Consignor vs Carrier: Who Does What Under TDG?

Two words decide who pays the fine when a dangerous goods shipment goes wrong. Here is where the consignor's job ends, where the carrier's begins, and the handoff moment where most violations begin.

The legal definitions

Start with who is who, because both words mean more than people assume. The consignor is not just "whoever sells the product":

And the carrier is defined by one thing, possession during the trip:

Read those twice, and two surprises fall out. First, importing makes you the consignor even if you never touch the goods. Second, possession makes you the carrier even if the truck is not yours. The law follows the goods, not the business cards.

The duty matrix

Ten rows, and only one shared. That last row is the exception that proves the design: the paperwork trail is the one duty the law refuses to let either side drop.

The consignor's duties in plain terms

Everything the consignor owes happens before the wheels move. Classify the goods against Schedule 1 and keep written proof for five years. Prepare the shipping document with every required line. Put the right labels and UN numbers on every small container before the carrier takes possession. Arrange the ERAP when the goods demand one. In short, the consignor builds the truth, on paper and on the boxes.

Get one of those wrong and every mistake that follows downstream traces back. A wrong classification poisons the document, the marks, and the placards all at once, which is why the consignor's training burden is the heaviest in the chain.

The carrier's duties in plain terms

Everything the carrier owes happens while the goods move. Keep the shipping document within the driver's reach, or in the door pocket when the cab is empty. Placard the large means of containment and keep every mark displayed for the entire trip, replacing anything that falls off, immediately. If goods release or an incident occurs, the carrier reports it. In short, the carrier protects the truth the consignor built, from dock to dock.

The full marking rules, sizes, and the four-sides placard rule live in our guide to TDG placards and labels.

The handoff moment

Every TDG shipment has one legal hinge: the moment the carrier takes possession. Before it, the consignor's duties must be complete, classification done, document prepared and handed over, small containers marked. After it, the carrier's duties are live, documents in reach, marks maintained, incidents reported.

That is why inspectors love the loading dock. It is the one place where both sets of duties are visible at the same time, and where a missing label answers the question of fault before anyone says a word. Marks on small containers before possession belong to the consignor, while marks maintained after possession belong to the carrier.

"The dispute I hear at every roadside stop is the same sentence: 'the shipper loaded it, not me.' It never works. Possession made them the carrier, and the carrier owns the marks staying up and the papers staying reachable. The law does not care whose forklift did the loading."

Samira AliCertified Public Health Inspector, 10+ years across Canada and the U.S.

Who answers when both touched the mistake?

The classic scenario: the shipper applies the wrong labels, and the trucker drives off with them. Who answers for it? Both can. The consignor answers for applying marks that do not match the classification. The carrier answers for transporting a load whose marks it was responsible for maintaining. TDG duties are personal to each role, and one violation on the road frequently becomes two, one per party.

The defence on each side is the same: do your own role's checks. Consignors verify marks against the document before release. Carriers walk the load and compare marks to the shipping document before pulling out. Thirty seconds at the dock beats a two-way violation on the highway.

Importers and brokers

Importing dangerous goods into Canada makes you the consignor by definition, paragraph (b), even when a foreign supplier packed and labelled everything. The import itself is the trigger, which surprises many small businesses bringing in their first regulated product.

Freight brokers who never take possession sit outside both definitions: no possession means not a carrier, and not being named, importing, or possessing means not a consignor. The moment a broker's operation takes possession of the goods, the analysis changes. The function decides, not the job title.

The short version

1. Consignor: named on the document, the importer, or whoever possesses the goods immediately before transport.
2. Carrier: whoever possesses the goods while they move.
3. The consignor builds the truth: classification, shipping document, marks on small containers, ERAP, proof kept 5 years.
4. The carrier protects it: documents in reach, placards up and maintained, releases reported.
5. The handoff is possession. Before it, consignor duties. After it, carrier duties.
6. Shared mistakes can result in fines for both parties, and both keep the shipping document for 2 years.

This article is general information, not legal advice. Duties depend on the specific shipment, the parties involved, and the mode of transport. Always verify against the current Transportation of Dangerous Goods Act, 1992 and Regulations.