Exemptions, limited quantities and special cases

Applying every requirement of the TDG Regulations to a single can of spray paint or a propane cylinder for a barbecue would bury small shippers in paperwork without making anyone safer. So Part 1 of the regulations contains special cases, usually called exemptions, that relieve small or low-risk shipments from some requirements when strict conditions are met. Exemptions are used every day by contractors, retailers, couriers, farmers and maintenance crews. They are also a common source of mistakes, because people remember the relief and forget the conditions. An exemption is never a blanket release: it lists exactly which parts no longer apply and which conditions must be met.

Excepted quantities

The smallest amounts of many dangerous goods can travel as excepted quantities. Column 6(b) of Schedule 1 gives a code, from E0 (not permitted) to E5, that sets the maximum amount per inner container (as little as 1 g or 1 mL for the most hazardous products) and per outer package. Excepted quantity packages need strong combination packaging, absorbent material for liquids and the excepted quantity mark, a square with red hatched edges showing the class number. Laboratory samples, small reagents and test kits often travel this way.

Limited quantities

Limited quantities are small inner containers, below the limit in column 6(a) of Schedule 1, packed in a strong outer package with a gross mass of not more than 30 kg. They cover a huge share of consumer and retail products: aerosols, paints, cleaners, adhesives, lighter fluid and fuel in small containers. Under section 1.17, limited quantities transported by road, rail or ship are relieved of most of the requirements of Parts 3 to 5: no shipping document is normally needed for road transport, no class labels or placards are required, and UN standardized packaging is not needed. In return, each package must be marked with the limited quantity mark, displayed on one side of the package, not on the top or bottom, as clarified in the 2026 amendments. When a vehicle carries more than a set total mass of limited quantity packages, the vehicle may need a limited quantity mark too.

The 150 kg exemption for consumer quantities

Section 1.15 helps people who buy and carry everyday products. It applies when dangerous goods are in a quantity or concentration available to the general public and are transported by a user or purchaser, or by a retailer to or from a user or purchaser. The total gross mass of dangerous goods must be 150 kg or less, each container other than a gas cylinder must be 30 kg or less, gas containers must meet the gas requirements in Part 5, and other containers must not release their contents under normal conditions. Under these conditions, Parts 3 to 6, 8 and 17 do not apply, so no document, no safety marks, no training certificate and no release reporting under Part 8 are required. Many goods are excluded, including goods that need an ERAP or temperature control, most explosives (apart from listed consumer fireworks and similar items), flammable gases in cylinders over 46 L, toxic gases, class 4 goods in packing group I, most organic peroxides, liquid 6.1 goods in packing group I, infectious substances and radioactive materials that need a licence.

The exemption suits a homeowner bringing propane cylinders home from a store, or a retailer delivering pool chemicals to a customer. It does not cover a business carrying its own working supplies, which must look to the 500 kg exemption or full compliance.

The 500 kg exemption

Section 1.16 is the exemption most often used by businesses carrying modest amounts of mixed dangerous goods, such as service vans and contractors' trucks. The total gross mass of all dangerous goods on the vehicle must be 500 kg or less, each container other than a class 2 container must be 30 kg or less, and liquids and solids must be in containers that do not leak under normal conditions, while gas containers must meet Part 5. Under these conditions, Part 4 (safety marks) and Part 5 (means of containment) do not apply, and Part 3 is reduced to a simple document: the shipping document need only show the class and the number of means of containment for each class, in the form Class 3, 4 means of containment. Packages may display WHMIS or pest control product labels in place of TDG labels. Part 6 still applies, so the driver and loaders must be trained and certified, and Part 8 reporting still applies. Excluded goods include most explosives, radioactive materials, infectious substances, toxic gases, some packing group I goods, large flammable gas cylinders, goods needing an ERAP and goods needing temperature control.

Because the 500 kg exemption removes the placard requirement entirely, it lets service vans carry useful amounts of fuel, gases and chemicals without placards, provided every condition is met. Transport Canada has indicated that the 500 kg total includes limited quantities and goods carried under other exemptions, so all dangerous goods on the vehicle count toward the limit.

# Does a service van qualify for the 150 kg or 500 kg exemption? (simplified; conditions abridged)
van = [  # (item, class, gross mass of container kg, number of containers, excluded group?)
    ("propane cylinder 20 lb", "2.1", 17, 2, False),
    ("acetylene cylinder", "2.1", 32, 1, False),
    ("gasoline jerrican 20 L", "3", 17, 2, False),
    ("aerosol case", "2.1", 8, 3, False),
    ("battery pack", "9", 4, 2, False),
]
total = sum(m * n for _, _, m, n, _ in van)
too_big = [i for i, c, m, n, _ in van if not c.startswith("2") and m > 30]
excluded = [i for i, _, _, _, x in van if x]
print(f"total gross mass of dangerous goods: {total} kg")
print("150 kg exemption:", "no - business use, not a consumer purchase" )
ok500 = total <= 500 and not too_big and not excluded
print("500 kg exemption:", "conditions met" if ok500 else "not met")
if ok500:
    classes = {}
    for _, c, _, n, _ in van:
        classes[c.split(".")[0]] = classes.get(c.split(".")[0], 0) + n
    for c, n in sorted(classes.items()):
        print(f"  document line: Class {c}, {n} means of containment")

total gross mass of dangerous goods: 132 kg
150 kg exemption: no - business use, not a consumer purchase
500 kg exemption: conditions met
  document line: Class 2, 6 means of containment
  document line: Class 3, 2 means of containment
  document line: Class 9, 2 means of containment

The van's 132 kg of dangerous goods qualifies for the 500 kg exemption, so it needs no placards or labels, only a simple document listing the classes and number of containers, plus trained and certified workers. It does not qualify for the 150 kg consumer exemption, which covers retail purchases, not a business's working supplies. Add a large cylinder of a toxic gas, or another 370 kg of goods, and the exemption would no longer apply.

Lithium batteries and other special cases

Lithium batteries have their own set of special provisions in Schedule 2, which set out when batteries packed with or contained in equipment are exempt from most requirements, how small cells and batteries must be protected against short circuits and damage, and when the lithium battery mark is needed. The 2026 amendments removed the requirement for a telephone number on the lithium battery mark and capped the state of charge of lithium-ion batteries carried as cargo on passenger aircraft at 30 % of rated capacity, in line with the ICAO Technical Instructions. Damaged, defective or recalled batteries are excluded from most exemptions and need special packaging.

Other special cases cover dangerous goods in a vehicle's own fuel tank or equipment, goods used by emergency services, residue in empty containers, samples for classification, and products moving within a single facility. Each has its own section and conditions, and the 2026 amendments reworded several of them for clarity. When an exemption does not fit, a permit for equivalent level of safety can be requested from Transport Canada for a specific operation.

Exemption mistakes in the field

Inspectors and incident investigators see the same exemption errors repeatedly. A contractor's truck claims an exemption but carries one container larger than the per-container limit. A van claims to be under the total limit, but nobody counted the aerosols and limited quantity products in the back. A shipper uses the limited quantity rules for a product whose list entry shows that limited quantities are not permitted. A battery shipment uses the small-battery exception for batteries that are above the watt-hour limit or have been damaged. Each of these turns an exempt shipment into a non-compliant one, often with no placards, documents or emergency information to warn responders.

The safest habit is to write down which exemption a regular load relies on and check it against a short list of conditions: total mass, per-container mass, excluded goods, packaging condition, marks and training. Many companies print the checklist on a card kept in each vehicle.