The United Nations Subcommittee of Experts on the Transport of Dangerous Goods (UNSCOE TDG) is holding their 66th Session June 30 through July 4, 2025 in Geneva, Switzerland. There are 36 formal and 63 informal papers submitted for discussion as of Day 2. 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 2 – Discussion of Papers

INF.7 (China) Classification of substances evolving flammable vapour which can also meet the criteria for flammable solids of Division 4.1 – China questioned whether polymeric The US indicated it was a good clarification and supported. Belgium was opposed suggesting that it could open the current classification of all Class 9 materials. UK further argued that the issue was limited to certain modes and thus did not need to be addressed. Based on the discussion, China withdrew the proposal. No proposals were adopted.

INF.23 (Germany, Kingdom of the Netherlands) Regulation of maritime transport of plastic pellets – Germany and the Netherlands proposed adopting an entry for plastic pellets. The Subcommittee gave general opposition to the proposal, noting that the material did not specifically meet any of the existing criteria. The Netherlands voiced passion that the provisions needed to be considered to protect the environment. After additional discussion, it was agreed to hold further discussions later in the session to prepare feedback for IMO. No proposals were adopted.

2025/31 (Kingdom of the Netherlands) Transport of articles containing gas in cryogenic receptacle – The Netherlands previously noted challenges with offering large articles containing gas in cryogenic receptacles. Building on past papers, they proposed a special provision that would require such shipments to comply with Section 5.5.3. The Subcommittee was generally supportive of the approach but preferred alternate text. Based on the discussion, the Netherlands indicated they would prepare a revised proposal for review later in the week or for a future session. No proposals were adopted.

2025/32 (Gafta) + INF.14 (Gafta) + INF.37 (Gafta) Entries for seedcake, UN 1386 and UN 2217 – GAFTA described the current transportation of several types of seedcake and proposed to combine the entries and provide an exception when seedcake would not be regulated. The Subcommittee was generally supportive of the effort but requested justification for the moisture content limits. GAFTA agreed to host a lunchtime working group on Day 2 to discuss future work. No proposals were adopted.

2025/18 (PRBA, RECHARGE) + INF.9 (PRBA, RECHARGE) + INF.36 (PRBA, RECHARGE) Lithium ion batteries testing – Amendment to the T.5 short circuit test – RECHARGE proposed to address problems with applying the T.5 test to high voltage and batteries that do not have exposed terminals. Proposals were offered in 2025/18 and INF.36. Germany was supportive of the effort in principle but felt additional discussion was necessary. Specifically, alternative testing should be defined. Germany also felt that the term high voltage batteries is used in the EV industry and may not be appropriate for other industries. China stated that the T.5 test should be conducted to determine how to mitigate results of short circuit, not to eliminate the ability to conduct the test. They stated that referencing production safety standards for the automobile industry is not appropriate for all high voltage batteries. The Republic of Korea was supportive of Proposal 1 but were not supportive of Proposal 2. France supported proposal 1 but felt that short circuit protections for high voltage must be readily identifiable and always present while the battery is in transport. OICA explained that the automotive industry is very concerned with the safety of electric vehicle batteries. Inclusion of high voltage safety standards is necessary to ensure protection of all involved. The US reiterated they believed the T.5 is to determine what happens when the battery is short circuited, not to test whether a battery can be short circuited. They were supportive of Proposal 1 but preferred additional discussion on Proposal 2. The Netherlands opined the tests do not appropriately fit the developing technology. Thus, additional work is needed on T.5, but they agreed with others that the proposals as drafted are not ready for adoption. RECHARGE explained that it is not necessary to conduct the T.5 test to determine the resulting hazards; the hazards are well understood. Instead, the discussion should be the purpose of the T.5 on large batteries. Based on the discussion, RECHARGE withdrew the proposals. No proposals were discussed.

