Refrigerating Machine Transport Guide
From Freon science to full DG declaration

Refrigeration equipment (ice makers, refrigerators, air conditioners, cold-room units) is common cargo. Many companies shipping a refrigerating machine for the first time run into the same confusion: the unit carries a small amount of refrigerant inside — is it dangerous goods? Must it be declared? Can it be exempted? The answer depends on two things: ① which refrigerant is charged in the machine; ② how much is charged. This guide covers both.

1. What refrigerants exist? What exactly is "Freon"?

1.1 Freon is a family, not a single substance

"Freon" (a DuPont trademark) is the collective name for fluorine-containing halogenated hydrocarbon refrigerants, mainly composed of fluorine, chlorine and carbon (plus hydrogen). It is not a single chemical but a large family, named with R + number:

• R12 (dichlorodifluoromethane), R11 (trichlorofluoromethane) — the first generation;
• R22 (chlorodifluoromethane) — a transitional generation;
• R134a (tetrafluoroethane), R32 (difluoromethane), R410A (R32/R125 blend) — the current mainstream;
• R1234yf (tetrafluoropropene) — the next generation.

1.2 Five generations by ozone depletion / global warming potential

The evolution in one sentence: humans first used chlorine-containing CFCs (ozone-depleting) → reduced chlorine into HCFCs → removed chlorine entirely into HFCs (no ozone depletion but high GWP) → then cut GWP further toward HFOs and natural refrigerants. "Environmentally friendly" and "safety (flammability)" are in tension: the more eco-friendly a refrigerant is, the more flammable it tends to be (e.g. R290, R600a, R32) — which is exactly why transport rules pay so much attention to refrigerating machines.

1.3 China's control basis (why Freon is "sensitive")

• MEP Announcement 2005 No. 117: prohibits the import and export of industrial and commercial compressors using CFCs as refrigerant;
• Huan Han [2007] No. 200: prohibits the production, sale, import and export of household appliances using CFCs as refrigerant/foaming agent;
• The legal source of these bans is the Montreal Protocol's global phase-out mechanism for ozone-depleting substances (ODS).

2. Which refrigerants go into which equipment

The same type of equipment uses different refrigerants across eras, markets and brands. The mainstream mapping by equipment type:

3. Transport exemption for equipment with different refrigerants

3.1 Classify first: is the refrigerant flammable?

There are only two dangerous goods entries for refrigerating machines, split by refrigerant flammability:

3.2 Sea transport exemption (IMDG Code 42-24, Chapter 3.3)

① Non-flammable refrigerating machines (UN 2857) — exemption

Interpretation: non-flammable refrigerating machine + refrigerant charge < 12 kg (or ammonia solution < 12 L) → the whole unit is not managed as dangerous goods and can be booked as ordinary cargo.

② Flammable refrigerating machines (UN 3358) — exemption

Interpretation: flammable refrigerating machine + charge < 12 kg + pressure parts designed and tested at 3× working pressure → the whole unit is exempt, likewise not managed as dangerous goods.

3.3 Air transport exemption (IATA DGR 67)

Air rules differ from sea and are stricter. Under the IATA DGR 67 Dangerous Goods List, refrigerating machines fall into the following cases:

3.4 Road transport exemption (JT/T 617-2018 / ADR / RID)

Domestic road transport follows JT/T 617 (equivalent to the UN TDG Model Regulations), and the refrigerating machine exemption is identical to sea transport (IMDG):

• Non-flammable machine: contains <12 kg of Class 2.2 gas, or <12 L ammonia solution (UN 2672) → exempt, not managed as dangerous goods;
• Flammable machine: contains <12 kg of flammable non-toxic liquefied gas, and pressure parts designed and tested at 3× working pressure → exempt.

European road (ADR) and rail (RID) share the same origin and the same 12 kg threshold.

3.5 Exemption quick reference table

3.6 The appraisal certificate is still required even when exempted

Even when a refrigerating machine meets the exemption above and is not declared as dangerous goods, in practice carriers (shipping lines / airlines / fleets) and customs usually still require a《Transport Dangerous Goods Appraisal Certificate》(Cargo Transportation Condition Appraisal), issued by a qualified appraisal agency, proving the machine is "not dangerous goods" or "meets the exemption conditions".

4. How to ship equipment that cannot be exempted

When the charge is ≥ 12 kg (or the carrier requires mandatory declaration), the refrigerating machine must be shipped through the full dangerous goods process:

4.1 Determine the proper shipping name and UN number

• Non-flammable refrigerant → UN 2857, REFRIGERATING MACHINES, containing non-flammable, non-toxic gases or ammonia solutions (UN 2672), Class 2.2;
• Flammable refrigerant → UN 3358, REFRIGERATING MACHINES, containing flammable, non-toxic, liquefied gas, Class 2.1.

4.2 Documentation (three core items)

1. Dangerous goods declaration / maritime declaration (submitted per the port of origin, stating UN number, class, proper shipping name and charge);
2. Dangerous goods packaging certificate: the pressure container (refrigeration system) must meet packing instruction P003 + PP32, with a valid inspection certificate;
3. SDS / MSDS: see the important note below.

4.3 Marking and labelling

• Dangerous goods label: the Class 2.1 (flame) or Class 2.2 (gas cylinder) label on the outer package; the UN number near the label or inside the dangerous goods mark;
• Proper shipping name marking: clearly shown on the outer package or in the shipping documents per Chapter 5.4.

4.4 Sea stowage and segregation (IMDG comparison)

4.5 Air and road differences

• Air: IATA DGR 67 applies. When a non-flammable refrigerating machine exceeds the exemption, passenger aircraft is forbidden and cargo-only applies (Packing Instruction 211, special provision A26); flammable refrigerating machines (R290/R600a/R32/R1234yf) are forbidden on both passenger and cargo aircraft — evacuate the refrigerant first or route by sea/road.
• Domestic road: JT/T 617 series applies (equivalent to TDG), with the same classification, UN numbers and 12 kg exemption threshold.

5. Practical checklist (one page for the shipper)

1. ✅ Read the nameplate: confirm refrigerant model + charge (kg);
2. ✅ Judge flammability: non-flammable → Class 2.2; flammable (R290/R600a/R32, etc.) → Class 2.1;
3. ✅ Check the exemption: sea/road charge < 12 kg and sealed unit → exempt; flammable refrigerating machines are forbidden by air;
4. ✅ Even when exempted, obtain the Transport Dangerous Goods Appraisal Certificate (Ginga can handle it);
5. ✅ Over the exemption: ≥ 12 kg → full DG declaration under UN 2857 / UN 3358, with an SDS whose subject is the refrigerating machine and Section 14 noting charge & exemption;
6. ✅ Check environmental compliance: if the equipment contains CFCs such as R12/R11 → pass the ODS import/export ban first;
7. ✅ Shipping refrigerant cylinders separately → declare under the corresponding refrigerant gas UN entry, no 12 kg exemption.

Appendix: regulations referenced