To support a Non-DG conclusion, identify the exact finished product and package, review its composition and relevant physical properties, check the transport criteria for the intended mode, and provide reliable test or supplier evidence where needed. A product name or “non-toxic” claim is not proof.
What does Non-Dangerous Goods mean?
It means the defined product and shipment are not regulated as dangerous goods under the transport framework being applied. The conclusion should identify the product, relevant mode and evidence reviewed. It should not be presented as a universal government approval.
Non-DG is not the same as non-hazardous. Section 2 of an SDS addresses hazard communication. Transport classification considers separate criteria and the complete shipment. A battery, aerosol, pressurised package or mode-specific provision may affect transport even when the product has limited workplace classification.
What evidence supports a Non-DG conclusion?
| Evidence | What it should establish | Common weakness |
|---|---|---|
| Finished formulation | Exact ingredients, concentrations and supplied form. | Only the main ingredient or a generic recipe is provided. |
| Supplier SDS files | Current hazard and property information for raw materials. | Documents are old, incomplete or cover a different grade. |
| Physical properties | Relevant values such as flash point, pH, pressure and state. | Values are estimated without a reliable basis. |
| Finished-product SDS | Consistent identity, classification and Section 14 information. | An ingredient SDS is submitted instead. |
| Packaging details | Container type, quantity, pressure and complete configuration. | The review ignores an aerosol, battery or inner package. |
| Transport mode | Whether air, sea, road or more than one mode is involved. | A conclusion for one mode is reused for another. |
| Test reports | Product-specific values required to resolve classification. | A report covers another formulation or test sample. |
The evidence should form one consistent chain. Product name, composition, physical data, SDS, invoice and package description should all refer to the same item.
Is laboratory testing required to prove Non-DG status?
Not automatically. Existing reliable data may support the conclusion. Testing becomes important when a transport criterion depends on a value that is unknown, disputed or not reliably transferable to the finished product.
For example, a formulated liquid may need credible flash-point data when flammability is central to its classification. A battery shipment may require UN 38.3 evidence. Other products may need data for corrosivity, pressure, self-reactivity or another relevant property.
Use Is Lab Testing Required for MSDS? to separate SDS authoring inputs from product testing.
Which document proves that a product is Non-DG?
There is no single universal certificate accepted by every courier, airline, shipping line or freight forwarder. The requesting party may accept one or more of the following:
- A current finished-product SDS with supported Section 14 information.
- A signed Non-DG declaration using the carrier’s wording.
- A transport-classification assessment or supporting statement.
- A laboratory report for a relevant physical property.
- A battery test summary or other product-specific test evidence.
- A carrier questionnaire, portal submission or product declaration.
Ask the reviewer what it requires before preparing the output. Read MSDS vs Non-DG Certificate for the purpose of each document.
How does the evidence change by product?
| Product | Evidence that may be important |
|---|---|
| Perfume or fragrance | Alcohol content, flash point, package volume and mode. |
| Water-based cleaner | Complete formula, pH, corrosivity basis and package. |
| Aerosol | Propellant, pressure, container and finished-article classification. |
| Lithium battery or device | Chemistry, configuration, energy rating, UN 38.3 and package. |
| Paint, ink or adhesive | Solvents, flash point, physical form and quantity. |
| Powder or granules | Composition, dust behaviour and any relevant transport criteria. |
Descriptions such as “natural,” “herbal,” “food grade,” “cosmetic,” “water-based” and “non-toxic” do not replace this evidence.
What is a defensible Non-DG review workflow?
- Capture the carrier request: save its exact language and required form.
- Lock the product identity: define formulation, grade, model and supplied form.
- Define the shipment: record package, quantity, route and transport mode.
- Collect reliable evidence: gather formulation, SDS files, specifications and available results.
- Check applicable criteria: review the finished product and package against the relevant mode.
- Resolve data gaps: obtain clarification or testing instead of assuming a favourable result.
- Prepare the requested document: ensure the SDS and any declaration use consistent information.
- Submit for carrier review: keep final acceptance separate from document preparation.
Need a Non-DG evidence review for a specific courier, package or route?
Check the Evidence Required →What does not prove Non-DG status?
- A marketing label saying safe, eco-friendly or non-toxic.
- An ingredient SDS that does not cover the finished product.
- A competitor’s SDS for a similar commercial name.
- A declaration prepared without formulation or property data.
- A test report for a different formula, grade or package.
- A previous carrier acceptance for another route or mode.
Which official references support this guide?
- PHMSA: shipper classification responsibility
- FedEx India: dangerous-goods shipping process
- UNECE: UN Model Regulations, Revision 24
- IATA: Shipper’s Declaration for Dangerous Goods
Frequently Asked Questions
There is no single universal document accepted by every carrier. A current SDS, classification assessment, physical data, test reports and a carrier-specific declaration may form the evidence file.
Sometimes a carrier accepts it, but Section 14 alone may not be sufficient. The reviewer may request supporting data or a separate declaration.
No. Testing is needed when the classification depends on a physical property or other result that cannot be supported by reliable existing evidence.
Only after assessment. Marketing descriptions do not establish transport status; composition, physical properties, package and mode still need review.