2025/21 (Republic of Korea) + INF.60 (Republic of Korea) Clarification of the installation and fixing methods for UN 38.3 lithium battery testing – Amendment of 38.3.4 of the Manual of Tests and Criteria – The Republic of Korea reiterated the importance of properly attaching cells and batteries to the testing platform to ensure the conditions of the test are faithfully transmitted to the test subjects. Fixtures are often used to meet this requirement. In INF.60, they proposed revised text 38.3.4 as a possible resolution to the issue. The US, Canada, France, Belgium, and RECHARGE supported the proposal as drafted in INF.60. China believed the only tests impacted are T.3 and T.4, and existing language in T.4 seemed to conflict with what was being proposed. Germany voiced concern that fixtures may modify the test results and was not satisfied with the proposed language. Based on a majority vote, the Subcommittee agreed to the proposal in INF.60.

INF.56 (China) Proposal of the vibration test conditions of the Manual of Tests and Criteria – China pointed out the significant developments in battery design since the UN38.3 provisions were developed. Originally, the tests were developed for small consumer electronics. In 2011, the provisions for T.3 were updated to reflect the growing number of large vehicle batteries. However, even larger batteries now require a review of the T.3 provisions. Further, testing shows that random vibration papers are more common in transport vs. the sinusoidal wave vibrations required by the T.3 test. Accelerations measured for very large batteries were between 0.09g and 0.79g, well below the current 2g provisions. They requested the Subcommittee consider reviewing the T.3 test. The US reminded the Subcommittee that tests are abuse conditions but recognized the severity of the testing may drive future review. COSTHA and PRBA supported the effort with PRBA suggesting other tests, such as T.1 Temperature may also need to be reviewed for large format batteries. China invited interested delegations to reach out to them for future discussions. No proposals were considered.

INF.50 (France, Germany) Re-activating informal working group IWG “Repair” to prepare lithium and sodium ion battery topics – Germany proposed to re-engage an Informal Working Group on Lithium batteries that was focused on Repair. However, they suggested that the mandate of the group expand to include technical aspects of the existing UN38.3 testing requirements. Belgium, the Netherlands, OICA, and RECHARGE all voiced their support for the effort. France offered to initiate and chair the group. The Subcommittee agreed to establish an intersessional working group to review lithium battery testing and repair topics. France suggested interested parties contact them directly for interest in participation.

INF.31 (United States of America) Creating Class 9 subdivisions for increased hazard awareness – The US acknowledged the challenges with Class 9 today and noted that there are 50+ entries that are assigned to the miscellaneous hazard class. While many of these materials do not have similarities, there may be a necessity to subdivide Class 9 into 3 divisions: Energy Storage Devices, Low Hazard Energetic Articles, and all remaining substances. Although no proposals were offered, the US requested the Subcommittee consider the impact of such an effort, including the development of classification criteria for low hazard energetic materials. Spain commented that Class 9 was currently a box of “disasters” that seem to include all sorts of materials that simply did not fit in other hazard classes, but it works. They were not supportive of the approach. Sweden was intrigued by the concept and suggested that a 4th category could be developed for environmentally hazardous substances and perhaps may include the introduction of a packing group concept. Germany, the Netherlands, and the UK supported the approach. Austria compared Class 9 to a closet or filing cabinet that has become so full that it is difficult to find anything within. They preferred to avoid classification criteria to simplify the discussion. The US indicated they would host a meeting during the Day 3 morning break to discuss further. No proposals were considered.

