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LQ&EQ Comparison between European ADR and China JT/T 617

The road transport of dangerous goods has been a major focus of Chinese policymakers ever since the implementation of China ADR, JT/T617 series in Dec, 2018. The government subsequently published a notice and draft measures to support the implementation of the regulation.

Chronology of China TDG regulation development after 2018:

China has learnt a lot from EU’s TDG management and referred to EU-ADR for the formulation of JT/T617. LQ/EQ requirements have garnered the most attention from policymakers as development of effective regulations can help save significant logistics cost for enterprises during dangerous goods transport. The table compares the LQ/EQ requirements between European ADR and China JT/T617:

 

European ADR2015 version

China JT/T 617.3-2018

Out of scope

LQ

  • List of dangerous goods, 7(a): “0”

  • List of dangerous goods, 7(a): “0”

  • Highly toxic chemicals, class 1 explosives and item6.2 infectious substances (Refer to (Measures of administration on road transport safety of dangerous goods) (draft))

EQ

  • List of dangerous goods, 7(b): “E0”

  • List of dangerous goods, 7(b): “E0”

  • Highly toxic chemicals, class 1 explosives and item6.2 infectious substances (Refer to (Measures of administration on road transport safety of dangerous goods) (draft))

MaximumCarriage Amount

LQ

  • Designated amount in 7(a) of list of dangerous goods

  • Designated amount in 7(a) of list of dangerous goods

EQ

  • Designated amount in 7(b) of list of dangerous goods

  • Designated amount in 7(b) of list of dangerous goods

Packaging Requirement

LQ

  • Consistency (Combination packaging)

EQ

  • Consistency (Three layers of packaging, drop test and stacking test, overpack with other dangerous goods packs or general packs)

Mark Requirement

LQ

  • Consistency(Mark of limited quantities, mark of overpack and mark of orientation)

EQ

  • Consistency(Mark of excepted quantities)

Vehicle Requirement

LQ

  • Transport units with maximum mass exceeding 12 tons of DG in LQ, mark of limited quantities shall be shown at the front and rear of transport units; When transport units contain other dangerous goods, orange-coloured plate shall be marked, mark of limited quantities is optional.

  • Containers carrying DG in LQ with maximum mass exceeding 12 tons, mark of limited quantities shall be shown on all four side; When the container contains other DG, placards shall be marked, mark of limited quantities is optional.

  • Transport units with maximum mass exceeding 8 tons of DG in LQ, mark of limited quantities shall be shown at the front and rear of transport units; When transport units contain other dangerous goods, orange-coloured plate shall be marked, mark of limited quantities is optional.

  • Containers carrying DG in LQ with maximum mass exceeding 8 tons, mark of limited quantities shall be shown on all four side; When the container contains other DG, placards shall be marked, mark of limited quantities is optional.

EQ

  • Consistency (The number of packages in any vehicle or container shall not exceed 1000.)

Transport Document

LQ

  • In advance of carriage, consignors of dangerous goods packed in limited quantities shall inform the carrier in a traceable form of the total gross mass of such goods to be consigned.

  • In advance of carriage, consignors of dangerous goods packed in limited quantities shall inform the carrier in consignment inventory of the total gross mass of such goods (Package included) to be consigned. (JT/T 617.3- 2018)

  • The Consignor shall state “Dangerous Goods in Limited Quantities”(“有限数量危险货物”) number of packages and total gross mass (package included) in the consignment inventory. (Refer to (Measures of administration on road transport safety of dangerous goods) (draft))

EQ

  • Consistency (State “Dangerous Goods in Excepted Quantities” and indicate the number of packages.)

Exemption

LQ

  • Consistency

EQ

  • Special exemption for dangerous goods packed in excepted quantities: Excepted quantities of dangerous goods assigned to codes E1, E2, E4 and E5 with a maximum net quantity of dangerous goods per inner packaging limited to 1ml for liquids and gases and 1g for solids and a maximum net quantity of dangerous goods per outer packaging which does not exceed 100g for solids or 100ml for liquids and gases are only subject to packaging requirements and pack testing requirements in excepted quantity. Other requirements such as mark of excepted quantities, load capacity of vehicle and transport documents could be exempted.

  • No exemption under EQ


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