark, and
- hazard labels required under 7.2.2.3
must be applied to the same package, the battery mark is now required to appear on the same surface as the hazard labels, provided the package dimensions are adequate.
This amendment particularly affects packages assigned to:
- UN 3363 Dangerous Goods in Apparatus, Articles or Machinery
- UN 3538 Articles Containing Non Flammable, Non Toxic Gas
- UN 3548 Articles Containing Miscellaneous Dangerous Goods
where those articles also contain lithium cells, lithium batteries or sodium ion batteries.
The revised placement requirement should improve package identification during acceptance, handling and transport by ensuring critical markings are located together.
One Issue Still Requiring Clarification
One aspect of the new provision remains uncertain.
The amendments do not clearly identify which UN number should appear on the battery mark for:
- UN 3363
- UN 3538
- UN 3548
where those articles contain batteries.
It is anticipated that this issue may be clarified through future guidance from either the United Nations Subcommittee or the ICAO Dangerous Goods Panel.
Until then, organisations should monitor future guidance and any published corrigenda.
Practical Considerations
Although many of the amendments contained within Sections 6 and 7 are technical in nature, they affect several parts of the dangerous goods supply chain.
Packaging manufacturers should review referenced technical standards to ensure continued compliance.
Shippers should verify that battery marks and hazard labels are applied in accordance with the revised placement requirements.
Freight forwarders and operators should ensure acceptance staff understand the updated battery marking provisions, particularly for apparatus, machinery and articles containing batteries.
Updating procedures before the 68th Edition takes effect will help avoid unnecessary shipment delays and acceptance issues once the new regulations become effective.
Compliance Readiness: Preparing for the 68th Edition
As with any major regulatory update, the biggest challenge is often not understanding the changes themselves. It is ensuring those changes are implemented consistently across the entire supply chain.
Dangerous goods consignments typically pass through multiple organisations before reaching an aircraft. Manufacturers, shippers, freight forwarders, ground handlers and operators all play a role. If each party updates its procedures at a different pace, the result can be shipment delays, rejected consignments, unnecessary rework and, ultimately, compliance risk.
Preparation should begin well before the 1 January 2027 implementation date.
Key Preparation Actions
- Review packing procedures
Organisations should compare existing packing procedures and work instructions against the revised packing instructions contained within Section 5.
Particular attention should be given to changes affecting batteries, environmentally hazardous substances, explosives and articles containing dangerous goods.
- Verify packaging specifications
Businesses responsible for manufacturing, purchasing or approving UN specification packagings should confirm that packaging approvals, technical documentation and referenced standards reflect the latest requirements introduced into Section 6.
Where packaging manufacturers are involved, early engagement may avoid unnecessary delays once the new edition takes effect.
- Update marking and labelling procedures
The revised battery marking provisions should be incorporated into acceptance procedures, work instructions and training materials.
Electronic systems used to generate package markings should also be reviewed to ensure they produce the correct battery marks and label placement.
- Refresh training material
Training programmes should be updated before the changeover to ensure staff understand the revised packing instructions, packaging specifications and marking requirements.
Acceptance staff, dangerous goods specialists, quality personnel and operational teams should all receive training appropriate to their responsibilities.
- Test operational processes
Before the 68th Edition becomes effective, organisations should conduct practical validation exercises using representative consignments.
Battery powered equipment, dangerous goods in apparatus or machinery, environmentally hazardous substances and Class 1 explosives provide useful scenarios for testing updated procedures, documentation and acceptance processes.
Use the Published Regulations
Industry summaries such as this article provide a useful overview of what has changed and where attention should be focused.
However, the authoritative compliance position will always be the published 68th Edition of the IATA Dangerous Goods Regulations, together with any subsequent addenda or corrigenda issued by IATA.
Businesses should ensure implementation decisions are based on the published regulatory text rather than secondary summaries.
Final Reflection
The amendments introduced across Sections 5, 6 and 7 demonstrate that dangerous goods compliance extends well beyond packaging dangerous goods correctly.
Packaging design, packaging performance, marking and labelling all form part of an integrated compliance system. Small regulatory changes in any one of these areas can influence operational procedures, staff training, acceptance processes and shipment readiness throughout the supply chain.
Organisations that begin preparing early will be best positioned for a smooth transition when the 68th Edition of the IATA Dangerous Goods Regulations becomes effective on 1 January 2027.
As with every regulatory change, successful implementation will depend on more than understanding the amendments. It will require organisations to review procedures, update training, validate systems and ensure every participant in the transport chain is working to the same standard.