Exemptions in Special Provisions for Road Transport of Dangerous Goods

According to Article 10 of the Measures for the Safety Administration of Road Transport of Dangerous Goods, the consignor shall make sure the class and division, product name and identification number of the dangerous goods per the Regulations concerning Road Transportation of Dangerous Goods (JT/T 617) and abide by relevant special provisions.

Special provisions (presented in numbers) have been allocated in Column 6 of the Dangerous Goods List in JT/T 617.3-2018, including special testing requirements, special exemption requirements, etc. The meaning and requirements of the special provisions are set forth in Appendix B of the JT/T617.3-2018 in sequence. Dangerous goods which meet the special exemption provisions are not subject to the requirements of JT/T 617.1-2018 ~JT/T617.7-2018 and can be transported as general goods.

Exemptions in the special provisions are mainly divided into below five situations:

 (1) The ingredient or the concentration of dangerous goods meets special provisions, such as 38, 39, 45, 47, 59, 62, 66, 138, 142, 144, 169, 177, 208, 215, 226, 249, 252, 271, 305, 332, 533, 543, 587, 590, 591, 597, etc.

Example 1:

 Special provision SP 533: UN No.1198 Formaldehyde solutions, flammable are substances of Class 3. Formaldehyde solutions, non-flammable, with less than 25% formaldehyde are not subject to the requirements of JT/T 617.1-2018~JT/T617.7-2018

(2) The form/shape of dangerous goods meets special provisions, such as 32, 242, 546, 586, 588, 600, etc.

Example 2:

Special provision SP 242: Sulphur is not subject to the requirements of JT/T 617.1-2018~JT/T617.7-2018 when it has been formed to a specific shape (e.g., pills, granules, pellets, pastilles or flakes)      

With the pictures above, you can understand the exemption situation more clearly.

(3) Package requirements or carriage amount meets special provisions, such as 119, 145, 190, 191, 286, 291, 319, 366, etc.

Example 3:

Special provision SP 190: Aerosol dispensers shall be provided with protection against inadvertent discharge. Aerosols with a capacity not exceeding 50 ml containing only non-toxic constituents are not subject to the requirements of JT/T 617.1-2018~JT/T617.7-2018.

(4) Articles meet special provisions, such as 188, 238, 251, 289, 594, etc.

Example 4:

Special provision SP 289: Airbags or seat belts installed in vehicles or in-vehicle components such as steering columns, door panels, seats, etc., are not subject to the requirements of JT/T 617.1-2018 ~JT/T617.7-2018.

For UN No.3268 Safety devices, if meeting the SP 289, they can be transported as general goods. However, there are two points noteworthy:

• Airbag devices or seat-belt pre-tensioners normally are Class 1 explosives. They can be classified as Class 9 dangerous goods after the bonfire test if the testing result excludes the possibility that the goods are explosives;

• Airbags or seat belts transported separately do not meet the requirements of SP 289 and shall still be transported as dangerous goods.

(5) Other special provisions, such as 141, 168, 199, 241, 283, 335, 346, 646, etc.

Example 5:

Special provision SP 646: Carbon made by steam activation process is not subject to the requirements of JT/T 617.1-2018 ~JT/T617.7-2018.