UNSCOE TDG 66th Session – Day 4 Summary

The United Nations Subcommittee of Experts on the Transport of Dangerous Goods (UNSCOE TDG) is holding their 66^th Session June 30 through July 4, 2025, in Geneva, Switzerland. There are 36 formal and 68 informal papers submitted for discussion as of Day 4. This session is the first of four sessions during the 2025-2026 biennium.

All daily sessions are to be held formally (interpreted). Therefore, papers are to be reviewed as listed on the agenda (INF.2) and final decisions will be taken when appropriate.

This summary is provided to assist you in following the discussions of the papers and is not intended as a full summary of the document that was presented. Links to individual papers are provided to allow you to read the papers directly. Note that the Official report of the session will be made available by the UN Secretariat 3-4 weeks after the session concludes.

Day 4 – Discussion of Papers

2025/33 (Germany, Sweden) + INF.28 (COSTHA, PRBA, RECHARGE) + INF.65 (Germany, Sweden) Clarification of special provision 405 assigned to UN Nos. 3556, 3557 and 3558 – Sweden provided an updated INF.65 to indicate that they do not believe unpacked vehicles do not need to be marked or labeled. Canada, Belgium supported the proposal as drafted. PRBA commented that they supported the revision but requested the Report reflect the challenges industry is facing while the revision is being implemented. The UK explained the difficulties in the ADR are due to how ADR linked the provision to full loads of vehicles. France supported the proposal. The US opined the report may reflect that modes will have to determine how to address the issue within their respective text. Sweden confirmed the problems within ADR/RID/ADN were the reasons they requested clarification. The Subcommittee adopted the proposal and agreed to provide a note regarding implementation in the report.

2025/20 (Republic of Korea) + INF.51 (United Kingdom) Prohibited packagings for substances which may become liquid during transport – The Republic of Korea proposed to revise P002, P410, and LP02 to clarify packaging options permitted for substances that may become liquid during transport. In INF.51, the UK believed the intent of 4.1.3.4 has been lost and proposed to replace 4.1.3.4 with revised text. Germany, France, Austria, Belgium and the US supported 2025/20 but voiced concern that INF.51 introduced the possibility that some packagings that are completely forbidden may be deemed acceptable. China added editorial amendments to 2025/20. The Subcommittee agreed to the proposals in 2025/20 but did not take a decision on INF.51 at this session.

INF.20 (Belgium) Definition of maximum capacity – Belgium raised the confusion of “capacity” when used throughout the packing instructions, pointing out it is used differently in different situations. Canada and Sweden supported the discussion and felt that the term might need to be either revised or deleted. Based on the discussion, Belgium indicated they would return at a future session with a formal proposal. No proposals were considered.

INF.46 (Russian Federation) Suggestions on amendments to 6.7.4.5.2, 6.7.4.7.2 and 7.2.4.2 of the Model Regulations – The Russian Federation noted slight confusion with the requirements related to remotely controlled devices and burst discs for FRP tanks. They offered proposals to clarify. The UK and the Netherlands voiced support for the effort noting that the paper was late. They also encouraged the document be shared with the Joint Meeting as well as the IWG on FRP tanks. Canada offered editorial amendments but supported the effort. Based on the discussion, the Russian Federation stated they would return with a revised formal proposal at a future session. No proposals were adopted.

INF.16 (IMO) Outcome of the forty-second session of the Editorial and Technical Group (on the IMDG Code) – IMO shared items identified during the E&T and CCC that they felt needed to be brought to the Subcommittee’s attention:

• SP401 includes the term “carried” and suggested the term “transported” should be used. The UN Secretariat indicated the UN uses the term “carried”. No changes were adopted.
• SP405 was not adopted under the IMDG Code and instead incorporated those provisions into SP962. No changes were considered.
• The Group questioned whether a general statement can be used in 6.7 that would reference the use of both FRP and metal service equipment. Some in the Subcommittee agreed that such a reference would be beneficial. But others felt additional review was necessary. Based on the discussion, the Subcommittee supported developing text but noted it would need to be based on a formal proposal. No proposals were adopted.
• IMO questioned whether piping may be excluded from the authorization to utilize FRP materials. The Subcommittee agreed that there was an intentional exclusion from FRP piping. No proposals were considered.

