由 caicai8478 Part One: Overview of the Core Regulatory Framework
Since the UK’s formal departure from the EU, its chemical management regulatory system has undergone independent evolution. The core framework currently required for exports is:
UN Recommendations on the Transport of Dangerous Goods (Model Regulations): The cornerstone of global dangerous goods transport, specifying classification, packaging, labeling, and documentation requirements.
GB International Regulations: UK domestic regulations based on UN regulations, applicable to all modes of transport (air, sea, road, and rail). For sea freight, special attention must be paid to the IMDG Code (International Maritime Dangerous Goods Code), and for air freight, the IATA DGR (International Air Transport Dangerous Goods Code) must be followed.
UK REACH & CLP Regulations: The UK version of the Registration, Evaluation, Authorization, and Restriction of Chemicals Regulations (UK REACH) and the Classification, Labelling, and Packaging Regulations (UK CLP). This is the legal basis for the UKCA marking.
UK Packaging and Packaging Waste Regulations: Environmental requirements for packaging materials.
Part Two: Detailed Explanation of the UN Standard Packaging Certification Process
This is the core of compliance for dangerous chemical export packaging. Step 1: Correct Classification
Determine the product’s hazard category (e.g., flammable liquids, corrosive substances, acutely toxic substances, etc.) according to UK CLP regulations (largely consistent with EU GHS). This is a prerequisite for selecting the correct packaging group.
Step 2: Selecting UN-Certified Packaging
Packaging Types:
Combined Packaging: Consists of one or more inner packaging (e.g., glass bottles, plastic bags) and one outer packaging (e.g., corrugated boxes, plastic drums). The inner packaging directly contains the product, while the outer packaging provides protection.
Single Packaging: Consists of only one container, serving both containment and protection functions (e.g., steel drums, plastic cans, IBC containers).
Composite Packaging: Consists of an inner layer (e.g., plastic) and an outer layer (e.g., steel, cardboard), forming an inseparable whole (e.g., a steel drum with a plastic inner liner).
Packaging Code Interpretation: For example, 1A1/Y1.4/250/23/GB/XXXX
1A1: Packaging type code (1=steel, A=drum, 1=closed drum).
Y: Packaging Group (X = Group I, Very High Hazard; Y = Group II, Moderate Hazard; Z = Group III, Low Hazard).
1.4: Maximum Relative Density (Product density must not exceed 1.4).
250: Hydraulic Test Pressure (kPa).
23: Year of Manufacture (2023).
GB: Approval Country Code (United Kingdom).
XXXX: Manufacturer/Certification Body Code.
Performance Testing and Certification:
Packaging must pass performance tests conducted by UK-accredited bodies (such as some former EU Notified Bodies), including drop tests, stacking tests, leak-proof tests (inner packaging only), and hydraulic tests (liquids only).
Upon successful testing, the UN code can be permanently marked on the packaging.
Step 3: Packaging Use
The design and intended use of the packaging must be compatible with the chemicals contained (e.g., corrosion protection).
The maximum capacity and maximum net weight indicated on the packaging must not be exceeded.
Ensure that the sealing device (e.g., drum lid) is the correct type and tightened to the specified torque. Part Three: Specific Requirements for Leak-Proof Packaging
Leak prevention is the bottom line requirement for chemical packaging, especially in preventing environmental pollution and ensuring transportation safety.
Inner Packaging Leak Prevention:
All inner packaging (bottles, cans, bags) containing liquids must pass a leak-proof test or be placed in auxiliary inner packaging with sufficient absorption capacity (such as leak-proof bags, absorbent pads).
Seals must have a secondary seal, such as an inner plug + threaded cap, or heat seal + cap.
Outer Packaging Leak Prevention and Absorption:
The outer carton of combined packaging must use sufficient absorbent material (such as diatomaceous earth pads, polymer absorbent cotton) to absorb all liquids that may leak from the inner packaging.
