Based on 49 CFR (DOT) and 10 CFR (NRC) as currently published in the eCFR
Excepted Packages by Air: What’s Required and What’s Not
What you need and don’t need when shipping excepted packages of radioactive material by air under the IATA Dangerous Goods Regulations.
Quick Answer
Excepted packages (UN2908–UN2911) are the simplest category of radioactive material to ship by air. They are exempted from the Shipper's Declaration (DGD), the standard diamond hazard labels, and the Notification to Captain (NOTOC). However, they are not exempt from all requirements.
- No DGD required — information goes on the Air Waybill instead
- No hazard labels — use the rectangular “Excepted Package” handling label with red hatchings
- No NOTOC — does not need to appear on the Notification to Captain
- Marking still required — UN number, shipper/consignee addresses
- Dose rate limit: ≤ 5 μSv/h (0.5 mrem/h) at any point on the surface
- Passenger aircraft: Allowed — no cargo-only restriction
Classify a radioactive shipment right now — no account required.
Try Live DemoWhy Excepted Package Air Rules Matter
Excepted packages are the most commonly shipped category of radioactive material by air. Smoke detector check sources, medical calibration sources, industrial gauges, luminous devices, and empty packaging returns — these all move as excepted packages when the activity is within the limits.
The simplicity of excepted packages is also their trap. Because they're exempt from so many requirements, shippers sometimes assume they're exempt from everything. I have seen packages rejected at airline cargo counters because the shipper skipped the Air Waybill entries entirely, or because the excepted package handling label was missing. “No DGD required” does not mean “no documentation required.”
Understanding exactly what is and isn't required prevents both over-compliance (wasting time on unnecessary paperwork) and under-compliance (missing the requirements that do apply).
Who Needs to Know This
This applies to anyone who:
- Ships small radioactive sources, calibration devices, or instruments by air
- Returns empty packaging (UN2908) via air freight
- Ships limited quantity (UN2910) material by air
- Ships instruments or articles (UN2911) by air
- Trains personnel who prepare excepted packages for air transport
What's NOT Required for Excepted Packages by Air
The whole point of the “excepted” classification is to reduce the regulatory burden for very low-activity shipments. Here's what you don't need:
- No Shipper's Declaration for Dangerous Goods (DGD) (IATA DGR §10.8.8.3.1)
- No standard hazard labels — no Category I-White, II-Yellow, or III-Yellow diamond labels
- No package category assignment — excepted packages are not categorized
- No Transport Index calculation
- No NOTOC entry — excepted packages do not appear on the Notification to Captain
- No “Dangerous Goods as per associated Shipper's Declaration” statement in the Air Waybill Handling Information box
- No Cargo Aircraft Only restriction — excepted packages can go on passenger aircraft
Tip: Compare this to ground transport under 49 CFR, where excepted packages don't require shipping papers at all (unless they're RQ or waste). For air, you still need the Air Waybill entries — the documentation burden is lighter than a full DGD but not zero.
What IS Required for Excepted Packages by Air
1. Air Waybill Entries
The following must appear in the “Nature and Quantity of Goods” box of the Air Waybill (IATA DGR §10.8.8.3.3):
- Name and address of shipper and consignee
- UN number preceded by “UN” (e.g., “UN 2910”)
- Proper shipping name
- Competent authority certificate identification marks (if applicable)
- Number of packages (unless they are the only packages in the consignment)
The preferred format is UN number first, followed by proper shipping name. This is simpler than a full DGD, but every item must be present. In my experience, the most commonly missed entry is the number of packages — shippers write the UN number and proper shipping name but forget to indicate how many packages are in the consignment.
2. Excepted Package Handling Label
Every excepted package shipped by air must bear the “Radioactive Material, Excepted Package” handling label (IATA DGR §10.7.4.4.3). This is a rectangular label (minimum 105 × 74 mm) with:
- Red diagonal hatchings on the border
- Printed in black and red on white, or red only on white
- Affixed on a contrasting background
If the package is in an overpack, the label must be clearly visible through the overpack or reproduced on it.
