Non-Dangerous Goods Certificate

Overview

A Non-Dangerous Goods Certificate is a practical document used by a shipper, manufacturer, exporter or other responsible party to explain that the cargo is not classified as dangerous goods for transport purposes.

It may also be called a Non-DG Certificate, Non-Dangerous Goods Declaration, Non-Hazardous Certificate or similar name.

In forwarding practice, this certificate can be an important supporting document, but it should not be treated as the final answer by itself. The forwarder should check whether the certificate is consistent with the SDS, product specifications, ingredients, transport mode, packaging condition and the acceptance rules of the airline, shipping line, CFS, warehouse or consolidator.

What a Non-Dangerous Goods Certificate Means

A Non-Dangerous Goods Certificate is used to explain that the cargo is not subject to dangerous goods transport requirements.

It is often requested for goods where the product name alone is not enough to judge whether the cargo may be dangerous. Typical examples include chemicals, liquids, powders, aerosol-like products, products containing batteries, machinery parts, samples, cleaning agents, cosmetics, resin materials and similar cargo.

Airlines, shipping lines, CFS operators, warehouses, customs brokers and forwarders may ask for this certificate as additional evidence when the cargo description raises a dangerous goods concern.

Points Forwarders Should Check

When a Non-Dangerous Goods Certificate is received, the forwarder should check the following points:

• whether the issuer is a responsible party such as the shipper, manufacturer or exporter;
• whether the cargo name, model number, product number, ingredients and use are clearly stated;
• whether the certificate is consistent with the SDS and product specifications;
• whether the reason why the cargo is not dangerous goods is clearly explained;
• whether the certificate is intended for air transport, sea transport or both;
• whether the cargo contains lithium batteries, aerosols, flammable liquids, corrosive substances or other regulated materials;
• whether the cargo may be a marine pollutant and may require special marking or declaration for sea transport;
• whether the cargo is actually handled as Limited Quantity or Excepted Quantity rather than ordinary non-dangerous goods;
• whether the date, signature, company name and contact information are shown;
• whether the document matches the actual cargo, packaging and shipment lot.

A certificate that only states “non-dangerous” without identifying the cargo, basis of judgment or transport mode may not be sufficient for practical acceptance.

Relationship with SDS

When checking a Non-Dangerous Goods Certificate, consistency with the SDS is especially important.

If the transport information section of the SDS shows a UN number, dangerous goods class, packing group, marine pollutant information or transport restrictions, the forwarder should confirm whether the certificate contradicts the SDS.

If the SDS appears to indicate that the product is dangerous goods, but only a Non-Dangerous Goods Certificate is submitted, the forwarder should not accept the certificate without further explanation. The shipper, manufacturer or dangerous goods specialist should be asked to clarify the basis of the classification.

The version and issue date of the SDS should also be checked. An old SDS and a newly issued certificate may not refer to the same product formulation or shipment condition.

Do Not Rely Only on the Certificate

A Non-Dangerous Goods Certificate is an explanation from the shipper or manufacturer. It is not a substitute for checking the actual cargo condition.

Forwarders are not expected to make a full technical dangerous goods classification by themselves. However, if the product name, SDS, invoice description, packaging or cargo appearance looks inconsistent with the certificate, the shipment should be stopped for additional confirmation.

Particular caution is needed when the product name includes words such as “battery,” “spray,” “aerosol,” “chemical,” “liquid,” “paint,” “cleaner,” “adhesive,” “resin,” “sample” or “reagent.”

In such cases, SDS, ingredient information, product specifications, dangerous goods classification documents and carrier acceptance requirements should be checked together.

Air Transport

Dangerous goods confirmation is especially strict in air transport.

Even if a Non-Dangerous Goods Certificate is submitted, the airline or air consolidator may still request SDS, product specifications, battery information, packaging details or a dangerous goods classification document.

Special care is required for products containing lithium batteries, power banks, aerosol products, cosmetics, cleaning agents, reagents, liquid samples and chemical products.

If the cargo does not satisfy airline acceptance conditions, it may not be loaded even when the shipper provides a Non-Dangerous Goods Certificate.

Sea Transport

In sea transport, the forwarder should check whether the cargo is dangerous goods under the IMDG Code, whether it is a marine pollutant, and whether the shipping line, NVOCC, CFS or co-loader can accept the cargo.

If the SDS transport section contains dangerous goods information for sea transport, further confirmation is needed even if a Non-Dangerous Goods Certificate has been submitted.

Marine pollutant status requires particular attention. Even where the shipper believes the cargo is “non-dangerous,” products with environmental hazard information in the SDS may require marine pollutant marking, documentation or carrier confirmation for sea transport. Such cargo should not be treated as simple ordinary cargo without checking the IMDG Code and carrier acceptance rules.

For LCL and consolidated cargo, CFS operators and consolidators may require a clear explanation of why the cargo is not dangerous goods. If the documents are insufficient, the cargo may be refused at CFS, held for confirmation or delayed from shipment.

