Compliance Alert: Summer Cooling Sprays as Hazardous Materials in Air & Ocean Freight
—— A Focus on Shipping Cooling Sprays from China: UN1950 & Flammable Liquid Compliance
To: International Buyers Sourcing from China
Subject: Regulatory risks of "instant cooling spray" shipments under UN/DOT/IATA frameworks
Recent testing by Shanghai Consumer Council and Shanghai Research Institute of Chemical Industry Testing (SRICI) evaluated 20 common cooling sprays marketed in China. The results indicate that most products fall under hazardous material classifications—requiring full DG (dangerous goods) protocols for international transport. As your freight forwarder based in Shenzhen, we advise reviewing this before booking air or ocean cargo.
Summary of Test Findings
The study divided samples into two categories:
1. Non-pressurized cooling sprays (liquid-only formulations)
All 10 samples were flammable liquids per GHS/ADR criteria:
- 2 products: Flammable Liquid Category 2 (flash point <23°C, boiling point 50°C)
- 7 products: Flammable Liquid Category 3 (flash point 23–60°C)
- 1 product: Flammable Liquid Category 4 (flash point 60–93°C)
Ocular irritation hazards: One product rated Eye Irritant 2A; four rated Mild Eye Irritant 2B.
2. Pressurized aerosol cooling sprays (gas-propelled containers)
All 10 units showed aerosol flammability:
- 4 classified as Aerosol Category 2 (ignition distance 15–75 cm)
- 4 classified as Aerosol Category 1 (ignition distance 75 cm)
- 2 lacked sufficient composition data but were confirmed non-Category 1 aerosols; exact sub-class pending full SDS disclosure.
Five tested samples presented no eye irritation risk; remaining five untested for ocular effects.
Transport Classification Impact
Under China's Catalog of Hazardous Chemicals (2015) and aligned with UN Model Regulations:
- Aerosols meeting Cat 1 / Flammable Liquids Cat 1–3 / Serious Eye Damage Cat 1, 2A, 2B are regulated as hazardous chemicals.
This triggers mandatory compliance with:
- IATA DGR for air freight (Class 2/3 dangerous goods)
- IMDG Code for sea freight (flammable liquids/aerosols)
- Proper packaging, labeling, shipper's declaration, and carrier approval.
Forwarder Advisory
Many cooling sprays sold as consumer goods actually require:
- Full SDS documentation and verified UN specification packaging
- DG surcharges, certified DG training for handlers, and limited aircraft hold capacity on air routes
- Potential port detention if misdeclared as general cargo
Buyers should confirm classification early via supplier SDS and engage qualified DG forwarders to avoid delays, fines, or cargo rejection at origin.