Will the Update to UN1169 for Flammable Liquids affect you?
Changes to UN1169 dangerous goods classification are expected to be rolled out in January 2023. If your business distributes and sells our fragrances and compounds in their original form, this change may affect the products you sell.
Is Fragrance a Dangerous Good?
All perfume, cologne, eau de parfum and eau de toilette which contain alcohol are considered a ‘dangerous good’. As a result, they are subject to strict rules regarding distribution and delivery.
So first of all, what is UN1169?
UN1169 is the UN classification for dangerous goods. Some of the products we make at Carvansons are flammable and fall under this classification. UN1169 currently applies Extracts, Aromatic, Liquids.
Some of our products will be impacted by the forthcoming regulatory updates to transport directives (2023 editions of ADR and IATA, 41st edition of IMDG).
If a product has a flashpoint of under 60 degrees, it is likely to be affected. If you are unsure about the flashpoint for a fragrance, please check the MSD’s for the Classification, Labelling and Packaging (CLP) regulation associated with a fragrance. CLP Regulation ensures that the hazards presented by chemicals are clearly communicated.
Will UN1169 Classification changes affect your business?
If your business distributes and sells our fragrances and compounds in their original form, there is a change coming that may affect the products you sell. Please note, if you are using our fragrances to create a final product, this regulation will not affect you.
How will UN1169 Classification be changing for January 2023?
This change will see the current UN1169 classification of Extracts, Aromatic, Liquid being deleted.
They will then consolidate all materials that fall under the description of “Extracts, Liquid, flavour or aroma” under the updated classification of UN1197.
There appear not to be any further changes to the description, class, packing group, packing instructions, quantity limitations or special provisions at this time.
Current classifications up until 31st December 2022:
UN1169 – Extracts, Aromatic, Liquid
UN1197 – Extracts, Flavouring, Liquid
Change as of 1st January 2023
UN1169 – will be deleted
UN1197 – Extract, Liquid for flavour or aroma
How will UN1197 affect you?
This change applies to anyone distributing anything flammable previously with UN number UN1169. This change will come into force on the 1st January 2023 and as result being prepared for this changeover is important. The above change is effective from 1st January 2023 and no sooner; under IATA regulations (for Air transportation) no grace period exists, therefore the change must be actioned by 1st working day of January 2023. There is, however, a 6-month grace period for ADR and IMDG codes (road and sea transportation).
It is recommended that all our customers who receive or handle Class 3 flammable fragrances and currently use UN1169, are aware and prepare for the change to UN1197. This includes the shipping name change for UN1197 to incorporate fragrances as well as flavours.
We also recommended that the timing of these changes is aligned with changes to marks, labelling, MSDS/SDS and also dangerous goods notes. Any inconsistencies will cause issues when attempting to ship an affected product.
What are Carvansons doing?
At Carvansons Ltd we have already begun the work required to adapt to this change from the 1st working day of January 2023 but delays to air shipments and production of SDS’s could be a possibility. This will also mean a change to our MSDS’s, product labels and CLP product labels.
Concerned about how it will affect your product or shipment?
Firstly, we would advise you to check your CLP documentation provided when you purchased your fragrances. We are able to provide this information should you require it. Furthermore, we would suggest you review your dangerous goods procedures and policies.
Finally, there is plenty of information available on this on this webpage. or alternatively contact us for more information.