The absorbent material must be chemically compatible with the contents and not react.
For single packages or IBCs, leak-proof trays or leak-proof dikes must be provided, with a capacity of at least 25% of the maximum packaging capacity (or 100% of the largest single package).
Pallet Reinforcement and Leak Prevention:
Goods should be securely loaded onto corrosion-resistant plastic pallets or properly treated wooden pallets (compliant with ISPM 15 International Phytosanitary Standard).
The entire pallet should be firmly secured with stretch film or strapping to prevent movement or tipping during transport.
It is recommended to use collapsible medium bulk container (FIBC) spill containment pallets as a second layer of protection on top of the pallet.
Part Four: UKCA Marking Explained (Mandatory from January 1, 2025)
From January 1, 2025, the UKCA mark will completely replace the CE mark as a mandatory market access requirement in Great Britain (England, Scotland, and Wales). Separate rules apply to the Northern Ireland market (usually UKNI+UKCA or CE).
When is the UKCA mark required?
When your chemical products are governed by relevant UK regulations and placed on the British market. This typically involves:
The packaging of the product itself (e.g., bottled chemicals sold directly to end users).
Packaging/containers (such as UN drums, IBCs) used for transporting dangerous goods, if they are sold as “products” in the UK market.
Safety Data Sheets (SDS) and labels must comply with UK REACH and UK CLP regulations.
UKCA Marking Style and Placement Rules:
Marking Style: Consists of the letters “UKCA,” and the proportions must strictly adhere to regulations.
Text: UKCA Minimum Size: The mark height must be at least 5mm (unless applicable regulations require a higher height).
Clarity and Permanence: Must be clearly visible, legible, and firmly and permanently affixed to the product or its label.
Placement: Usually located on the product itself or its data sheet. For transport packaging, the UKCA mark cannot replace or interfere with the UN markings and dangerous goods labels required for transport. Both must be present.
Technical Documentation: Manufacturers must prepare a UK Declaration of Conformity and technical documentation demonstrating that the product complies with relevant UK regulations.
Packaging Labels (Distinguished from Transport Labels):
Safety labels on product packaging must comply with UK CLP regulations (including pictograms, signal words, hazard statements, precautions, etc.).
Compared to transport labels (such as UN labels), CLP labels focus more on hazard communication, while transport labels focus on risk control during transport. Both types of labels may be present on a single package.
Part Five: Export Full-Process Checklist
Classification and Documentation:
Complete product hazard classification according to UK CLP.
Prepare a UK Safety Data Sheet that complies with UK REACH requirements.
Design product safety labels that comply with UK CLP.
Packaging Selection and Preparation:
Select the correct UN-certified packaging and packing group based on the classification and mode of transport.
Check that the UN markings are complete and legible, and that the packaging is in good condition.
Place sufficient and compatible absorbent material between the inner and outer packaging.
Ensure all seals are properly sealed.
Identification and Marking:
Correctly affix the UKCA mark (if applicable) to the product or its label. Affix transport dangerous goods labels conforming to GB/IMDG/IATA requirements (including the correct UN number, official transport name, hazard label, etc.) to the outer packaging.
Affix directional arrows (upward labels) to both sides of the packaging (for liquids).
If necessary, affix other handling labels (such as “Fragile,” “Protect from Sun”).
Loading and Documentation:
Secure the package securely to a spill-proof pallet.
Prepare transport documents: Dangerous Goods Transport Declaration (DGD), container/vehicle loading certificate, commercial invoice, etc.
Notify the carrier to ensure they are qualified to transport dangerous goods.
Disclaimer: This guide is a comprehensive overview and does not constitute legal advice. Chemical export regulations are complex and constantly updated. Before proceeding, consult with a professional compliance advisor, carrier, and official body (such as the UK Health and Safety Executive, HSE), and refer to the original regulations to ensure full compliance with the latest legal requirements.