IMDG Code 38-16 – Update 1 – Classification

Good Day Readers,

We are all aware that 38th amendment of IMDG Code, published in 2016, will run recommendatory from 1st January 2017 before it becomes mandatory on 1st January 2018.  During 2017 shippers and carriers may opt the provisions of IMDG Code 38th amendment (38-16) or 37th Amendment (37-14).

We are publishing a series of article highlighting prominent changes and additions in 38th Amendment for better understanding. You may feel free to comment, suggest and ask questions.

The first in this series is changes to ‘Classification’.

A new section is added to chapter 2.0, classification. This section deals with the classification of substances listed by name in dangerous goods list, chapter 3.2, but differs the dangerous classification in columns 3 & 4, Classes or Divisions and Subsidiary Risk(s) respectively.

For example:

A substance is listed in IMDG Code by name and column 3 of DGL reads 5.1 and no subsidiary risk is allocated. If the laboratory test confirms this substance is having a subsidiary risk of class 8 then shipper can transport as below.

  • Under the most appropriate generic or not otherwise specified (N.O.S.) entry reflecting all hazards (Class 5.1 with subsidiary risk class 8)


  • Under the same UN number and name but with additional subsidiary risk(s) (class 8) (documentation, label, placard). Provided that the primary hazard class remains unchanged and that any other transport conditions (e.g. limited quantity, packaging and tank provisions) that would normally apply to substances possessing such a combination of hazards are the same as those applicable to the substance listed.

This must be done with approval of Competent Authority.

Duties of Competent Authority

When Competent Authority approves such classification, the Competent Authority must communicate this information to United Nations Sub-Committee of Experts on the Transport of Dangerous Goods and submit proposal to include this in the dangerous goods list of chapter 3.2 of the next amendment of IMDG Code.

What happens if the United Nations Sub-Committee of Experts on the Transport of Dangerous Goods reject this proposal?

If UN Sub-Committee rejects this proposal the competent authority should withdraw the approval and shipper must cease to transport unless reclassified according to the relevant provisions of IMDG Code.

There are additional changes to classification of goods of Class 1 explosives. Refer to IMDG Code 38th Amendment for full details.

Further readings

New Entries in IMDG Code 38-16

IMDG Code 38-16 – Changes to Tank Provisions


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