Guidance

Packaging of dangerous goods for carriage

Updated 6 April 2020

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This publication is available at https://www.gov.uk/government/publications/carriage-of-dangerous-goods-guidance-note-22/packaging-of-dangerous-goods-for-carriage

Introduction

All dangerous goods are classified according to internationally agreed standards, and each type of substance or article is assigned a specific United Nations (UN) identification number.

When dangerous goods are transported in the United Kingdom, all those involved in the carriage operation must comply with the Carriage of Dangerous Goods Regulations and Use of Transportable Pressure Equipment (as amended) (CDG2009). Northern Ireland has separate equivalent regulations. These regulations apply the provisions of RID and ADR to UK national transport.

One of the key elements to the regulations is that dangerous goods must be safely contained during transport.

One means of containment is ‘packaging’ which includes packages, large packaging and intermediate bulk containers (IBCs).

‘Packages’ include single packages such as boxes, bags, jerricans and drums made of fibreboard, plastics, metal or other materials.

More complex packages are ‘composite packagings’ made of more than one material. ‘Combination packaging’ consists of inner packagings placed inside an outer packaging.

In most cases all packaging types must be design type tested and certified as being suitable to contain particular types or single substances. With certain exceptions such packaging can be used in all modes of transport for both national and international carriage of dangerous goods.

More detailed information and guidance is available on the Vehicle Certification Agency’s (VCA) Dangerous Goods Packaging web page, including information regarding the requirements to be met to obtain design type approval for a dangerous goods packaging.

Dangerous goods – packaging and transport

There are 9 different classes of dangerous goods which are derived from the UN recommendations on the Transport of Dangerous Goods: Model Regulations.

They include explosive, flammable, toxic and corrosive substances and articles. For packaging purposes, most substances are assigned to packing groups based on the degree of danger they pose:

  • packing group I (which carries the code X in the certification mark) is for goods presenting high danger - one of the tests packagings must pass is a drop test from at least 1.8 meters
  • packing group II (code Y) is for medium danger and packagings must pass a drop test from at least 1.2 meters
  • packing group III (code Z) is for low danger and packagings must pass a drop test from at least 0.8 meters

What packaging to use

Most design types of packaging used to carry dangerous goods must be tested to demonstrate that they meet minimum UN performance standards set by the regulations.

The testing is carried out by independent test stations appointed by the VCA which ensure that it meets the required performance standards. The test stations report each successful test that they perform to the VCA’s Dangerous Goods Office (DGO) which then issues a unique approval mark for the package design type.

The mark may then be applied to every package of the same design to indicate that it complies with the supporting test report. The approval mark is valid indefinitely subject to payment of annual fees and validation of the latest produced packaging to the design type at a maximum of 5-year intervals.

The packaging must not only be approved in this way, but it must also only contain dangerous goods that have similar or the same physical characteristics as the test substances or articles for which it was successfully tested. The packaging materials must also be compatible with the contents. The filler/packer/consignor is responsible for ensuring this.

The supplier of the packaging must by law provide a copy of the test report, which should show what it has been tested with and clear written instructions about the use and limitations of the packaging. If they can’t do this or if the report does not explicitly show the characteristics of the test substance or inner packaging to be used - identified by size, type, manufacturer, type of material and quantity - such packaging should not be used.

The instructions will usually cover the type(s) of inner packaging that is/are permitted, the method of assembly, how it should be closed, and how to properly tighten the cap on a bottle or drum. If the supplier can’t provide this information or if the information does not explicitly show that the inner packaging has been approved in combination with the approved outer packaging - identified by the size, type, manufacturer, type of material and quantity - then such packaging should not be used. This does not apply to special packagings that are identified by having the letter V suffixed to the packaging code in the approved mark.

Where to get packaging for dangerous goods and the VCA approval database

The VCA’s DGO has issued over 7,000 UK packaging certificates, many of which are still valid. New UK packaging types are approved regularly, and existing ones can be withdrawn, suspended, or become invalid. This means that at any one time, there are about 2,000 valid certificated packaging types, but the specific list is constantly changing.

The VCA’s DGO maintains a database of all approved packaging so you can check the validity of any packaging. You can find a database of approved dangerous goods packaging on the VCA website.

The database shows:

  • the approval number
  • the full United Nations mark as allocated
  • the certificate holder’s name
  • a description of the package contents
  • a contact phone number (where packaging is offered for sale)

The database is presented in the form of Excel spreadsheets. Individual lists of different packaging types can be viewed or, alternatively, a listing of all approvals is available.

There are also many packaging types on sale which have been approved abroad to the same UN performance standards. These can be recognised from the approval mark, which will include a code similar to those used for cars, for example ‘GB’ for the UK, ‘F’ for France, and ‘D’ for Germany.

Examples and explanations of UN package markings can be found in chapters 6.1, 6.3, 6.5 and 6.6 of the UN Recommendations, ADR, RID, the IMDG code and part 6.2 of ICAO.

  • Recommendations on the Transport of Dangerous Goods: United Nations Model Regulations latest revised edition (UN Model Regulations)

  • European Agreement Concerning the International Carriage of Dangerous Goods by Road as amended. The Agreement is more commonly known as ‘ADR’ (from Accord Européen Relatif au Transport International des Marchandises Dangereuses par Route)

  • Annex I of the Convention Concerning International Carriage by Rail (COTIF, from Convention de l’Organisation Intergouvernmentale pour les Transports Internationaux Ferroviaires). Annex I is the Regulations Concerning the International Carriage of Dangerous Goods by Rail as amended. It is more commonly known as ‘RID’.

  • International Maritime Dangerous Goods Code (IMDG)

  • International Civil Aviation Organization (ICAO) Technical Instructions for the Safe Transport of Dangerous Goods by Air

  • The Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 (CDG 2009) as amended by

  • The Carriage of Dangerous Goods and Use of Transportable Pressure Equipment (Amendment) Regulations 2011

  • Carriage of Dangerous Goods: Approved Derogations and Transitional Provisions 2012

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