Do I need to ship smaller quantities of UN 3082 or UN 3077 as dangerous goods?

Modified on Wed, 24 Aug 2022 at 04:54 PM

UN 3082 and UN 3077 are unique UN numbers, in that they are the only UN classifications for "environmentally hazardous substances", also known interchangeably in some regulations as "marine pollutants" where the environmental hazard is the only dangerous goods hazard attributable to the entry.

Environmentally hazardous substances are classified in ADR at and in the IMDG Code the procedures for classification are summarised at 2.10.2. 

Note that the way in which some entries are classified as marine pollutants in the IMDG Code differs from that of ADR, but the result is the same, in that if no other hazard is involved, the entry will be assigned to UN 3082 for liquids or UN 3077 for solids.

Dangerous goods have an inherent hazard or hazards and the controls we use in transport for these goods are purposely aimed to decrease the risk presented by that hazard. 

It has been deemed by the UN experts (representatives of countries and official industry bodies who decide on the regulations) that below 5 L for liquids (UN 3082) or 5 kg for solids (UN 3077) per inner packaging or per package, that the risk associated to the environment is decreased significantly enough to allow these goods to be transported without being marked, labelled or declared as dangerous goods.

Whilst there are some general packing rules (use of good quality packagings e.t.c.) which still apply, no other provisions of the dangerous goods rules apply to these entries at or below these quantities per inner packaging or per package, regardless of how many packages are in a shipment.

The goods should not be marked or labelled as dangerous goods for transport purposes, or declared as dangerous goods using a shipper's declaration, dangerous goods note (DGN) or dangerous goods transport document.

In ADR, for road transport in the UK, Europe, and other contracting territories, this exemption is enacted by special provision 375 which can be found in Chapter 3.3. 

In the IMDG Code, for international sea transport, this is enacted by text given at

In IATA, for international air transport, this provision can be found in special provision A197, behind the blue pages in Section 4.

In 49CFR, for domestic transport in the United States, environmentally hazardous substances classified under the UN Model rules are not regulated as dangerous goods anyway (so they don't need to be exempted).

If you plan to take advantage of these provisions, please understand the importance of not declaring the goods as dangerous goods. This is because these rules are deemed "optional", e.g. you can declare, pack, mark and label these goods as dangerous goods if you wish, including to the limited quantities provisions.

Therefore what you don't want to do, is unintentionally declare goods as dangerous goods which are not fully prepared to the relevant provisions, as this will attract penalties.

For marking, labelling and declaration purposes, they should be treated as if they are not dangerous goods. Note that safety data sheets (SDSs) will still give dangerous goods information in Section 14, because it is up to the shipper to determine the quantity and therefore whether the exemption can be used. We recommend that a note is added to Section 14 of an SDS to provide further information about these exemptions if they are to be relied upon for the product concerned.

It is acceptable for the goods to be labelled with consumer labels identifying the environmental hazard, but if using the above provisions, should not be marked or labelled or declared as dangerous goods. This is also detailed in IATA at the note below 2.2.2.

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