INF.21 (Secretariat) Amendments to the Model Regulations proposed by the Ad hoc Working Group on the Harmonization of RID/ADR/ADN with the UN Recommendations on the Transport of Dangerous Goods – The Secretariat provided a number of editorial amendments stemming from conversations at the Joint Meeting.

• Proposal 1 – The Subcommittee agreed to the proposal as drafted.
• Proposal 2 – The Subcommittee agreed to the proposal as drafted.
• Proposal 3 – The Subcommittee agreed to the proposal as drafted.
• Proposal 4 – The Subcommittee agreed to the proposal as drafted.
• Proposal 5 – The Subcommittee agreed to the proposal as drafted.

INF.59 (IAEA) Review and Revision of the IAEA Regulations for the Safe Transport of Radioactive Material, 2018 Edition, IAEA Safety Standards Series No. SSR-6 (Rev. 1) – The IAEA shared planned revisions to SSR-6 (Rev. 1) through a presentation included as INF.59. The document provided a history of the IAEA and the process of how changes are made to the document. The latest review cycle started in 2021 and will be completed in 2026. They noted some significant changes:

• Numerous changes to A₁/A₂ values. There will be a 10-year transition period (2035). SSR-6 will only include the updated tables. The Subcommittee will need to consider whether two tables will need to be maintained.
• New definitions of naturally occurring radioactive material.
• Deleted the definition for confinement system.
• New exceptions for fissile materials.
• New requirement the design of special form shall take account of aging mechanisms.
• Clarification on how LSA and SCO are packed together.
• Clarification on how to use a freight container as a packaging
• Clarification on how describe when more than one UN number is in a package.
• Revised approval requirements
• Slight changes to the description of the labels (to harmonize with the Model Regulations).
• Clarification as to what is meant by “exclusive use”.

IAEA indicated they would provide a formal proposal of changes in March 2026. No proposals were adopted.

2025/13 (COSTHA) Articles containing dangerous goods, n.o.s. entries – COSTHA requested confirmation from the Subcommittee that is acceptable to use the substance entry for a substance contained in an article if the article may be properly packed in accordance with the specific substance entry. The US, Austria, Sweden and the Netherlands agreed with the interpretation. The Subcommittee agreed to include a note to this effect in the Report. No proposals were considered.

INF.24 (Canada) Request for a unified interpretation regarding the intent behind Special Provision 223 and its assignment to specific entries in the Dangerous Goods List – Canada questioned whether SP223 is applied inconsistently, and whether it should be more generally applied in 2.0.2. Sweden agreed with the concern noted by the paper but felt implications should be considered before adopting any general text. The US agreed with Sweden and encouraged work in this area. China, The Netherlands, China, and Austria agreed with the approach. DGAC recalled the SP was applied to entries where a specific “cutoff” was needed because the entry was very generic. Several delegations preferred to see a dual approach, keeping the special provision and applying a general approach. Others noted there are some entries that are identified EVEN IF testing may indicate the material would not be regulated. Germany proposed to create a new special provision to allow one SP to apply to mixtures and solutions and a second to apply to specific entries that may be deemed not subject to the regulations. Canada indicated they would return at a future session with a revised proposal. No proposals were considered.

Informal Working Group on the Hazard-based Classification of Lithium Batteries – Belgium, as Chairman of the IWG, shared discussions from the lunchtime discussion of the topic on Day 3.

Two face-to-face meetings are planned:

• 3-5 December 2025 (Geneva, Switzerland)
• 8-10 July 2026 (Geneva, Switzerland)
• LB papers were requested to be discussed during the second week of the 67^th and 68^th sessions.