Important: This handling label is specific to air transport. Domestic ground shipments under 49 CFR require different excepted package markings but not this specific label. If you ship the same package both by air and ground, you need the IATA handling label for the air leg.
3. Package Markings
Excepted packages must be marked with (IATA DGR §10.7.1.3.2):
- UN number preceded by “UN”
- Full name and address of shipper and consignee
- Gross weight if over 50 kg
Note that unlike IP, Type A, and Type B packages, excepted packages do not require the proper shipping name as a mark on the package itself — just the UN number.
4. Dose Rate Compliance
The surface dose rate must not exceed 5 μSv/h (0.5 mrem/h) at any point on the external surface (IATA DGR §10.3.11.1.1.2). For UN2911 instruments and articles, there is an additional limit of 0.1 mSv/h (10 mrem/h) at 10 cm from the external surface.
5. Activity Within Limits
The activity must be within the limits specified in IATA DGR Table 10.3.C for the applicable category (materials, instruments/articles, or empty packagings). These limits are the same as the 49 CFR excepted package limits.
6. Contamination Limits
The non-fixed radioactive contamination on any external surface must not exceed the limits in IATA DGR §10.5.3.2. For empty packagings (UN2908), internal non-fixed contamination must not exceed 400 Bq/cm² for β/γ and low-toxicity alpha, or 40 Bq/cm² for other alpha emitters.
7. Training
Personnel who prepare excepted packages for air shipment must be trained as required by IATA DGR §1.5. Even though the documentation is simplified, the training requirement still applies.
Ground vs. Air: What Changes for Excepted Packages?
| Requirement | Ground (49 CFR) | Air (IATA DGR) |
|---|---|---|
| Shipping paper / DGD | Not required (unless RQ or waste) | No DGD; Air Waybill entries required |
| Labels | Excepted package marking per 49 CFR 173.422 | Excepted package handling label (red hatchings) |
| Package markings | UN number, “RQ” if applicable | UN number, shipper/consignee addresses |
| Language | English (domestic US) | English required, plus origin country language if applicable |
| Passenger vehicle/aircraft | No restriction | No restriction — passenger aircraft allowed |
| Old labels | Must remove/obliterate | Must remove/obliterate, plus old labels must no longer be visible (UN2908) |
The main practical difference is the Air Waybill entries and the excepted package handling label. If you're used to ground shipping excepted packages with minimal documentation, the air requirements add a small but important step. Most of the time, this is a 5-minute process — but only if you know it's required.
Special Cases
Excepted Packages with Other Dangerous Properties
If your excepted package contains material with other hazardous properties (e.g., corrosive, flammable), the other hazard takes precedence (IATA DGR §10.5.8.3). Special Provisions A130 and A194 apply, and a DGD is required for the subsidiary hazard unless the A130(a) conditions are met.
Dry Ice as Refrigerant
When dry ice (UN1845) is used as a refrigerant for an excepted package, no DGD is required. The dry ice details go in the “Nature and Quantity of Goods” box of the Air Waybill (IATA DGR §10.8.8.3.2). The dry ice marking and labeling requirements still apply separately.
Air Mail
Excepted packages transported by air mail must comply with the additional requirements of IATA DGR Subsection 10.2.2 (IATA DGR §10.5.8.1(d)). Postal regulations may impose additional restrictions beyond what IATA requires.
How RadShip.com Helps
RadShip.com makes excepted package air shipments straightforward:
- RAMcalc — Determines whether your material qualifies as an excepted package and identifies the correct UN number (UN2908, UN2909, UN2910, or UN2911)
- Verifies activity against the Table 10.3.C limits for your specific radionuclide and package type
- Pre-shipment checklists include the Air Waybill entries and handling label requirements
Here's the reality: excepted packages are the easiest category to get right, but the most common category to get lazy about. Having a tool that confirms qualification and reminds you of the air-specific requirements eliminates the casual errors I see most often — missing Air Waybill entries, forgotten handling labels, and old labels not removed from reused packaging.
