Dangerous goods by mode: IMDG, ADR, RID and IATA One cargo, four rulebooks. Change the mode, change the rule.

Four modes, four rules

Road: the activity certificate

The Turkish road regulation requires businesses in the transport chain to hold a Dangerous Goods Activity Certificate (TMFB) (art. 7):

• Carriers and tank-container operators, regardless of quantity.
• Businesses that received or sent 20 tonnes or more of dangerous goods in the last calendar year; also packers, loaders, fillers and unloaders above that threshold.
• Businesses dealing with Class 1 (except 1.4S) and Class 7 (except those under ADR 1.7.1), regardless of quantity.

For receivers and unloaders, activities under the ADR 3.3, 3.4 and 3.5 exemptions are not counted towards the quantity (art. 7/2). Under the regulation, where the carriage is based on a contract, the person named as "consignor" in the contract is the consignor (art. 4). So if a forwarder is named as consignor, the consignor's obligations fall on it.

Sea: cargo interests and the packing certificate

In the Turkish sea regulation, the "cargo interest" is the consignor, receiver or agent of the dangerous cargo or the freight forwarder (art. 4/1-v). The cargo interest (art. 9):

• prepares the mandatory documents and makes sure they travel with the cargo,
• ensures the cargo is correctly classified, packed, marked, labelled and placarded,
• ensures safe loading, stowage and securing into approved packagings and cargo transport units.

The IMDG Code's Container/Vehicle Packing Certificate is completed and signed by the person who loads the cargo into the container and who has received IMDG 1.3 training; it is presented to the port before or together with the cargo, and a copy is placed on the inside wall of the container's right-hand door (art. 15/4). UN-certified packagings are mandatory (art. 15/3). When IMO rules change, the current IMO provisions apply (art. 24/4).

Air and lithium batteries

SHT-18 is based on the ICAO Technical Instructions; unless otherwise provided, the transport document is prepared at least in English (art. 30). For lithium-ion batteries, IATA's 2026 guidance sets the state-of-charge (SoC) limit as follows:

Safety data sheet

The supplier of a substance or mixture classified as hazardous must give the recipient a safety data sheet (SDS) prepared by a certified chemical assessment expert (Turkish KKDİK Regulation art. 27). Section 14 of the sheet is transport information: the UN number, the UN proper shipping name and the transport hazard class are given there. It is the first place to look to find out whether a cargo is dangerous goods.

When it goes wrong

The forwarder is named as consignor in the contract

Under the road regulation, the person named as "consignor" in the contract is the consignor, and the obligations pass to them. At sea, the forwarder is already within the definition of "cargo interest". Settle from the start who is named in which capacity.

The packing certificate is signed by someone untrained

The certificate is presented to the port before or together with the cargo; a signature by someone without the training, or a copy missing from the door, is contrary to the regulation.

A battery-powered product is sent by air fully charged

For lithium-ion batteries packed with equipment, the 30% limit has been mandatory since 2026. In Section I, anything above it may be carried only with the written approval of the State of Origin and the State of the Operator.

Documents prepared to an old edition

At sea, amendment 42-24 has been mandatory since 1 January 2026; by road, the transition period for the old ADR ended on 30 June 2025. Check document and label templates against the current edition.