2025/32 (Gafta) + INF.14 (Gafta) + INF.37 (Gafta) + INF.64 (GAFTA) Entries for seedcake, UN 1386 and UN 2217 – GAFTA updated the Subcommittee on the results of a lunchtime working group on the issue. Moving forward, GAFTA will not propose to eliminate the two entries but will instead focus on a special provision that would provide an exception from regulation for certain seedcake. The proposal will be accompanied by data to reflect the lack of hazard associated with the product. Thus, GAFTA will submit a formal proposal at a future session. No proposals were considered.

INF.49 (COSTHA) Exceptions for UN 3358, Special Provision 291 – COSTHA questioned whether the sentences of SP291 applicable to UN3358 REFRIGERATING MACHINES are to be taken together, or whether the exception noted in the last sentence is separate from the performance criteria in listed in the first three sentences. The Netherlands inquired to the origin and original intent of the provision. The US, Belgium, and Austria commented in their initial review that they believed the conditions were required even for units containing less than 12 kg. Austria pointed to the French language for further clarity. COSTHA thanked the Subcommittee for their comments and requested interested delegations to send COSTHA any additional thoughts on the topic. No proposals were considered.

INF.17 (Secretariat) Recommendation on the consultative status of kiloFarad International – The Secretariat explained that further research on the organization kFI. The research indicated that the organization as originally recognized as an observer to the Subcommittee had changed. As a result, the Secretariat prepared an INF paper to suspend kFI’s participation as an NGO until additional is provided. As a result, the Subcommittee agreed to suspend kFI’s consultative status until further notice.

INF.57 (KFI) Comments on document ST/SG/AC.10/C.3/2025/29 and informal document INF.17 – Prior to the meeting, kFI submitted comments to be considered by the IWG on Lithium Batteries. The Chairman confirmed the comments would be forward to the IWG for their review. No proposals were considered.

2025/1 (United Kingdom) + INF.66 (United Kingdom) Multimodal transport of portable tanks and multiple element gas containers The UK submitted a revised proposal to address comments received on the issue. The Subcommittee agreed to the revised proposal as drafted.

INF.67 (Russian Federation) Informal working group on portable tanks with shells made of fibre reinforced plastics (FRP) intended for the transport of non-refrigerated liquefied gases (class 2) Terms of References – The Russian Federation provided terms of reference for an Informal Working Group on FRP Tanks for non-refrigerated gases. They provided minor editorial amendments to the proposal. The Secretariat indicated they would update the document in the list of documents on the website. The Subcommittee agreed to create an IWG for FRP Tanks using the terms of reference in INF.67.Rev1.

INF.68 (Germany and France) Proposed Terms of Reference for the Work on UN 38.3 Tests and Reuse, Repair and Repurposing of Lithium – and Sodium-ion Cells and Batteries in IWG “Testing and Repair” – France shared the terms of reference for a possible Informal Working Group on Testing and Repair of Lithium Batteries (IWGTRLB) and invited delegations to indicate interest in participating as well as identifying potential topics to discuss as identified in the 66^th Session. France indicated the group would work with the IWG on the Classification of Lithium Batteries (IWGHBCLB) when necessary. The US offered language to clarify the intent and purpose of the group is not to require retesting of the design, but to address batteries that may be repaired. The Chairman clarified the group may address test conditions for new designs. The Subcommittee agreed to create an IWG on Testing and Repair of Lithium Batteries using the terms of reference in INF.68 as amended by the US.

The Secretariat indicated they have been notified that some standard organizations had suspended their support of providing standards to the Joint Meeting. As a result, the Working Group on Standards would also be suspended. The issue is based on the standard organization’s concerns of copyright infringement during distribution for review. The Secretariat indicated they would update the Subcommittee as additional information was available.

Agenda Item 17(a) includes Election of offices. With the retirement of Duane Pfund (United States), the Netherlands nominated Subcommittee Vice-Chairman Remko Dardenne (Belgium) to be the Chairman starting with the 67^th Session. Sweden nominated Shane Kelley (United States) to serve as the Vice Chairman. With unanimous support, the Subcommittee agreed to both positions.

End of Day 4 [COSTHA]