What is happening?
In Revision 22 of the Model Regulations on the Transport of Dangerous Goods (published 2021) the entries in the dangerous goods list for UN 1169, EXTRACTS, AROMATIC, LIQUID were deleted.
Following on from this change in the Model Regulations, the five entries for UN 1169 are set to be deleted from the dangerous goods list of ADR 2023.
This change will be mirrored in the 64th Edition of IATA with the entry in the IATA dangerous goods list for UN 1169 (PGII & PGIII) also being deleted.
Although not confirmed this change will almost certainly appear in the next edition of the IMDG Code.
In addition to the changes above the Proper Shipping Name of UN 1197 will be changing from “EXTRACTS, FLAVOURING, LIQUID” to ‘EXTRACTS, LIQUID for flavouring or aroma”
Who will this affect?
Any organisations who stock or consign substances assigned to UN 1169 will be affected by this change, no matter which mode of transport they use for their consignments.
Commonly transport substances assigned to UN 1169 include essential and fragrance oils. Essential oils are commonly used in the practice of aromatherapy and fragrance oils are used in the manufacture of household products such as scented candles and bathroom products.
UN 1197 is commonly assigned for extracts used for flavouring foods and beverages amongst other uses.
What action needs to be taken?
Substances formerly classified as UN 1169 will now be classified as UN 1197. This will require the revision of the Safety Data Sheets for these products. Transport documents, the marking of packages (and tanks/containers where relevant) will be required to display the required information of UN 1197. Look out for any older stock that might be in the warehouse.
This action will need to be taken within the transition periods of the different regulations. The transition periods vary but in multi-modal travel goods moving by road may be carried in accordance with ADR 1.1.4.2.1.
Transition periods
| ADR | Dangerous goods may be carried in accordance with ADR 2021 until 30th June 2023 |
| IMDG | IMDG 41-22 may be applied voluntarily from 1st January 2023. After 1st January 2024 the application of IMDG 41-22 is mandatory. |
| IATA | The 64th edition of IATA become effective on 1st January 2023, the 63rd edition may not be used after this time unless indicated otherwise in the Regulations. |
| RID | Dangerous goods may be carried in accordance with RID 2021 until 30th June 2023 |
| ADN | Dangerous goods may be carried in accordance with ADN 2021 until 30th June 2023 |
*Transitional derogations may be added to the regulations to extend the terms of certain aspects of previous editions but there has been no indication at the time of writing this article that there will be an extension for the use of UN 1169 for road transport.
Why is this change happening?
In the editions of the regulations printed in English it is relatively easy to differentiate between the two UN numbers by proper shipping name, if an extract is used for its aroma it is UN 1169, if it is used to add flavour it is UN 1197.
The issue arises in editions of the regulations printed in other languages. This can be seen by looking at the regulations as printed in French and Spanish.
| UN Number | French Entry | Spanish Entry |
| 1169 | EXTRAITS AROMATIQUES LIQUIDES | EXTRACTOS AROMÁTICOS LÍQUIDOS |
| 1197 | EXTRAITS LIQUIDES POUR AROMATISER | EXTRACTOS LÍQUIDOS PARA AROMATIZAR |
There is no reasonable way to differentiate between which UN number should be assigned when looking at the regulations printed in these languages.
This is further complicated if you seek clarity by looking at the definition given in the ICAO Technical Instructions for the Safe Transport of Dangerous Goods by Air (excerpt below):
EXTRACTS, AROMATIC OR EXTRACTS, FLAVOURING. Substances used for fragrances or for flavouring foods or beverages.
This had led to industries in several countries using both UN numbers indistinctly (and sometimes interchangeably).
The provisions for transporting both UN numbers are identical, so the deletion of UN 1169 seems the logical step to ensure classification compliance.
You can read more about the reasoning for these changes here:
https://unece.org/fileadmin/DAM/trans/doc/2020/dgac10c3/ST-SG-AC10-C3-2020-38e.docx
Changes like these are why it is important that organisations ensure they have access to the most up to date copies of the regulations and that dangerous goods awareness training for personnel is completed and refreshed regularly, taking into account updates in the regulations.
Organisations with competently trained personnel working to the provisions of the newest editions of the regulations experience less shipment stoppages, fewer fines and fewer delays in shipments.
At EcoStar we have a whole range of online training available to help, you can check our courses out at: https://www.ecostarshop.com and for consultancy advice, we’re always happy to help: https://www.ecostarenvironmental.co.uk/dgsa
Written on behalf of The EcoStar Dangerous Goods Team by Callum Wyse, August 2022.
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