MSDS Labeling and Air/Sea Classification for Exporting Cosmetics Containing 70% Ethanol

Question

I am planning to export cosmetics containing 70% ethanol. According to the regulations, it is classified as UN1170 Ethanol solution, Class 3, PG III dangerous goods. In this case, I would like to inquire whether it is mandatory to indicate the dangerous goods classification and the flash point on the MSDS, and whether the regulations differ when transporting via air or sea.

tflow_expert · Accepted Answer

When exporting cosmetics containing 70% ethanol (UN1170 Ethanol solution, Class 3, PG III), the flash point that serves as the basis for designating the product as PG III must be indicated in Section 9 of the MSDS, and a declaration regarding dangerous goods must also be made in Section 14. For maritime transport, it can be classified as UN1170 Ethanol solution, Class 3, PG III in accordance with the IMDG Code. For air transport, if the item is a cosmetic and meets conditions (a) and (b) below, it may be classified as ID8000 Consumer Commodity, Class 9 according to the DGR. (a) Consumer Commodity: Defined as substances packaged and distributed in a form suitable for retail sale for personal care or household purposes; the Class/Division permitted under this definition follows Special Provision A112. (b) A112: Only Class 2 (non-toxic aerosols only), Class 3 (PG II or III), Division 6.1 (PG III only), and substances corresponding to UN 3077, 3082, 3175, 3334, and 3335 that have no subsidiary risk can be designated as ID8000 Consumer Commodity, and dangerous goods prohibited from passenger aircraft transport cannot be classified as Consumer Commodity.

MSDS Labeling and Air/Sea Classification for Exporting Cosmetics Containing 70% Ethanol

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