Dangerous goods on aircraft 2025-2026: what airlines and shippers must change

Key data

Companies that send or manage dangerous goods by air have an active obligation from April 14, 2026: to comply with the new technical requirements of the Addendum to the ICAO Document 9284/AN/905, 2025-2026 edition, published by the General Directorate of Civil Aviation.

This update is not optional. It is binding in Spain and incorporates the changes approved by the International Civil Aviation Organization. Ignoring it exposes the company to administrative penalties and, more seriously, compromises the operational safety of flight operations.

What does this regulation establish?

The General Directorate of Civil Aviation publishes the Addendum to ICAO Document 9284/AN/905 2025-2026 edition, which updates the international technical instructions for the safe transport of dangerous goods by air. These instructions are the global reference standard for classifying, packing, labeling, documenting and transporting substances and objects that pose a risk during flight.

The Addendum contains the technical changes approved by ICAO for the 2025-2026 cycle. By being published through a resolution from the General Directorate of Civil Aviation, it becomes binding in Spain: it is not a recommendation, but a legal obligation for all operators in the sector.

The sectors expressly identified as particularly relevant for this update are:

• Chemicals
• Pharmaceuticals
• Lithium batteries
• Flammable materials
• Corrosive materials

Companies must adapt three key areas: their internal procedures, personnel training and shipment documentation.

Economic and operational impact

The impact of this regulation is not measured in a published fee or penalty figure, but in the cost of non-adaptation and the resources needed to comply.

Affected companies must assume operational costs on three fronts:

• Review and update of internal procedures: This involves technical staff time and, in many cases, hiring specialized consulting in dangerous goods (DGR — Dangerous Goods Regulations).
• Personnel training: ICAO regulations require that personnel involved in the shipping, handling and transport process are trained and up-to-date. Each regulatory cycle requires recertification or refresher training.
• Update of shipment documentation: Shipper declarations, labels, marks and accompanying documents must reflect the new technical requirements. Errors at this point are a direct cause of cargo rejection and penalties.

The most immediate economic risk is not the penalty itself, but the paralysis of shipments due to incorrect documentation or outdated procedures, with the cost of delays, claims and loss of customers that this entails.

Who does it affect?

This regulation directly affects the following companies and professionals:

• Airlines that operate cargo routes or accept dangerous goods on their flights.
• Air cargo operators (freight forwarders, customs brokers) that manage the shipment of goods classified as dangerous.
• Handling agents at airports that handle, store or prepare dangerous goods for loading onto aircraft.
• Shipping companies from any sector that send products classified as dangerous goods by air, including:

• Chemical sector companies
• Laboratories and pharmaceutical companies
• Lithium battery manufacturers and distributors (including electronic devices with built-in batteries)
• Companies that ship flammable or corrosive materials

Practical example

A lithium battery distribution company for electric vehicles that regularly ships batches by air to customers in Europe and Asia must act immediately on three fronts:

1. Documentation: Shipper declarations of dangerous goods must be updated to reflect the new technical requirements of the ICAO 2025-2026 Addendum. If the company continues to use templates from the previous edition, its shipments may be rejected at origin or destination.

2. Training: Logistics and shipping personnel who sign the dangerous goods declaration must have received training updated according to the new edition. If the last training was with the previous edition, refresher training must be scheduled.

3. Internal procedures: The company's procedures manual for packing, labeling and declaring lithium batteries must be reviewed and updated to align with the technical changes in the Addendum. An internal or external audit before the next shipments reduces the risk of incidents.

What should companies do now?

1. Obtain the ICAO 9284/AN/905 Addendum 2025-2026 edition: Access the official text published in the BOE to identify the specific technical changes that affect your goods and operations.
2. Review internal procedures: Compare your current procedures with the new technical requirements. Prioritize the processes of classification, packing, labeling and shipment documentation.
3. Verify the status of personnel training: Check that all personnel involved in the process (shipping, logistics, handling) have current training according to the 2025-2026 edition. Schedule refresher training if necessary.
4. Update shipment documentation: Review and update shipper declaration templates, labels and marks to comply with the new technical requirements.
5. Communicate changes to the supply chain: Inform your cargo agents, customs brokers and handling operators of the changes to ensure consistency throughout the chain.
6. Document the adaptation: Keep records of reviews conducted, training provided and procedure updates. In case of inspection or incident, this documentation is key to demonstrating diligence.

Official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. The information contained herein is based on the Resolution of April 14, 2026, from the General Directorate of Civil Aviation and the Addendum to ICAO Document 9284/AN/905, 2025-2026 edition, published in the Spanish Official State Gazette (BOE). Companies must verify the specific requirements applicable to their operations and, if necessary, consult with specialized legal and technical advisors. The author and publisher assume no liability for the use or misuse of this information or for any damages arising from non-compliance with applicable regulations.