Dangerous goods on aircraft: the 2015 rules replaced after 11 years

The framework under which Romania allows or forbids dangerous goods on board an aircraft has been replaced after 11 years. The Ministry of Transport and Infrastructure approved, through Order No. 700 of 17 July 2026, published in Official Gazette of Romania No. 631 of 30 July 2026, edition 5/2026 of the Romanian civil aviation regulation RACR-TABP “Carriage of dangerous goods by air”. This is the ministry’s second substantial intervention in the transport field this summer, after the e-MOVE RO scheme worth 262 million euro for electric charging stations.

The order has three articles. The first approves the regulation, set out in the annex. The second assigns enforcement to the autonomous public undertaking “Romanian Civil Aeronautical Authority” and to all natural or legal persons involved in the carriage of dangerous goods by air. The third repeals Order No. 488/2015 of the minister of transport, which had approved edition 4/2015, published in Official Gazette of Romania No. 235 of 7 April 2015.

The regulation implements Annex 18 to the Convention on International Civil Aviation, signed in Chicago in 1944, and refers constantly to the Technical Instructions of the International Civil Aviation Organization, the document that contains the actual lists of substances, the hazard classes and the quantity limits.

What it changes in practice

The first effect is that the old edition disappears entirely. Air operators, shippers and handling companies that worked under manuals drafted on the basis of the 2015 edition must update their internal procedures, because the reference act no longer exists.

The second effect concerns staff training, the chapter with the heaviest practical load. Instruction is delivered exclusively in training centres certified, authorised or recognised by the Romanian Civil Aeronautical Authority, under the employer’s CBTA type programmes, meaning programmes built on competencies and on the assessment of those competencies. This is the modern standard promoted by the International Civil Aviation Organization, replacing the older logic of fixed length courses.

The third effect is the duty to inform passengers. The authority must ensure that air operators or ground handling companies display, compulsorily in the check-in area, the types of dangerous goods forbidden on board an aircraft. It is the only part of the regulation that an ordinary traveller sees directly.

The fourth effect relates to security. Operators, shippers and the other persons involved in the carriage of high consequence dangerous goods must adopt and apply a security plan. The regulation defines such goods as those with the potential to be used in terrorist attacks, with major loss of life or, in the case of class 7, with serious disruption of socio-economic life. The plan must contain at least the allocation of responsibilities, the procedure for recording the goods and an analysis of vulnerabilities, including at transfers between modes of transport.

The fifth effect is the sanctions regime. In the event of non-compliance, the Romanian Civil Aeronautical Authority may reduce the categories of dangerous goods carried by an operator, may limit, suspend or withdraw its right to conduct such operations and may apply the penalties provided by the applicable legislation.

The sixth effect concerns air mail. Under the Universal Postal Union Convention, carrying dangerous goods by air mail is forbidden, save for the exceptions set out in the Technical Instructions, and where it is allowed it may be done only by designated postal operators authorised by the aeronautical authority.

What has changed compared with the previous situation

The general structure remains familiar to anyone who worked with the previous edition: 13 chapters, from definitions and classification to packaging, labelling, documentation, operator obligations, information, training, compliance, occurrence investigation and security.

What changes is the calibration. The regulation no longer contains its own lists of substances, but refers systematically to the Technical Instructions, which means that international updates apply without a new ministerial order at every revision. That is precisely why the previous edition lasted 11 years and, at the same time, why it fell behind.

The second substantive change is the explicit move to CBTA type training. The old edition spoke of approved training programmes; the new edition requires competency based programmes and centres certified by the authority.

The third change is the strengthening of the security chapter, with mandatory plans for high consequence goods and a minimum list of elements those plans must contain.

The fourth change concerns exemptions. The ministry may grant an exemption in three exhaustively listed situations, namely extreme urgency, cases where other forms of transport are inappropriate, or cases where full compliance with the regulation would be contrary to the public interest, but only if a level of safety equivalent to that of the Technical Instructions is ensured. A separate rule applies to the mere overflight of Romanian airspace, likewise conditional on equivalence of the safety level.

What has not changed: absolute prohibitions remain absolute. Articles and substances identified in the Technical Instructions as forbidden for carriage by air under any circumstances cannot be carried on any type of aircraft, regardless of packaging or authorisations.

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