2025/29 (Belgium, France, RECHARGE on behalf of the IWG) + INF.12 (Belgium, France, RECHARGE on behalf of the IWG) + INF.32 (Belgium, France, RECHARGE on behalf IWG) + INF.33 (Belgium, France, RECHARGE on behalf of IWG) Progress report of the informal working group on the hazard-based classification system for lithium cells and batteries – Belgium, as Chairman of the IWG on the Classification of Lithium Batteries, updated the Subcommittee on progress to develop a hazard-based classification system. The Group met in Shanghai in March 2025, and the report of that meeting was provided in INF.12. Following those discussions, possible proposals were drafted and presented in INF.32. Austria noted that their fire safety group was previously unaware that off-gassing of lithium batteries can result in an explosive atmosphere. Thus, they were supportive of including measurements for presence of flammable gases. The Netherlands was concerned that using battery state of charge (SOC) as an intrinsic property would result in a single battery being assigned multiple UN numbers and that may lead to confusion. They also preferred minimum granularity by limiting the number of categories to 4. China preferred not to apply the flammable gas criteria except in very limited cases. They were also in favor of allowing cells and batteries to be tested at an SOC <100%. The UK defended the SOC as an intrinsic property, noting that a battery being offered at 50% is going to act and react as a battery containing 50% of the capacity of the battery. They further suggested that if a battery is not tested at 100%, then the battery would have to default to a Category A (most reactive). The UK voiced concern that the proposals have lumped lithium and sodium ion batteries into the same entries and preferred to continue toward maximum granularity. Germany agreed with the Netherlands that SOC should be a mitigating factor used in packing instructions vs. considering it as an intrinsic property. ICAO argued Intrinsic SOC would be very difficult to implement practically in air transport. The US shared they also preferred to consider SOC as a mitigating factor. DGAC agreed with Germany, the Netherlands, and the US. France agreed with the UK that SOC is an intrinsic hazard. The Chairman noted the significant divide between delegations on several topics including SOC and encouraged delegations to consider how to find consensus on the topics. Belgium requested a lunchtime working group on Day 3 to discuss the issue further and see if a consensus could be reached. No proposals were considered.

2025/19 (UNICEF, WHO) + INF.41 (UNICEF, WHO) + INF.62 (UNICEF, WHO) – UNICEF presented a revised proposal that provided a full exception to the Model Regulations for netting impregnated with insecticide. The Subcommittee agreed to the proposal as drafted.

2025/34 (MDTC) Lithium cells and batteries – Classification and identification – MDTC acknowledged the significant work by the IWG on Lithium Batteries. However, they shared that critical need articles and medical devices may need to have specialized considerations. No proposals were included but they requested the IWG consider possible provisions to simply the classification of such devices. No proposals were considered.

2025/3 (United Kingdom) Amendments to special provisions on lithium batteries – The United Kingdom proposed to clarify and simplify special provisions SP360, SP388, and SP410. Sweden argued against Proposal 1 and offered editorial amendments to Proposals 2 and 3. Austria, RECHARGE, and Belgium preferred to keep the current text. France supported Proposal 1, Option 2, Proposal 2, Option 1, and offered amendments to Proposal 3. The US supported Proposal 1 or 2, Proposal 2, Option 1, and opposed Proposal 3. Germany voiced support for Proposal 1, Option 1 or 2, Proposal 2, Option 2, and opposed Proposal 3. Australia supported Proposal 1, Option 2, Proposal 2, Option 2, and opposition for Proposal 3. China agreed with others that revisions to SP360 and SP388 were not necessary. They were also confused as to the approach in proposal 3 for cargo transport units with hybrid batteries. The UK heard support for Proposal 1, Option 2, and offered to update the wording in Proposal 2, Option 1 to clarify the provision applied only to batteries that were not installed in vehicles or equipment. The goal of Proposal 3 was to clarify how to handle a Cargo Transport Unit with various batteries installed. Based on the comments from China, they indicated they would emphasize lithium metal batteries in future proposals. The UK withdrew Proposals 2 and 3. The Subcommittee agreed to Proposal 1, Option 2.

2025/33 (Germany, Sweden) + INF.28 (COSTHA, PRBA, RECHARGE) Clarification of special provision 405 assigned to UN Nos. 3556, 3557 and 3558 – Sweden explained that adoption of SP405 has created a number of questions at the ADR regarding whether a vehicle packed within a box or crate are still required to be marked/labeled if there are images on the box. They asked whether hazard communication was necessary on given examples in the paper. To solve the issue, they proposed to revise SP405 by providing an exception from marking/labeling when the vehicle has a net mass >30 kg. In INF.38, PRBA offered an alternate approach that specifically stated when marking/labeling was required and when it was excepted. OICA opposed the proposal in 2025/33 noting that it would have significant implications for the automobile industry. They argued that communication was unnecessary in ground transport. They offered alternate text that pointed to the modal regulations for hazard communication options/requirements.

End of Day 2 [COSTHA]