Limited Quantity and Excepted Quantity

Limited Quantity and Excepted Quantity are not the same as ordinary non-dangerous goods. They are special dangerous goods handling categories under transport rules, subject to their own conditions, packaging, marking and documentation requirements.

If a cargo is handled as Limited Quantity or Excepted Quantity, a simple Non-Dangerous Goods Certificate should not be used as a substitute for the correct classification and transport procedure. The forwarder should confirm the applicable rule, quantity limit, packaging condition, marking and carrier acceptance requirements.

Lithium Batteries

Cargo containing lithium batteries should not be judged only by a Non-Dangerous Goods Certificate.

Lithium battery handling depends on whether the battery is shipped alone, packed with equipment or contained in equipment. It also depends on battery type, capacity, number of batteries, UN38.3 status, packaging condition and transport mode.

Even if the shipper says that the battery is only built into the equipment, air or sea transport requirements may still apply. Forwarders should confirm whether lithium batteries are included, whether spare batteries are included, and whether the shipment is acceptable under the relevant transport rules and carrier conditions.

Aerosols, Liquids and Chemical Products

Aerosol products, liquid chemicals, cleaning agents, adhesives, paints, fragrances, cosmetics and reagents often require careful dangerous goods confirmation.

Even if a Non-Dangerous Goods Certificate is submitted, the product may still have flammable, corrosive, toxic, oxidizing or environmentally hazardous properties.

Forwarders should check the SDS, ingredients, flash point, container type, capacity, packaging and transport mode. Small samples should not be assumed to be safe merely because the quantity is small.

CFS and Warehouse Acceptance

CFS operators and warehouses may request additional confirmation even when a Non-Dangerous Goods Certificate has been submitted.

If the cargo appearance, product name, SDS or packaging suggests possible dangerous goods, the CFS or warehouse may place the cargo on hold, refuse acceptance or request additional documents.

For chemicals, liquids, sprays, products containing batteries, odor-generating goods or cargo with leakage risk, the forwarder should send documents to the CFS or warehouse before cargo delivery and confirm whether acceptance is possible.

Last-minute delivery without prior confirmation may lead to CFS rejection, storage delay, rebooking, missed cut-off or additional handling costs.

Common Problems in Practice

The most common problem is a certificate that looks complete in form but is weak in substance.

Examples include:

• the product name is vague;
• the model number or product number is missing;
• the certificate conflicts with the SDS;
• the transport mode is not stated;
• marine pollutant status is not checked for sea transport;
• Limited Quantity or Excepted Quantity is confused with ordinary non-dangerous goods;
• the certificate is old and may not match the current product;
• the issuer is unclear;
• the certificate contains only a general statement without classification basis;
• the actual packaging differs from the document description;
• the product contains a battery, aerosol, liquid or chemical component not mentioned in the certificate.

In these cases, the forwarder should request additional documents or confirmation before proceeding with booking, CFS delivery or airline acceptance.

Practical Points for Forwarders

Forwarders should treat a Non-Dangerous Goods Certificate as one part of the dangerous goods checking process.

The following points are especially important:

• compare the certificate with the SDS;
• check whether the certificate applies to the actual shipment lot;
• confirm whether the certificate is for air, sea or both modes;
• check whether the product contains batteries, aerosols, liquids or chemicals;
• confirm whether the cargo may be a marine pollutant and whether marine pollutant marking or declaration is required;
• confirm whether the cargo is actually Limited Quantity or Excepted Quantity rather than ordinary non-dangerous goods;
• confirm CFS, warehouse, airline or shipping line acceptance before cargo movement;
• request manufacturer confirmation if the shipper’s explanation is unclear;
• avoid treating the certificate as a “paper shield” against misdeclaration.

The practical question is not whether a certificate exists. The question is whether the certificate matches the actual cargo and transport conditions.

Practical Notes for Shipments to Japan

For shipments to Japan, overseas shippers and origin-side forwarders should prepare dangerous goods-related documents before cargo delivery to the airline, CFS or warehouse.

If the Japanese-side forwarder or customs broker asks for SDS, product specifications, battery information, ingredient information or dangerous goods classification documents, the overseas side should respond with technical information rather than only a general commercial description.

Where the cargo is a chemical product, sample, battery-related product, aerosol, liquid, cleaning agent, cosmetic or machinery part containing a regulated component, the safest approach is to confirm transport classification early.

Waiting until the cargo reaches CFS or airport acceptance may cause refusal, delay, additional storage cost, rebooking or missed vessel or flight.

Key Takeaway

A Non-Dangerous Goods Certificate is a useful document, but it is not the final answer by itself.

Forwarders should check the certificate together with SDS, product specifications, invoice description, packaging condition, transport mode and carrier or CFS acceptance requirements.

Marine pollutant status, Limited Quantity and Excepted Quantity should also be checked separately. These issues may require specific marking, documentation or handling even when the shipper describes the cargo as “non-dangerous.”

The purpose of the certificate is not to avoid checking. It is to support a proper dangerous goods confirmation process and prevent misdeclaration, cargo rejection, loading refusal and shipment delay.