Common Questions
Do excepted packages need a Shipper's Declaration (DGD) for air transport?
No. Excepted packages are exempted from the DGD requirement (IATA DGR §10.8.8.3.1). The required information — UN number, proper shipping name, number of packages, and shipper/consignee details — goes in the “Nature and Quantity of Goods” box of the Air Waybill instead.
Can excepted packages go on passenger aircraft?
Yes. There is no cargo-only restriction for excepted packages. Their activity levels are low enough that no special handling, separation distances, or aircraft limitations apply.
What is the dose rate limit for an excepted package?
5 μSv/h (0.5 mrem/h) at any point on the external surface (IATA DGR §10.3.11.1.1.2). For UN2911 instruments and articles, the dose rate at 10 cm from the external surface must also not exceed 0.1 mSv/h (10 mrem/h).
Does an excepted package appear on the NOTOC?
No. Excepted packages do not need to appear on the Notification to Captain (NOTOC). The optional text on the excepted package handling label — “The information for this package need not appear on the Notification to Captain (NOTOC)” — confirms this but is not required to be on the label.
Do I need to remove old labels from reused excepted packaging?
Yes. All irrelevant labels must be removed or obliterated before the package is presented to the airline (IATA DGR §10.7.2.1(a)). For empty packagings (UN2908) specifically, previous labels must no longer be visible.
Summary: Your Excepted Package Air Shipment Checklist
Before shipping an excepted package by air, verify:
- ☐ Activity is within Table 10.3.C limits for your UN number
- ☐ Surface dose rate does not exceed 5 μSv/h (0.5 mrem/h)
- ☐ For UN2911: dose rate at 10 cm does not exceed 0.1 mSv/h
- ☐ External contamination is within limits
- ☐ UN number preceded by “UN” is marked on the package
- ☐ Shipper and consignee names and addresses are on the package
- ☐ Excepted package handling label (red hatchings) is affixed
- ☐ All old or irrelevant labels and marks removed/obliterated
- ☐ Air Waybill “Nature and Quantity of Goods” box includes: UN number, proper shipping name, number of packages, shipper/consignee
- ☐ If overpack: handling label visible or reproduced on overpack
- ☐ If dry ice used: dry ice details in Air Waybill
- ☐ Personnel preparing the shipment are trained per IATA DGR §1.5
Regulatory References
IATA (Air Transport):
- IATA Dangerous Goods Regulations §10.3.11.1 — Classification as excepted packages
- IATA DGR §10.5.8 — Excepted package transport requirements
- IATA DGR §10.7.1.3.2 — Excepted package marking requirements
- IATA DGR §10.7.4.4.3 — Excepted package handling label specifications
- IATA DGR §10.8.8.3 — Air Waybill requirements for excepted packages
- IATA Dangerous Goods Regulations — Official publication page
DOT Requirements (Ground Transport Comparison):
- 49 CFR 173.421–173.428 — DOT excepted package requirements
- 49 CFR 173.422 — DOT excepted package marking requirements
Related RadShip Guides:
- Excepted Packages: When and How
- UN2908/2909: Empty Packages & Manufactured Articles
- UN2910: Limited Quantity Packages
- UN2911: Instruments and Articles
- The DGD: Class 7 Guide
- Marking and Labeling for Air Shipment
- Shipping Radioactive Material by Air: IATA Overview
About the Author
Scott Brown is the Subject Matter Expert and co-creator of RadShip.com. He has been a trained hazmat shipper for over 15 years and specializes in DOT Class 7 radioactive material shipping.
This guide is based on the requirements of the IATA Dangerous Goods Regulations and 49 CFR (DOT) as of the publication date. As regulations are amended, RadShip.com is committed to keeping its guides current with the latest requirements.
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