Most water-based skincare (creams, serums, gel moisturizers, most toners) is not dangerous goods. Products become dangerous goods for transport when they are flammable liquids, which under US rules means a flash point of 60 °C (140 °F) or lower (typical for perfumes and high-alcohol toners and mists, usually shipped as UN1266 Perfumery products, Class 3), or when they are pressurized aerosols (UN1950, Class 2). These can still be shipped, mostly as limited quantities under the IATA rules for air, the IMDG Code for sea and 49 CFR in the US, but carriers need a dangerous goods agreement, international post refuses them, and Amazon FBA reviews them with an SDS. The easiest path is to design formulas and packs that are not dangerous goods from the start.
What counts as dangerous goods in skincare
Dangerous goods (in the US also called hazardous materials or hazmat) are substances that can harm people, aircraft, ships or vehicles in transport. The UN sorts them into 9 classes. For cosmetics, two classes matter almost every time: Class 3 flammable liquids and Class 2 gases (aerosols).
| Product | Usually dangerous goods? | Why |
|---|---|---|
| Water-based creams, lotions, gels, serums, ampoules | No | Mostly water; no low flash point |
| Toners and essences with little or no alcohol | Usually no | High water content; check if ethanol is present |
| Face oils and cleansing oils | Usually no | Plant and mineral oils have high flash points |
| High-alcohol toners, mists, astringents, spot treatments | Often yes | Ethanol lowers the flash point, often below 60 °C |
| Perfumes, colognes, body mists with alcohol | Yes | Usually UN1266 Perfumery products, Class 3 |
| Aerosol sunscreens, aerosol mists, foams in cans, dry shampoo | Yes | Pressurized container: UN1950 Aerosols, Class 2 |
| Non-pressurized pump sprays and trigger mists | Depends on the liquid | Not aerosols; judged on the liquid's flash point |
| Sheet masks, hydrogel patches | Usually no | Water-based essence; check alcohol content |
| Devices with lithium batteries (LED masks, cleansing brushes) | Yes | Lithium batteries have their own rules |
A warning label for consumers ("flammable", "keep away from heat") is a different rule from transport classification. Amazon's dangerous goods guide notes that cosmetics can be regulated as dangerous goods even without a warning label. The SDS from your manufacturer is where the transport classification is written.
Alcohol-based products: flash point, UN1266, Class 3
The flash point is the lowest temperature at which a liquid gives off enough vapor to ignite. Under US DOT rules (49 CFR 173.120), a flammable liquid has a flash point of not more than 60 °C (140 °F). A combustible liquid has a flash point above 60 °C and below 93 °C; in non-bulk packaging it is generally not regulated for ground transport in the US. Above 93 °C it is not regulated as either.
Ethanol mixed with water lowers the flash point quickly, so even a toner with a modest share of alcohol can test below 60 °C. The same US rule lists exceptions that matter for cosmetics: a liquid with a flash point above 35 °C is not a Class 3 flammable liquid if it does not sustain combustion in a standard test, or if it is a water-miscible solution with more than 90% water by mass. Air and sea rules have their own versions of these tests, so ask your dangerous goods specialist which apply to your product.
- UN number and name. Alcohol-based cosmetics and perfumes usually ship as UN1266, Perfumery products (with flammable solvents), Class 3.
- Packing group. Class 3 has packing groups I (greatest danger), II and III, set by flash point and boiling point. Most perfumes are packing group II or III.
- US ground. 49 CFR 173.150 allows limited quantity shipping of Class 3 liquids in inner packagings of up to 1 L for packing group II and 5 L for packing group III, in packages up to 30 kg gross. A separate exception covers retail cosmetics with up to 70% ethyl alcohol in small inner packagings (up to 0.47 L non-glass or 0.23 L glass), with tighter limits by air.
Aerosols: UN1950, Class 2
An aerosol is a non-refillable container with gas under pressure, with a valve that releases the contents as spray, foam or paste. All aerosols ship as UN1950, Aerosols. Flammable propellants (such as butane, propane, dimethyl ether) make them Division 2.1; non-flammable propellants (such as compressed air or nitrogen in some bag-on-valve cans) make them Division 2.2. Both are dangerous goods.
- US limits. 49 CFR 173.306 sets limited quantity rules for aerosols, including a maximum capacity of 1 L per container, pressure limits and a hot water bath or equivalent leak test, in packages up to 30 kg gross.
- Bag-on-valve is still an aerosol. The product sits in a bag inside a pressurized can. It is often Division 2.2, but it is not exempt.
