Recently movement of bottled Scotch Whiskey from Hong Kong to other locations via ocean going vessels and feeder vessels are getting delayed due to shippers insisting Material Safety Data Sheet to accompany the consignments.
Let us look at the classification criteria of Dangerous Goods Transport regulations for Scotch Whiskey and analyze what is the basis of above requirement whether it is necessary or not.
In Dangerous Goods Regulations Alcoholic Beverages are listed under UN Number 3065 as below
- UN 3065, Packing Group II , ALCOHOLIC BEVERAGES with more than 70% alcohol by volume
- UN 3065, Packing Group III, ALCOHOLIC BEVERAGES, with more than 24% but not more than 70% alcohol by volume
Scotch Whiskey falls under second entry, Packing Group III, (more than 24% but not more than 70%)
Below are the entries in Dangerous Goods Regulations with special provisions for UN 3065 Packing group III
Above clearly states that, as per special provision 145, Scotch Whiskey, falling under UN 3065 Packing Group III, is not subject to provisions of IMDG Code if capacity per receptacle is less than 250 litres.
Hence, Scotch Whiskey packed in bottles further placed in cartons are not subject to any provisions of IMDG Code for sea transport.
Why shippers are insisting for MSDS?
Self believe this sudden requirement of MSDS asked by Hong Kong shippers are due to the same being asked by some of the shipping shipping lines. Somewhere in the booking desk or approval desk of certain shipping lines misunderstanding of the provisions of IMDG Code has demanded the MSDS for verification and this has sent a wrong message among shippers that all shipping lines need MSDS for transport of bottled Scotch Whiskey.
How to resolve this situation?
In case any shipping line ask for MSDS for shipment of bottled whiskey shipper can offer a non-hazardous declaration quoting special provision 145 of IMDG Code.
Training
Above misunderstanding reiterates the requirement of Training in IMDG Code.
WhatsApp your queries
Sigh ! carriers are treating wines (brandy, whisky etc) as DG though it is under PG III.
Eric, shippers should quote relevant sections of IMDG Code to carriers while placing the shipment requests.
Though alcoholic beverages of packing group III is not subject to IMDG code if packed in receptacles lesser than 250l
It can still be carried as hazardous if shipper wants. See column 7a of dangerous goods list 🙂
Thanks Shashi.
Hi Shashi,
I want to send whisky samples in 375 ml bottles from India to Africa by “Air” and the alcohol content is more than 24% and less than 70% v/v. This again is UN3065, Packaging Group III ?? Please help me in this regard. Your reply much appreciated. Thanks.
Gopi,
Sorry, I do not cover Air transport (IATA DGR). you need to check with the carrier ( airline) or your forwarder.
Rgds/Shashi
Thanks, Shaahi.
I’m having a huge headache now. Malaysian Shipping Agents considers this as DG Class III cargo and is insisting of MSDS. How can I avoid this ? My products is Fruit Wine – 14.5% Alcohol content and Vodka Coffee with 40% Alcohol content. Who should I contact that can help me get an MSDS for my products? I have tried Intertek and SGS but to no avail.
Elton, Are you exporting from Malaysia or Importing into Malaysia?
You may quote above article to your agents in Malaysia, additionally may ask them to contact Malaysian Competent Authority on any of the below addresses
Director
Marine Department, Peninsular Malaysia
P.O. Box 12
42009 Port Kelang
Selangor
MALAYSIA
Telex: MA 39748
Director
Marine Department, Sabah
P.O. Box 5
87007 Labuan
Sabah
MALAYSIA
Director
Marine Department, Sarawak
P.O. Box 530
93619 Kuching
Sarawak
MALAYSIA
—
Regards/Shashi
Hi Shashi,
I’m facing the same issue, but why contacting Malaysian Competent Authorities?
Benny,, I suggested t contact Malaysian Competent Authority so your Malaysian Shipping Agents can get convinced there is no need for MSDS. Have you found out from your agents which shipping line is insisting for this?
Regards/Shashi
Dear Shasi,
i Have an sea shipment inquiry to the destination Onne port. Pls note the commodity is Whisky ( Alcoholic Beverages ) kindly advice it can be move as NON HAZ or HAZ also i didn’t rcvd any MSDS from the customer. If HAZ want to know any s/line will accept this for transportation.
Awaiting your earliest reply.
Regards,
Johnson
Johnson,
What is the percentage of alcohol volume by volume
How it is packed, bottles in cartons? large quantity in drums ?
Regards/Shashi
amounts under 1 ltr is allowed anything over 1 ltr will cause you problems. If it is more then 1ltr you are wanting to send it must be separately packaged.
Hi Shaashi,
what’s the definition of “per receptacle”? is it referring to the inner packing like bottle or outer packing or total volume in a container ?
Per receptacle means per bottle of alcohol
Regards/Shashi
many thanks for your clarification, Shashi.
[…] due to carriers insisting Safety Data Sheet (SDS) to accompany the consignments. I had written an article during that […]
Hi Shashi,
we are planning to import wine and Brandy from France to India in LCL. Shipping agents are tell us that, without MSDS it can’t be shipped to India from France and also they are not even providing the quote.
Alcohol contain for wine is 14% and Brandy 42%.
Please let me know if you have any shipping agents details, who can help us to bring the product.
You may inform the shipping line that alcoholic beverages containing less than 24 % alcohol is not subject to IMDG Code further special provision 145 of IMDG Code exempt the brandy with 42% alcohol from the provisions of IMDG Code when packed in less than 250 litres per receptacles hence both the goods are not hazardous for transport.
I am not aware which shipping agent you are using.
Regards/Shashi
Dear Mr Shasi, We have a shipment of Whisky(42% alcohol) in 750 ml bottles to Sohar,evergreen line asking for msds ,how can i manage
Hello Vinoo,
Whiskey with 42 % alcohol by volume is packing group III. Special provision 145 says “Alcoholic beverages of packing group III, when transported in receptacles of 250 L or less, are not subject to the provisions of IMDG Code”. Your shipments are in 750ml bottles which can be considered as non hazardous.
Regards/Shashi
[…] due to carriers insisting Safety Data Sheet (SDS) to accompany the consignments. I had written an article during that […]
Hi Shasi. It appears that shippers are still not understanding what you have said since 2013 – i.e. that alcoholic beverages do not require a (M)SDS since they are packaging group III. I am attempting to transport gin at 37% ABV (in small 40ml receptacles) from South Africa (Cape Town) to New Zealand (Auckland) (via transhipment in Singapore). It appears that if I elect to ship on a groupage/LCL basis, then the NVOCCs want to charge me HUGE hazardous charges because they are saying that the Singapore port wants to handle the good as if they are classed as hazardous, which as you say they are not based on Special provision 145. Matt
Hi Matt,
This is a confusion going on since ages.
May be you send the explanation to NVOCC to understand the provisions of IMDG Code.
or
You may contact Singapore Port Authority (hazmat @ mpa.gov.sg) for clarification about policy at their terminal.
Let me know the outcome. I am curious.
Regards/Shashi