Chemical regulations are constantly evolving, which can often be difficult to keep up with for businesses that rely on chemical substances. The United Nations frequently updates its model regulations in line with changing understandings and uses of chemicals. In 2021, the most recent changes were made to Dangerous Goods, with specific changes made to flammable liquid UN 1169.
This article will outline what is changing, why this change is occurring, who it will affect, and what actions need to be taken by distributors to remain compliant.
Prior to the 22nd Revision of the Model Regulations on the Transport of Dangerous Goods, liquid extracts for aroma and for flavouring were classified separately. UN 1169 was used for aromatic products and UN 1197 was used for flavouring. This has caused problems in classification and consignment in languages other than English.
To rectify this, the 22nd Revision (published 2021) has deleted UN 1169, EXTRACTS, AROMATIC, LIQUID and related entries. Instead, all liquid extracts will be classified under UN 1197, whether they are aromatic or flavouring, under the new Proper Shipping Name of ‘EXTRACTS, LIQUID for flavouring or aroma’.
In addition to the UN Model Regulations, these changes have been reflected in the ADR 2023 dangerous goods list, ADG 7.8 update, the 64th Edition of IATA, and IMDG 41-22.
This change is taking place due to language issues which have prevented products from being accurately labelled. While the difference between UN 1169 and 1197 are fairly obvious in the English proper shipping name, it is less so in languages such as French or Spanish. This has led to industries in several countries using both UN numbers indistinctly or interchangeably.
Proper Shipping Names by Language
| UN Number | UN 1169 | UN 1197 |
| English | EXTRACTS, AROMATIC, LIQUID | EXTRACTS, FLAVOURING, LIQUID |
| French | EXTRAITS AROMATIQUES LIQUIDES | EXTRAITS LIQUIDES POUR AROMATISER |
| Spanish | EXTRACTOS AROMÁTICOS LÍQUIDOS | EXTRACTOS LÍQUIDOS PARA AROMATIZAR |
The model regulations need to be unambiguous in as many languages as possible, so to avoid further confusion, the Sub-Committee of Experts on the Transport of Dangerous Goods elected to delete UN 1169 and consign all liquid extracts under the one classification—UN 1197. Consignment procedures for both classifications were already identical, so changes that need to be made are in name alone.
This decision will affect any organisation which stocks, consigns, or is responsible for the transportation of substances which have been assigned to UN 1169 or UN 1197.
Substances previously classified under UN 1169 include essential and fragrance oils, which are used in aromatherapy products, scented candles, bathroom and household cleaners. UN 1197, on the other hand, has often been reserved for food and beverage flavourings.
Substances formerly classified as UN 1169 will now be classified as UN 1197, and all documentation will need to be revised accordingly to display the new information. This will require an update of SDS for these products, as well as transport documents, marking, and labels of packages, tanks, containers, and vessels.
Consignors of substances classified as UN 1197 will also need to update their documentation to include the new proper shipping name, EXTRACTS, LIQUID for flavouring or aroma.
The transition periods vary depending on the mode of transport. See the table below for more information.
| Regulation | Transition Period |
| ADG | ADG 7.8 may be applied voluntarily for existing records only from 1st April 2023. After 1st April 2024 the application of ADG 7.8 is mandatory for all products. |
| 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 became 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. |
In anticipation of this change, Chemwatch has already begun implementing updates on Chemwatch Authored SDS, as well as incorporating the new classifications into our labels. This includes automatically updated templates and chemical information to comply with the requirements of the jurisdiction and mode of transportation. Chemwatch Gold and Pure SDS have already been updated, and changes to all Chemwatch Authored Vendor SDS are expected to be finalised by 12 April 2023.
To check whether your SDS are compliant, or for any questions regarding regulatory changes, SDS authoring, chemical risk assessment, or labelling for transport, talk to the Chemwatch team today! We’re informed by over 30 years of chemical expertise and well equipped to help you with hazard identification and chemical compliance. Speak to your customer service representative or contact re*********@ch*******.net.
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