Logistics service providers transporting air cargo under a so-called E (light) approval must convert it to a D approval. That was actually supposed to happen by July 1, but the Environmental and Transport Inspectorate pushed the deadline to Oct. 1. We’d be happy to tell you what this means for your business.
Reason
Much has changed recently in the legal landscape surrounding air transport dangerous goods. Various decisions and regulations have been amended to allow the introduction of the IATA CBTA training methodology. In addition, the government wanted to formalize the actually nonexistent E-light recognition.
Recognition system
For the purpose of the CBTA system, the Dutch government works with a recognition system, with one recognition for each role in the logistical process (A through E):
A: for senders
B: for forwarding air cargo agents
C: for ground handlers
D: for logistics service providers
E: for organizations specializing in the transportation of dangerous goods by air
E-light
In addition, the government created the “E-light recognition” a few years ago, for companies that were somewhat in danger of falling between the cracks. The activities of these companies did not fit the conditions for A-recognition (sender), but the conditions for E-recognition (specialized company) were again excessive. To offer the business community a suitable solution for this, the Environmental and Transport Inspectorate (Inspectie Leefomgeving & Transport) then came up with a stripped-down version of E-recognition: the E-light recognition.However, this recognition was nowhere secured in laws and regulations, so its legal status remained rather vague. That is why the government wanted to formalize E-light recognition over time. This has since been done.
D-recognition
On June 12, the Decree on the Transport of Dangerous Goods by Air was published in the Staatscourant. In it, the “E-light recognition” is included as D recognition:
‘a recognition for a logistics service provider, being a natural or legal person, which has the authority to prepare dangerous goods which it holds in contractual storage for third parties, on behalf of the owner, and to offer them as consignors for transport by air.’
No owner
Or put more simply: The D-approval holder may act as a consignor for air transport dangerous goods, not owning the goods to be shipped. Therein also lies the major difference with A-recognition: An A-recognition holder owns the goods to be shipped, a D-recognition holder does not. In terms of operations, this means that a logistics service provider with D approval contractually stores the dangerous goods for third parties and prepares them for shipment. Then, on behalf of the owner, he offers these goods for transportation by air.
Many companies that now have E-light approval are satisfied with D approval for their operations
What to do.
Thus, E-light recognition as such disappears altogether. If you currently hold this accreditation, you must decide whether to:
- want to keep it as a full-fledged E-recognition;
- want it converted to the new D accreditation.
In the first case, you will have to start meeting all the conditions associated with full-fledged E-recognition. Then you need a DGOM (Dangerous Goods Operations Manual), among other things.
Eased transposition
In the second case, you have to apply for D accreditation. Many companies that now have E-light approval are satisfied with D approval for their operations. They can have the E-recognition converted to a D-recognition. According to Article 9a paragraph 1 of the Decree on the Transport of Dangerous Goods by Air, this conversion can be relaxed (free of charge, upon request) until July 1, 2023.
Deadline moved up
However, the introduction of the amended Decree was delayed, with the result that its contents did not take effect until June 12. That means the transition period until July 1 would be very short indeed. For this reason, the Environmental Protection and Transport Inspectorate (Inspectie Leefomgeving & Transport) – within the framework of reasonableness and fairness – recently decided to implement the relaxed transposition procedure not until July 1, but until next October 1. After this date, converting is also possible, but must be paid for.
The requirements for obtaining E and D approval are in the Regulation on Approvals for the Transport of Dangerous Goods by Air.
What can Special Cargo do?
Have questions about the various accreditations or need help applying? Special Cargo College can provide support. And should you be looking for a party to ship dangerous goods by air: Special Cargo Services has E-recognition, awarded by the Ministry of Infrastructure and Waterways. This E-approval gives us the authority to act on behalf of your company as a sender and packer of dangerous goods. Thus, we can take over full legal liability from you. Expert, proactive and always safety-conscious.