- Pump sprays are not aerosols. A mechanical pump or trigger with no propellant is classified by the liquid inside it.
By air: IATA DGR, limited and excepted quantities
Airlines apply the IATA Dangerous Goods Regulations (DGR), based on the ICAO Technical Instructions. IATA states that the DGR places the responsibility for correct classification on the shipper. A new edition comes out every year; the 2027 edition (68th) takes effect on January 1, 2027.
- Fully regulated.
UN specification packaging, hazard labels, a Shipper's Declaration for Dangerous Goods and trained staff. Some quantities are allowed only on cargo aircraft.
- Limited quantities.
Smaller inner packagings in strong outer packaging, with the limited quantity mark (the diamond with black top and bottom and a "Y" for air). The per-package limits depend on the UN number and packing group in the DGR list of dangerous goods.
- Excepted quantities.
Very small amounts per inner packaging, with an excepted quantities label. Useful for some samples; not every product qualifies.
- Consumer commodity (ID 8000).
Retail consumer products that qualify can travel as ID 8000, Consumer commodity, under the air rules. USPS uses the same idea for domestic air mail.
The exact limits change by edition. Your forwarder's dangerous goods desk checks your UN number, packing group, inner pack size and net quantity against the current DGR before booking.
By sea: the IMDG Code
Sea freight follows the International Maritime Dangerous Goods (IMDG) Code of the International Maritime Organization. For skincare it is usually the simpler route: limited quantity rules allow larger inner packagings than air, and many shipping lines accept limited quantity cargo in LCL and FCL. You still declare it. Tell your forwarder before booking, give them the SDS, and expect the limited quantity mark on cartons and a dangerous goods note to the carrier. Some lines and LCL consolidators refuse dangerous goods or charge a surcharge, so ask early. More on booking is in the Incoterms and LCL vs FCL guide.
SDS section 14: where the answer is written
A safety data sheet (SDS, older name MSDS) follows the 16-section format of the UN Globally Harmonized System (GHS). Section 14, Transport information, lists:
- UN number (or "not regulated")
- UN proper shipping name
- Transport hazard class
- Packing group
- Environmental hazards (marine pollutant)
- Special precautions, often per mode: road, sea (IMDG) and air (IATA)
Section 9 gives the flash point. Carriers, forwarders, 3PLs and Amazon read sections 9 and 14 first. The SDS must match the exact formula you ship; a generic sheet for "a toner" is not enough. If you change the formula, update the SDS. Under OSHA's Hazard Communication Standard the transport section is listed but not enforced by OSHA, because transport rules belong to DOT; carriers and Amazon still expect it filled in.
Couriers and post: DHL, FedEx, UPS, EMS, USPS
| Carrier | Dangerous goods position (check your own account terms) |
|---|---|
| DHL Express | Requires pre-approval for dangerous goods shipments, names perfumes as a typical example, and charges extra; the shipper is legally responsible for compliance |
| FedEx | Shippers must be approved to ship hazardous materials, through their account executive or customer service, and must be able to produce the SDS |
| UPS | Ships hazardous materials under a contract (Hazardous Materials Agreement) tied to a scheduled pickup account; not accepted at retail counters or through online tools; limited quantity ground in the contiguous US is an exception |
| International post, including EMS | Postal networks generally refuse flammable liquids and pressurized gases in international mail; USPS lists flammable liquids and all gases as prohibited internationally |
| USPS domestic | Flammable liquids are not mailable by air; limited quantity surface (ground) mail is allowed within limits, and gases follow separate rules; ethanol-based products need written authorization for air |
For samples of an alcohol-based or aerosol product, plan a courier with a dangerous goods agreement, not the post. KoreanOEM ships sample boxes by EMS, so tell us before samples are made if any formula may be flammable or pressurized.
Amazon FBA dangerous goods review
- Amazon flags the listing.
Products that may be dangerous goods (perfumes, alcohol-based products, aerosols, products with flammable ingredients) are placed in a dangerous goods review before they can be sent to FBA.
- You upload a document.
Amazon's dangerous goods guide says the manufacturer supplies the SDS and the seller uploads it in the Manage dangerous goods classification tool. For a product that is not dangerous goods, sellers often submit an exemption sheet instead, which states why the product is not regulated.
- Amazon classifies the product.
If the information is complete and accurate, Amazon classifies the ASIN. Dangerous goods that FBA accepts are stored and handled under Amazon's dangerous goods program, which can have its own limits; others must be fulfilled by you.
