UN 3548 Air Transport: Exemption when containing max. 5 kg of UN 3077 respective 5L of UN 3082
The exemption for max. 5 kg UN 3077 or 5 L UN 3082 per inner or single packaging from the A197 are known.
Until now, it was impossible to apply this exemption to articles, since an article is definitely neither an inner nor an
single packaging. The automotive industry in particular had a major challenge here with transmissions.
In 2023 there is the new packing instruction 975 for UN 3548 and it now says ".... This packing instruction may only
be used for articles to which no other proper shipping name has been assigned and which contain only
environmentally hazardous substances where the quantity of environmentally hazardous substances in the article
exceeds 5 liters or 5 kilograms.
This passage made us wonder what happens with articles containing max. 5 kg UN 3077 or 5 L UN 3082?
On inquiry Dave Brennan of the IATA provided us with the information that these articles, which contain max. 5 kg UN
3077 and/or 5 L UN 3082, are not subject to the regulations, thus can be shipped as "not restricted". Unfortunately,
there is no explanatory text in the IATA DGR or ICAO TI that this is the case.
