Does dry ice need a Shipper's Declaration?

Usually not. When dry ice (UN1845) is the only regulated material in the package, FedEx and UPS do not ask for a Shipper's Declaration for Dangerous Goods. USPS is the exception: it requires one for dry ice sent by air. What every air shipment does need is the right marking on the box and, depending on the carrier, an entry in the shipping record.

This guide covers shipments with FedEx, UPS, and USPS where dry ice is cooling something that is not itself a dangerous good.

The Short Answer by Carrier

Carrier and service	Shipper's Declaration?	What is required instead
FedEx Express (air)	No, when dry ice is the only dangerous good	Select "Dry Ice" in the shipment and enter the dry ice details; package markings and Class 9 label
FedEx Ground	No	Mark the package "Dry Ice" and tell the pickup driver
UPS domestic air, 2.5 kg or less	No	Package markings; no Hazardous Material Shipping Papers
UPS domestic air, more than 2.5 kg	Not listed by UPS	"UN1845" marking, dry ice weight in kg, acceptance audit
UPS Ground, contiguous U.S.	No	Processed like any UPS Ground shipment
USPS air	Yes, in triplicate	Declaration fixed to the outside of the mailpiece, plus markings and Class 9 label
USPS surface	No	"Surface Only" marking plus dry ice markings

What the Federal Rule Says

The U.S. hazardous materials rule for dry ice is 49 CFR 173.217. Paragraph (c) covers transport by aircraft and paragraph (d) covers diagnostic and treatment shipments. Together they give three paperwork outcomes:

Standard air shipments, paragraph (c)(1) to (c)(4). Dry ice is excepted from the shipping paper requirements if alternative written documentation is supplied with the description of the materials. It must give the proper shipping name (Dry ice or Carbon dioxide, solid), Class 9, UN number 1845, the number of packages, and the net quantity of dry ice in each package. The shipper must make arrangements with the aircraft operator for each shipment, and the net mass of dry ice must be marked on the outside of the package.
2.5 kg (5.5 lb) or less per package, paragraph (c)(5). Dry ice used to refrigerate the contents is excepted from all other requirements of the hazardous materials regulations, including those in the item above, provided the package lets carbon dioxide gas escape and is marked "Carbon dioxide, solid" or "Dry ice", with the name of the contents being cooled and either the net weight of the dry ice or a statement that it is 2.5 kg (5.5 lb) or less.
Diagnostic or treatment shipments, paragraph (d). Dry ice refrigerating materials shipped for diagnostic or treatment purposes, such as frozen medical specimens, is excepted from the shipping paper and certification requirements. The conditions are a package that lets the gas escape, arrangements with the aircraft operator, and a package marked "Carbon dioxide, solid" or "Dry ice" that shows the contents are being transported for diagnostic or treatment purposes.

Carriers can ask for more than the federal rule does. USPS is the clearest example.

FedEx

FedEx's dry ice page says: if dry ice is the only dangerous good in the package, a Shipper's Declaration is not required. Instead:

Select "Dry Ice" when you create the shipment online or on a FedEx airbill, and fill out the dry ice information.
On a paper airbill, mark "Yes, Shipper's Declaration not required" in the Special Handling section.
For international shipments, fill in the airbill line "UN 1845, Dry Ice, __ x __ kg" with the number of packages and the net quantity in kilograms.

The package still needs its markings ("Dry ice" or "Carbon dioxide, solid", "UN 1845", the weight of dry ice in kilograms, and the shipper's and recipient's names and addresses) and a Class 9 label. FedEx says dry ice is not regulated as a hazardous material with FedEx Ground, but the package must be marked "Dry Ice" and the pickup driver told. See the FedEx dry ice guide.

UPS

UPS's coolants and refrigerants page sorts U.S. domestic air packages into three groups:

Diagnostic or medical treatment packages prepared under 49 CFR: no Hazardous Material Shipping Papers, no Hazardous Material Agreement, and no acceptance audit. Mark the carton "Dry Ice for Medical Purposes" or "Dry Ice for Diagnostic Purposes" with the amount of dry ice.
Non-medical packages with 2.5 kg (5.5 lb) or less, prepared under 49 CFR: no shipping papers, agreement, or audit. Mark the carton "Dry Ice" or "Carbon Dioxide, Solid", describe the non-hazardous contents, and show the amount of dry ice or state that it is 2.5 kg or less.
Non-medical packages with more than 2.5 kg: UPS performs an acceptance audit. Mark the carton "Dry Ice" or "Carbon Dioxide, Solid" and "UN1845" with the amount of dry ice in kilograms. UPS lists the Class 9 label as optional under 49 CFR. UPS does not list a Shipper's Declaration for these packages; confirm the documentation for your account with UPS before tender.

For the first two groups UPS says no other paperwork is required. All three are processed through current UPS shipping software. UPS says dry ice is not regulated for ground transport, so UPS Ground shipments to and from the 48 contiguous states are processed like any other Ground shipment. International shipments may need a UPS International Special Commodities contract. See the UPS dry ice guide.

USPS

USPS asks for the form the other two carriers waive. Packaging Instruction 9A in Publication 52 says that for air transportation, a properly completed Shipper's Declaration for Dangerous Goods must be prepared in triplicate and affixed to the outside of the mailpiece. Air mailpieces are limited to 5 pounds of dry ice and need a Class 9 label and the marking "Carbon Dioxide Solid, UN1845" or "Dry Ice, UN1845".

For domestic surface mail, a Shipper's Declaration and a Class 9 label are not required. The mailpiece is marked "Surface Only" or "Surface Mail Only" with the same dry ice marking, and must not be routed by air. Dry ice is prohibited in international mail. See the USPS dry ice guide.

When a Declaration Is Needed After All

The carrier statements above apply when dry ice is the only regulated material in the package. They stop applying when:

The contents are dangerous goods too. FedEx waives the declaration only when dry ice is the only dangerous good. UPS says that when the contents are hazardous materials, its normal hazardous materials procedures for that commodity apply.
You mail dry ice by air with USPS. The triplicate declaration is required.

If either applies, contact the carrier before you ship.

Marking Still Matters

No declaration does not mean no marking. Each path above still puts the proper shipping name and the amount of dry ice on the package, and UN1845 where the carrier asks for it. The UN1845 Class 9 label requirements guide covers size, placement, and printing.

Generate the Markings and Airbill Text

Dry Ice Wizard checks a FedEx, UPS, or USPS dry ice shipment against these rules and generates the Class 9 label, the outer package marking with your net weight, the carrier's airbill or documentation text, and an acceptance checklist. It flags the USPS air declaration; it does not generate or replace the USPS declaration form.

Run the free dry ice check →

Sources

Important Notes

This guide is informational and not legal advice. Verify current requirements with the sources above and with your carrier before you ship.
International air shipments are prepared under the IATA Dangerous Goods Regulations, which are not freely published. This guide cites 49 CFR and the carriers' own pages instead.
Requirements may change. The rules referenced in this guide were last reviewed in October 2026.
If your dry ice is refrigerating other dangerous goods, additional regulations and a full Shipper's Declaration may apply. Consult a qualified dangerous goods specialist.

Last updated: October 2026 | dryicecompliance.com

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