Autoritatea Aeronautică Civilă Romană

Exemptions for the transport of dangerous goods normally forbidden by air


National and European legislation directly applicable to air transport of dangerous goods (see legislation) implements the application of ICAO Technical Instructions Doc 9284 "Technical Instructions for the Safe Transport of Dangerous Goods by Air", which provide that certain types of dangerous goods may not be transported on board an aircraft.

ICAO Doc 9284 provides in Part 1; 1.1.3 that dangerous goods, which may not be permitted under normal circumstances for air transport or in conditions which are different to those prescribed in the Technical Instructions, are enable to transport by air operators only in condition that exceptions are obtained from the States concerned.

Such derogations may be granted only in cases where:

provided that in such cases every effort is made to achieve an overall level of transport safety, which is at least equivalent to the level of safety set out in the Technical Instructions.


In accordance with the provisions of Government Decision no. 859/2021, regardless of the nationality of the air operator, flights with civil aircraft carrying dangerous goods classified according to ICAO document Doc 9284 in the category of goods normally prohibited for air transport may be executed only on condition that the air operator requests and obtains this derogation, granted by the Ministry of Transport and Infrastructure, through the Romanian Civil Aviation Authority.

In addition, in order to grant a derogation for the transport of dangerous goods classified as "dangerous materials and any other type of cargo that, by their nature, may affect the national security of Romania" (see term definition), is required to obtain the prior opinion of the Ministry of National Defense.


Details of requesting an exemption:

The request of an air operator to obtain a waiver for the transport of dangerous goods normally prohibited in air transport shall materialize by submitting an application in a pre-established format and binding documents.

All applications must include:

    • pre-established application form, completed accordingly;
    • documents listed in Annex II to the form; and
    • mandatory documents according to the Romanian national legislation (CNCAN Authorization), where necessary.

      Note 1: Documents must be written / translated into Romanian or English.

      Note 2: An application form must be submitted to the AACR for each flight.

Attention !

Any application whose form is not fully completed and for which all documents requested are not provided, will not be processed.


The completed application and the required documents represent the "Complete file" for the derogation

”The complete file” for obtaining the exemption must be sent to the AACR at least 10 working days before the flight start date, to the e-mail address:

Note: for flights flying over the territory of Romania, only in situations of extreme urgency duly justified by the operator, requests for derogation may be submitted at least 5 working days before the start of the flight.


Application form

Given the involvement of many states in the process of obtaining exemptions for the transport of forbidden dangerous goods, as well as the need to present exemptions obtained from all states involved to interested parties, the application form and granting of the exemption is made only in English.

In order to maintain the information provided by the air carrier, without further intervention by AACR on this information, the request and the granting of the exemption will be made on the same form.

The Application Form is structured in 3 indivisible sections:

    • The actual application;
    • Annex I - Description of general measures aimed at achieving a global level of transport safety that is at least equivalent to the level of safety set out in the ICAO Technical Instructions, including the additional measures required by the AACR; and
    • Annex II - Documents required to be submitted to the AACR together with the application, applicable to all EASA member countries which have adopted the same procedure for issuing exemptions (Belgium, Croatia, Estonia, France, Germany, Luxembourg, Sweden, and Switzerland).


Annex II does not contain the mandatory documents according to Romanian national legislation.


Documents required to be submitted to AACR together with the application

  • Documents applicable to all EASA member countries

See the documents listed in Appendix II to the "Application Form", or see the list.

In accordance with the provisions of Government Decision no. 859/2021, for radioactive materials (class 7) it is necessary to obtain a prior authorization from the National Commission for the Control of Nuclear Activities (CNCAN). This authorization must be attached to the application to AACR!

NOTE: The authorization granted by CNCAN also means the letter by which CNCAN informs the applicant that for the radioactive materials in question, it is not necessary to issue an authorization.


How to complete the application:

Given that the Application Form is in "editable pdf" format, it will be completed and signed only in electronic format.

The application form will be completed in all fields, except the areas marked vertically on the right side of the pages, with the words "Official use only".

The application is signed in electronic format:

    • uploading a "pdf" file containing the scanned handwritten signature; and / or
    • digital signature.


Application management :

An application form must be submitted to the Ro CAA for each flight.

AACR assesses the application.

When the results of the assessment of the application and the related documents are considered satisfactory, the AACR shall complete and sign the form in its respective parts, the form becoming a letter granting an exemption for transport of forbidden dangerous goods. The final document will be sent to the applicant by e-mail.

Otherwise, AACR will send you a letter rejecting the application.


Amendment of the conditions set in exemption granted by Ro CAA

Any change in the conditions that led to the issuance of the exemption shall be re-evaluated for the purpose of issuing the exemption, unless the change relates to the date and number of the flight (provided that the flight remains scheduled during the period of validity of the original exemption). In order to avoid or reduce such situations, the applicant is advised to complete the form to cover different alternatives (for example: flight number if the alternative route is planned).


Last update: 05/05/2022, 08:19:39