Does dry ice always require a Shipper's Declaration?

No. It's only required when the dry ice is refrigerating another dangerous good that itself requires a declaration. Dry ice alone, cooling non-DG cargo, does not trigger one — though the vented packaging, prior arrangement, and net-weight-marking requirements still apply.

What packaging does dry ice need?

Vented packaging that allows CO2 gas to escape. A sealed, airtight container is not permitted under PI 954.

What happens if the packaging isn't properly vented?

Trapped CO2 gas can build up pressure inside a sealed package during transit, which is exactly why PI 954 mandates venting rather than treating it as a best practice. A carrier can refuse a shipment at acceptance if the packaging doesn't meet this requirement.

Is the 200kg limit per package or per shipment?

Per package, as stated in PI 954. The instruction doesn't state a separate total-shipment cap beyond the per-package figure, so a multi-package shipment can include more than one 200kg-compliant package — confirm the specific carrier's own acceptance limits before booking a large multi-package dry ice shipment.

Dangerous Goods & Compliance

Dry Ice Shipping Rules for Air Freight

UN 1845, Class 9, PI 954 — what actually governs dry ice as air cargo, and the one exemption most generic guidance leaves out.

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UN 1845

Carbon dioxide, solid (Dry ice)

Class 9

Miscellaneous dangerous goods

200 kg

Maximum dry ice per package

PI 954

Governing IATA packing instruction

What actually triggers DG handling for dry ice

Dry ice moving as air cargo is UN 1845, Class 9 Miscellaneous, governed by IATA Packing Instruction 954. The core requirements: packaging must vent released CO2 gas — a sealed, airtight container is not permitted, because trapped gas can rupture the package in flight. The carrier must be notified and agree to accept the shipment before it's tendered; this isn't optional paperwork, an unarranged dry ice shipment can be refused at acceptance. And the net weight of the dry ice itself must be marked on the exterior of the package.

The 200kg-per-package limit under PI 954 applies on both passenger and cargo aircraft — it isn't a cargo-aircraft-only figure. That limit is confirmed unchanged from the 2019 edition through IATA's current 67th Edition (effective 1 January 2026) via independent secondary sourcing; IATA's own 2026 dry ice acceptance checklist PDF could not be decrypted for direct primary verification in this pass, so treat the figure as corroborated rather than freshly re-read from the primary source.

The nuance most generic guidance skips: a Shipper's Declaration is only required for dry ice when it's being used to refrigerate another dangerous good that itself requires a declaration. Dry ice alone, cooling non-DG cargo — fresh produce, a non-hazardous biologic sample — does not trigger a Shipper's Declaration on its own. Every other PI 954 requirement (vented packaging, prior arrangement, net weight marking) still applies regardless of whether a declaration is needed.

Dry ice shipping requirements checklist

PI 954's requirements apply to every dry ice shipment — the Shipper's Declaration requirement is the one exception that depends on what else is in the package.

Vented packaging

The package must allow CO2 gas to vent. A sealed, airtight package is not permitted under PI 954.

200kg per package limit

PI 954 caps dry ice at 200kg per package, on both passenger and cargo aircraft.

Prior carrier arrangement

The operator must be notified and agree to accept the dry ice shipment before tender.

Net weight marked on the package

The exterior of the package — and the overpack, if one is used — must show the net weight of dry ice it contains.

Shipper's DeclarationCONDITIONAL — SEE NOTE

Only required when the dry ice is refrigerating another dangerous good that itself requires a declaration. Dry ice alone, refrigerating non-DG cargo, does not require one.

ULD dry ice rulesCONSOLIDATED / ULD SHIPMENTS

A unit load device packed with dry ice must not contain any other dangerous goods except UN 3373 / ID 8000 (biological substances), and must still allow the CO2 to vent.

Common Misconception

Dry ice doesn't always require a Shipper's Declaration — but getting the exemption wrong is worse than not knowing it exists

A Shipper's Declaration is required only when dry ice is refrigerating another dangerous good that itself needs one. Dry ice alone, cooling non-DG cargo, does not require a declaration — but every other PI 954 requirement (vented packaging, prior arrangement, net weight marking) still applies regardless.

See how dry ice fits UAL's cold chain pharma handling →

Source: IATA Dangerous Goods Regulations, PI 954 (60th Edition, 2019 primary extraction); 200kg limit corroborated as unchanged against the 67th Edition, effective 1 January 2026.

Worked example

Cold chain pharma vs. a straightforward perishable shipment

Take a real cold-chain shipment already on this site — 40kg of insulin moving Mumbai to Toronto — next to a hypothetical shipment that shows the ShipDec exemption in practice.

Insulin needs a 2–8°C cold chain for the full transit. If the packaging uses dry ice to hold that temperature, UN 1845 is declared on the AWB, vented packaging is confirmed before acceptance, and — because insulin itself doesn't carry a hazard classification that needs its own Shipper's Declaration — the dry ice refrigerant alone doesn't trigger one either. PI 954's other requirements still apply in full.

Contrast that with a shipment of dry ice refrigerating a dangerous good that does require its own declaration — some diagnostic reagents and certain biological substances fall in that category. There, the dry ice's presence is declared as part of that same Shipper's Declaration, not filed separately. The trigger is what's being refrigerated, not the dry ice itself.

What UAL handles for you

Every dry ice shipment is checked against PI 954 before it's tendered, and cold chain handling is booked directly with the operating carrier. UAL is IATA DGR certified, so dry ice declarations are handled directly by our own trained team.

Every shipment checked against PI 954

Cold chain booked directly with the carrier

IATA DGR Certified

Frequently asked questions

200kg per package under PI 954, on both passenger and cargo aircraft.

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Dangerous Goods in Air Freight

Lithium Battery Air Shipping Rules

The Shipper's Declaration Process

UN 1845 / PI 954 requirements: IATA Dangerous Goods Regulations, 60th Edition (2019) primary extraction; 200kg quantity limit corroborated unchanged against the 67th Edition (effective 1 January 2026) via independent secondary sourcing — IATA's own 2026 dry ice acceptance checklist PDF could not be decrypted for direct primary verification this cycle. Last verified: July 2026.