Customer Advisory Others

Implementation of IMDG regulation amendment No.35 by Japan Maritime Safety Agency

Dear Valued Customer,

The IMDG regulation amendment No.35 went into effect from 1 January 2011 on a voluntary basis until 1 January 2012 when it becomes mandatory. However, the Japan Maritime Safety Agency has chosen to make this amendment No.35 mandatory effective from 1 January 2011 with the following exceptions:

  1. UN 3166/3171 – UN 3166 is to be handled as hazardous class 9 and will need a dangerous goods declaration but no placard is required. However, UN 3166 can be handled as non-hazardous cargo if there is no sign of leakage from the fuel tank, fuel tank is empty or terminals of battery are insulated. UN 3171 is to be handled as hazardous cargo as well but there is transition period provided in “Other exceptions” below.
  2. Other exceptions - Japan’s Ministry of Land, Infrastructure, Transport and Tourism (MLIT) granted a transitional exception measure which allows only the following UN numbers to be carried as non-hazardous through 31 December 2011 in accordance with IMDG regulation amendment No.34. They are UN 3171 (battery powered vehicles or equipment) and UN 3496 (nickel metal hydride batteries).
  3. Limited Quantity – Limited quantity mark is a changed mark under IMDG regulation amendment No.35 but MLIT granted a transitional exception through 31 December 2011.

APL will accept cargo which is in compliance with either IMDG regulation amendment No.34 or No.35 during the voluntary compliance period but such cargo will also need to be in full compliance with all local government’s rules and regulations.

If you need more information, please contact your local APL representative.