State Approvals & NOTAM Requirements
IATA DGR 67th Ed. Section 2.8 — State Variations, Operator Variations, competent authority notification requirements, and NOTAM (Notice to Airmen) procedures for dangerous goods air transport.
Critical: Before every DG shipment, both State Variations and Operator Variations must be checked. A substance permitted by the State may still be refused by the operator. Pre-application lead times can range from 7 to 30 business days.
State Variations (DGR 2.8.3)
Each ICAO Contracting State may impose additional restrictions or requirements beyond the baseline IATA DGR rules. The following are key examples — always consult the current DGR Appendix A for the full list.
Under IATA DGR 2.8.3, each ICAO Contracting State may impose additional requirements or restrictions beyond the baseline DGR rules. These 'State Variations' apply to all shipments originating from, transiting through, or destined for that State's airspace.
- ▸Shippers must check all applicable State Variations before tendering a shipment
- ▸If multiple States are involved (origin, transit, destination), ALL their variations apply
- ▸Operator may apply the most restrictive variation in case of conflict
- ▸State Variations are updated annually in the DGR Appendix A
The US applies 49 CFR (HMR) rules in addition to IATA DGR. USG variations are among the most extensive, with over 30 specific entries.
- ▸49 CFR training and certification required for US-originating shipments
- ▸Class 1 explosives: ATF permit required in addition to DGR compliance
- ▸Lithium batteries: DOT Special Permits may override standard PI limits
- ▸Radioactive: NRC license and DOT-7A Type A package certification
Australia applies CASA (Civil Aviation Safety Authority) rules. Specific restrictions on flammable liquids and toxic substances.
- ▸CASA DG approval required for operators carrying DG from Australian airports
- ▸Class 7 (radioactive): ARPANSA notification mandatory
- ▸Certain Class 6.1 PG I substances require CASA special exemption
- ▸Additional documentation for transiting through Australian airspace
China applies CAAC (Civil Aviation Administration of China) rules. Lithium battery restrictions are particularly strict.
- ▸CAAC pre-approval required for Class 1 and Class 7 shipments
- ▸Lithium batteries: State of Charge (SoC) must not exceed 30% for Section II
- ▸Special labelling in Chinese may be required for domestic segments
- ▸DG acceptance only at designated CAAC-approved airports
EU member states may apply EASA (European Union Aviation Safety Agency) regulations. Individual member states may have additional national variations.
- ▸EASA Part-SPA.DG operator approval mandatory
- ▸ADR-trained shippers recognized for ground transport segments
- ▸Class 7: national nuclear authority notification (e.g. BfS Germany, ASN France)
- ▸Harmonized with ICAO TI but with EASA-specific oversight requirements
Operator Variations (DGR 2.8.4)
Each airline operator may further restrict or add requirements for DG acceptance. The entries below are illustrative — always verify with the operator's current DG manual.
- ▸Class 1 PAX completely forbidden
- ▸UN 3090/3091 lithium battery pre-booking mandatory (min 7 days)
- ▸Shipments over 35 kg lithium battery require DGM certification
- ▸Approved airports only (IST, ESB, ADB hubs)
- ▸Special documentation: white copy + 2 copies
- ▸One of the most extensive operator variation lists (200+ UN entries)
- ▸All classes accepted with special reservation required
- ▸Cryogenic (cooled) special handling capacity available
- ▸Dedicated pharma cold chain service
- ▸Direct route IST-FRA (Frankfurt) frequently used
- ▸Extensive DG acceptance program across most classes
- ▸Lithium battery: pre-approval via SkyCargo portal required
- ▸Class 7: 72 h advance booking with radiation safety officer clearance
- ▸DG accepted at DXB, DWC hubs; limited acceptance at outstations
- ▸Oversize and heavy DG: cargo aircraft only (B777F fleet)
- ▸Class 6.2 infectious substance special acceptance program
- ▸ETA (Estimated Time of Arrival) notification mandatory
- ▸Transit via London Heathrow LHR
- ▸Lithium battery restrictions (some EU rules apply)
- ▸Class 1 forbidden
- ▸Comprehensive DG acceptance including Class 7
- ▸CAAS (Singapore) approval for transit shipments
- ▸Lithium battery: Section II accepted with advance booking
- ▸Cool chain and pharmaceutical DG program available
- ▸Class 1 limited to Division 1.4S with pre-approval
- ▸DG accepted at HKG hub; limited outstations
- ▸Class 7: minimum 5 working days advance booking
- ▸Lithium battery: strict compliance with HKCAD requirements
- ▸Flammable liquids PG I: CAO only
- ▸HKIA DG storage facility available for transit
Competent Authority Approval Process
Identify Applicable Authorities
Determine which competent authorities are relevant: origin State, transit State(s), and destination State. Check DGR Appendix A for State Variation codes.
Submit Application
Contact the competent authority (e.g. FAA/PHMSA for US, EASA for EU, SHGM for Turkey, CASA for Australia) with the required documentation: substance details, UN number, packaging specification, route plan.
Obtain Operator Acceptance
Separately confirm with the airline operator that they accept the specific DG shipment. Check operator variations in DGR 2.8.4 or contact the airline's DG desk directly.
Receive Written Approval
Obtain written approval/exemption document with validity period. Include approval reference number on the DGD (Shipper's Declaration) in the 'Additional Handling Information' field.
NOTAM and AIP Check
Before final booking, verify current NOTAMs and AIP supplements for any temporary restrictions affecting the route, airports, or specific DG classes.
Key Competent Authorities
- • FAA / PHMSA — United States (49 CFR)
- • EASA — European Union (Part-SPA.DG)
- • CAAC — China
- • CASA — Australia
- • DGCA / SHGM — Turkey
- • CAAS — Singapore
- • HKCAD — Hong Kong
- • Transport Canada — Canada (TDGR)
Common Approval Scenarios
- • Class 1 (Explosives): Nearly all States require prior written approval
- • Class 7 (Radioactive): National nuclear authority + CAA dual approval
- • Lithium batteries >35 kg: Some States require DGM certification
- • Narcotics/psychotropics: Health + trade + aviation triple approval
- • New/unclassified substances: Competent authority classification required
NOTAM (Notice to Airmen)
NOTAMs are aviation operational notices that may temporarily restrict or modify DG acceptance at specific airports, routes, or by specific operators.
- • Temporary bans: Volcanic eruptions, conflicts, or pandemics may trigger class-specific prohibitions
- • Airport closures: Infrastructure issues may require DG route changes
- • Operator restrictions: Fleet changes or capacity reductions may temporarily limit DG acceptance
- • Pre-shipment check: Always verify current NOTAMs via ICAO NOTAM database before finalizing booking
- • AIP Supplements: Longer-term changes are published in Aeronautical Information Publications (AIP)
References
- • IATA DGR 67th Ed. Section 2.8 — State and Operator Variations
- • IATA DGR 67th Ed. Appendix A — State and Operator Variation Tables
- • ICAO Doc 9284-AN/905 — Technical Instructions for the Safe Transport of Dangerous Goods by Air
- • ICAO Annex 18 — The Safe Transport of Dangerous Goods by Air
- • National competent authority websites for current variation lists