As soon as dry ice enters the picture, the world of a pharma shipment changes in an instant. What used to be a simple courier job becomes a dual dangerous goods shipment.
On one side the refrigerated biological material (often UN3373 – Biological Substance, Category B) and on the other the refrigerant itself (UN1845 – Carbon dioxide, solid). Anyone who does not master both sets of rules simultaneously risks freight rejection, fines and – in the worst case – a lost patient sample shipment.
Patient samples, diagnostic specimens, clinical trial materials. Packing instruction P650 under ADR.
Class 9 – largely exempt on the road under ADR (only section 5.5.3), but full dangerous goods in air freight. Always: ventilation + marking.
Misconception 1: "Dry ice is just a refrigerant, right?"
Half true – and this is exactly where it gets tricky. Dry ice (UN1845) is in principle listed as Class 9 dangerous goods because it sublimates to CO₂ and can displace oxygen in enclosed spaces. How strict the obligations are, however, depends heavily on the mode of transport – this is what is most often confused.
By road (ADR): largely exempt
Under Special Provision 593, dry ice is "not subject to the provisions of ADR – except for section 5.5.3". This applies both as a refrigerant for the goods and to dry ice as its own shipment – a genuine peculiarity, since other refrigerants (e.g. liquid nitrogen) are full dangerous goods when shipped on their own. In concrete terms: no classic dangerous goods transport document and no ADR certificate for the dry ice alone – but section 5.5.3 is mandatory: "UN1845" marking, asphyxiation warning label and ventilation.
In air freight (IATA-DGR): full dangerous goods
The opposite is true in the air: here, dry ice – even as a pure refrigerant – is declarable Class 9 dangerous goods. Packing Instruction 954, the quantity in kg on the Air Waybill and carrier-specific quantity limits are mandatory.
Road: dry ice is usually ADR-exempt (only section 5.5.3). Air: dry ice is always full dangerous goods. Anyone who confuses the two over-declares by road – and under-declares in the air.
Ventilation is mandatory in any case
Regardless of the mode of transport: completely airtight boxes are not permitted. Qualified dry ice boxes have defined, documented ventilation openings – otherwise CO₂ pressure builds up.
Misconception 2: "UN3373 isn't really dangerous goods"
UN3373 is a special regulation: not a full dangerous goods classification, but strict packaging requirements under P650 ADR. In concrete terms, this means:
Anyone shipping UN3373 + UN1845 in combination (typical for frozen samples, mRNA materials, clinical trial samples) must comply with both sets of rules simultaneously. This is exactly where many standard courier services fail. The shipment is held up at the airport – and after 24 hours of waiting, the sample is often no longer usable.
Misconception 3: "We'll just take more dry ice, that'll hold it"
More dry ice is not automatically better. Three effects make things more complicated:
More sublimation = more CO₂ pressure
With insufficient ventilation, the packaging can burst open – a genuine safety incident in the cargo hold. In a lorry cab, CO₂ can leak in quantities that endanger the driver.
Upper quantity limits in air freight
Typically: 200 kg of dry ice per package, plus carrier-specific limits (Lufthansa Cargo, FedEx, DHL all differ). Exceeding them leads to immediate freight rejection.
More weight = higher freight cost
Pharma shipments are usually billed by volumetric weight. Twice as much dry ice doesn't just mean twice the risk – it often also means 30 – 60 % higher freight costs.
1.5 – 2 kg of dry ice per 10 litres of box volume per 24 h
Applies to a qualified va-Q-tec box with vacuum-insulated walls. For standard insulated boxes, plan on twice as much – plus a significantly higher risk of failure.
Checklist: what pharma manufacturers should demand from their carrier
These seven points are the most common audit findings with pharma suppliers – and at the same time the simplest filter question when selecting a pharma carrier:
When you should not ship yourself
Sometimes the honest answer is: don't do it yourself. If even one of the following applies, dry ice pharma shipping is not the right learning curve:
- No SOPs for handling at goods receipt.
- No appointed dangerous goods officer.
- Standard carrier without a documented pharma sector track record.
- No existing insurance policy with explicit UN3373/UN1845 cover.
Specialised pharma carriers cost more per shipment – but they know the pitfalls, have the training and the insurance. With the first incident prevented, the premium is paid back.
The question to every carrier should be: 'Are you simultaneously GDP-, UN3373- and UN1845-capable?' If they hesitate, they shouldn't be your logistics partner.
Conclusion
Dry ice shipping with UN3373 material is not black magic – but it has clear rules of the game. Pharma manufacturers, CROs and biotechs working with deep-frozen pharma, clinical samples or mRNA materials need a carrier who masters all three sets of rules simultaneously: GDP, UN3373, UN1845.
Anything else is a gamble with the shipment – and with patient samples, gambling is not an option.
Dry ice pharma transport with dual dangerous goods expertise
TempSecure runs pharma shipments with dry ice (−80 °C) GDP-compliantly and with full dangerous goods cover for UN3373 + UN1845. Including replenishment service and live monitoring.
Topics
