Japan’s Ministry of Land, Infrastructure, Transport and Tourism (MLITT) is consulting on the proposed updates of the Regulations for Transport and Storage of Dangerous Goods by Ships (hereinafter referred to as the Regulations) and the Standards Concerning the Transport of Dangerous Goods by Ships (hereinafter referred to as the Standards), aiming to align Japan’s rules for transport of dangerous goods (TDG) by ships with the international rules - International Maritime Dangerous Goods Code (IMDG Code)*. The consultation will end on November 28, 2022. Once approved, they are expected to be officially released in late December 2022 and take effect from January 2023.
| * The IMDG Code was developed as an international code for the maritime transport of dangerous goods. Its latest version is IMDG Code 2022 Edition, which is authorized to be used from January 2024 with a 12-month transitional period from January 1, 2023. |
Proposed updates in the Regulations
As stipulated in the IMDG Code, before packing dangerous goods into a container, the interior and exterior of the container must be thoroughly examined to ensure that it’s structurally serviceable and would not compromise its cargo retention capabilities. The IMDG Code 2022 Edition prescribes that packagings exempted from container examination can also be used to transport dangerous goods with a mass over 400 kg. As per the current Regulations, in Japan, such exemption (exempted from container examination) applies to ‘Small Container (in Japanese: 小型容器)’, which refers to ‘Dangerous goods container with a capacity of less than 400kg (or with a capacity of less than 450 L when used for transport of liquid dangerous goods)’. To be in line with international rules, the definition of ‘Small Container’ in the Regulations is proposed to be updated, and new requirements are proposed to be added. Highlights are summarized as below.
Small container may refer to a container with a capacity of less than 450 L and thus is exempted from examination.
For the transport of dangerous goods with a mass over 400 kg in a certain container exempted from examination, permission from the Minister will not be required.
Marks indicating small amount dangerous goods, fumigation warning marks and asphyxiation warning marks will be required to meet the requirement for durability of the package marks, i.e., package marks shall still be identifiable on packages surviving at least three months’ immersion in the sea.
Proposed updates in the Standards
Updates of the Standards are proposed in accordance with the IMDG Code 2022 Edition, including:
Adding new requirements for the storage methods for containers containing 4 types of substances, e.g., self-reactive substances and organic peroxides.
Updating the hazard classification of ethyl bromide (UN1891) from Class 6.1 Toxic Substances to a main hazard class - Class 3 Flammable Liquids and a secondary hazard class - Class 6.1 Toxic Substances; and updating its allowable capacity and mass for safe carriage.
Adding ‘Cobalt (II) hydroxide powder (containing more than 10% respirable particles)’ as dangerous goods.
Eliminating the distinction between segregation groups SGG1 (acids) and SGG1a (strong acids) with respect to segregation requirements specified for each kind of dangerous goods.
Consolidating the ‘Extracts, Aromatic, Liquid (UN1169)’ and ‘Extracts, Flavoring, Liquid (UN1197)’ as ‘Extracts, Liquid (UN1197)’.
Removing the requirement to show the telephone number on the lithium battery mark.


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