Diesel (60°C): Shipping Classification Clarified

To Our Valued Clients and Partners,

This notice aims to provide crucial clarifications regarding the regulatory landscape for transporting diesel fuels from China, particularly in light of recent changes to its management as a hazardous chemical.

1. Key Regulatory Change in China (Effective Jan 1, 2023)

A significant regulatory update was issued by ten Chinese ministries, including the Ministry of Emergency Management (MEM), on November 7, 2022 (Announcement No. 8 of 2022). It stipulates that all diesel fuels, irrespective of their actual flash point, are now uniformly managed as Hazardous Chemicals in China. This update removes the previous flash point criterion (≤60°C) from the entry for "Diesel" (No. 1674) in the Catalog of Hazardous Chemicals (2015 Edition).

2. Distinction: "Hazardous Chemical" vs. "Dangerous Goods" for Transport

It is critical to understand that "Hazardous Chemical" (a regulatory term primarily for production, storage, and domestic handling within China) and "Dangerous Goods" (a transport classification for international carriage) are governed by different regulatory frameworks. The new Chinese rule mandates that all diesel is a hazardous chemical for domestic regulatory purposes. However, this does not automatically classify all diesel as dangerous goods for international air or sea transport. The classification for transport depends on the specific criteria of the relevant international transport regulations.

3. UN TDG Sub-Committee Clarification (Dec 2022)

Addressing widespread industry inquiries, a proposal (INF.35) was submitted to the 61st session of the United Nations Sub-Committee of Experts on the Transport of Dangerous Goods (UN TDG). The key clarification confirmed is:

Diesel with a flash point exceeding 60°C, provided it does not meet the criteria for any other hazard class, is not subject to the provisions of the UN Model Regulations.

This is a pivotal clarification for international shippers, as the UN Model Regulations form the basis for most modal transport codes.

4. Implications for International Air and Sea Transport

The UN clarification directly influences the major international transport codes:

Air Transport – IATA DGR (Dangerous Goods Regulations):

The current IATA DGR (64th Edition) includes Special Provision A3 for UN 1202 (GAS OIL or DIESEL FUEL or HEATING OIL, LIGHT). This provision aligns with the UN clarification. Therefore, diesel with a flash point 60°C, and not meeting other hazard criteria, is not restricted as dangerous goods for air transport.

Sea Transport – IMDG Code (International Maritime Dangerous Goods Code):

The current IMDG Code (40-20 Edition) aligns with the UN Model Regulations on this matter. Consequently, the UN TDG clarification applies: diesel with a flash point 60°C, and not meeting other hazard criteria, is not restricted as dangerous goods for sea transport under the IMDG Code.

5. Important Considerations for Road and Rail Transport within China

For multimodal shipments originating in China, note that domestic land transport rules differ:

Road Transport (JT/T 617): Classifies diesel with a flash point 60°C but ≤ 100°C as Class 3, UN 1202. Only diesel with a flash point 100°C (and no other hazards) is not restricted.
Rail Transport: International rail rules (OSJD) mirror the Chinese road rule (100°C threshold). For domestic Chinese rail, specific station consultation is advised.

Conclusion and Recommendations

For International Air/Sea Shipments: The recent clarifications confirm that high-flash-point diesel (60°C) may not be classified as dangerous goods for transport, provided it has no other hazards. This can potentially simplify documentation and reduce logistics costs for such shipments.
Compliance is Key: Shippers remain fully responsible for providing the accurate flash point and proper classification for their goods, supported by a Safety Data Sheet (SDS) and/or test report.
Carrier/Authority Discretion: Individual carriers or authorities may implement more stringent requirements. Always verify with your appointed carrier or forwarder prior to shipment.
Domestic China Leg: Remember that all diesel is now treated as a hazardous chemical within China, affecting its handling prior to and during the initial domestic transport leg to the port or airport.

Conclusion: We recommend consulting with your logistics provider to ensure your specific diesel shipments are correctly classified and documented for all segments of the supply chain. Please feel free to contact us for further assistance with your shipments from China.