- Keep it current.
The SDS has to match the exact formula and look recent. Outdated or generic sheets are a common reason for rejection, according to seller guides.
Read the current rules in Seller Central before you send stock; listing and FBA basics are in selling skincare on Amazon and warehouse options in the 3PL and fulfillment guide. Walmart's fulfillment service does not accept items classified as fully regulated hazardous materials at all.
Plan formulas and packaging to avoid hazmat
The cheapest dangerous goods shipment is the one you never have to make. Decide at the brief stage; see the product brief guide.
- Keep alcohol out of toners and mists unless it does a real job. Hydrating, alcohol-free toners are standard in K-beauty.
- Ask for the flash point early. If a formula needs some alcohol, have the flash point measured on the lab sample before you approve it.
- Choose a pump or trigger, not an aerosol. A fine-mist pump gives a similar experience for facial mists and keeps the product out of Class 2.
- Keep fragrance low. Fragrance at a normal level in a cream does not make it dangerous goods; a perfume-strength product does.
- Separate risky SKUs. If one product in a range is dangerous goods, ship it separately so the rest of the order does not travel as hazmat.
- Mind sunscreen formats. Aerosol sunscreens are dangerous goods everywhere, and US sunscreens are OTC drugs too. Lotions, gels and sticks avoid the transport problem.
- Assuming a cosmetic is never dangerous goods because it has no warning label.
- Sending alcohol-based samples or aerosols by post, where they are refused or returned.
- Using a generic SDS that does not match the formula, so Amazon or a carrier rejects it.
- Booking air freight for a perfume-strength mist without telling the forwarder.
- Thinking bag-on-valve cans are not aerosols.
- Mixing one dangerous goods SKU into a whole order, so everything ships as hazmat.
- Approving a high-alcohol formula before checking its flash point and the costs it brings.
- Every SKU's ingredient list checked for ethanol, other solvents and propellants
- Flash point known for any product with alcohol or solvents
- SDS for every SKU, matching the exact formula, with sections 9 and 14 filled in
- UN number, class and packing group confirmed by a dangerous goods specialist
- Air, sea and courier routes checked for each dangerous goods SKU
- Carrier dangerous goods agreement in place if you ship parcels
- Limited quantity marks and documents prepared with your forwarder
- Amazon dangerous goods review submitted before the first FBA shipment
- 3PL confirmed for hazmat storage and shipping
- Samples routed by courier, not post, when a formula may be flammable
How KoreanOEM helps
Creams, serums, gels and alcohol-free toners usually ship as ordinary cargo. If a product you want may need dangerous goods handling, raise it before samples are made.
- An SDS (MSDS) with every product, included, with the transport section for carriers, your 3PL and Amazon.
- Formula choices made with you by our chemists in Busan: alcohol-free toners and mists, pump formats instead of aerosols, and fragrance levels that keep products simple to ship. Browse the formula library.
- Spray or high-alcohol formats on request: tell us what you need, and our team checks the formula, the pack and its transport classification with the lab or partner before anything is promised.
- Shipping planned with your forwarder from FOB Incheon, with the documents your forwarder needs. See our export work.
Frequently asked questions
Is skincare considered dangerous goods for shipping?
Can I ship an alcohol-based toner by air?
What is UN1266?
Are aerosol sunscreens and mists dangerous goods?
What flash point makes a cosmetic flammable?
Does Amazon need an SDS for skincare?
Can I send perfume or aerosol samples by EMS or USPS?
Sources
- 49 CFR 173.120: Class 3 flammable and combustible liquids (definitions and exceptions)
- 49 CFR 173.150: Exceptions for Class 3, including limited quantities and alcohol-containing cosmetics
- 49 CFR 173.306: Limited quantities of compressed gases, including aerosols
- PHMSA: Hazardous materials safety
- IATA: Dangerous Goods Regulations
- IMO: Dangerous goods and the IMDG Code
- OSHA: Hazard Communication Standard, safety data sheets
- Amazon Seller Central: Dangerous goods identification guide (hazmat), sign-in required
- ComplianceGate: Amazon hazmat review and exemption sheets (secondary source)
- DHL Express: Shipping dangerous goods
- FedEx: How to get approval for shipping hazardous materials
- UPS: Shipping hazardous materials
- USPS Publication 52: Flammable and combustible liquids and Gases
- Walmart Marketplace Learn: WFS prohibited products, fully regulated hazmat
Checked against these sources in October 2026. Rules and fees change; check with the authority or your importer before you sell.