Frequently Asked Questions

According to Section 142(1) of Dangerous Goods (Control) Regulation (Cap. 295G), the packing, marking and labelling (PML) of DG shall comply with those specified in Schedule 6 of Cap. 295G.  The relevant requirements are also stipulated in Chapter 3.3 and 3.4 of the Code of Practice for Control of Dangerous Goods on Land.  Nevertheless, the special packing requirements (i.e. approval and periodic testing of pressure receptacles) for Class 2 DG as stipulated in Section 145 of Cap. 295G are also required. 

Apart from that, according to s.143 of Cap. 295G, for those DG (Except Class 3A DG) packed, marked and labelled in conformity with the International Maritime Dangerous Goods Code, they are regarded as complying with the PML requirements of Cap. 295G.

DG shall be packed in conformity with Schedule 6 of Dangerous Goods (Control) Regulation (Cap. 295G), details of the requirements are stipulated in the Basic Packing Instruction (BP).    The appropriate Basic Packing Instruction (BP) and the Special Packing Instruction (SP), if any, for the specific DG are provided at column 7 of the DG List.  Details of BP with SP are provided at Appendix 5 of the Code of Practice for Control of Dangerous Goods on Land.  The searching engine of the DG Thematic Website could also be used to find out the BP and SP of that DG.

DG shall be marked and labelled in conformity with the requirements as stipulated in Schedule 6 of Dangerous Goods (Control) Regulation (Cap. 295G), details of the requirements, for instance, the selection of DG labels, contents of marks, and relevant ways of display are stipulated in Chapter 3.3 and 3.4 of the Code of Practice for Control of Dangerous Goods on Land.

According to Section 142 of Dangerous Goods (Control) Regulation (Cap. 295G), Dangerous Goods (“DG”) shall be packed, marked and labelled in conformity with the requirements as stipulated in Schedule 6 of Cap. 295G.  Nevertheless, according to Section 140 of Cap. 295G, the packing, marking and labelling requirements under Section 142 do not apply to DG in consumer packs, UN 3065 ALCOHOLIC BEVERAGES, Class 3A DG in an approved tank and DG forming part of machinery.  Furthermore, the marking and labelling requirements under Section 142 do not apply to S2DG* in limited packs.

*The interpretation of S2DG is stipulated in Section 2 of Dangerous Goods (Application and Exemption) Regulation 2012 (Cap. 295E)

Pressure receptacles containing Class 2 DG are required to comply with the requirements for packing, marking and labelling stipulated in Section 142 of Dangerous Goods (Control) Regulation (Cap. 295G) as well as the special packing requirements stipulated in Division 8 of Part 3 in Cap. 295G.  Special packing requirements for pressure receptacle include

the requirement of obtaining approval from FSD as stipulated in Section 145(1)(a); and

the requirement of inspection or testing as stipulated in Section 145(1)(b).

Application for approval of pressure receptacle(s) shall be submitted to the Dangerous Goods Enforcement Division of FSD for processing by making reference to relevant guideline published in FSD’s DG Thematic Website.  Details could be found in the Code of Practice for Control of Dangerous Goods on Land.

According to paragraph 3.2.3.6 of the Code of Practice for Control of Dangerous Goods on Land, packing multiple types of DG are called “Mixed Packing”, which is not allowed if the DG are determined as incompatible according to Chapter 2.3 of the Code, except for the following situations:

(a) during storage, each type of DG does not exceed their respective GEQ / IEQ / SEQ (as the case may be) and the aggregate quantity of DG does not exceed the aggregate EQ; or

(b) during conveyance, each type of DG does not exceed their respective GEQ and the aggregate quantity of DG does not exceed the aggregate EQ.

In principle, DG shall not be packed together in the same outer packaging with other DG or other goods which may react dangerously with each other and cause:

 (a) a combustion occurs or is likely to occur;

 (b) considerable heat is, or is likely to be, generated;

 (c) a flammable, asphyxiant, oxidizing or toxic gas is, or is likely to be, generated;

 (d) a corrosive substance is, or is likely to be, formed; or

 (e) a chemically unstable substance is, or is likely to be, formed.

Marking

According to Chapter 3.3 of the Code of Practice for Control of Dangerous Goods on Land, if multiple types of DG are packed in the same packaging, the information of each type of DG shall be displayed, except for duplicate UN number / HK number or name.

Labelling

According to Chapter 3.4 of the Code of Practice for Control of Dangerous Goods on Land, if multiple types of DG are packed in the same packaging, the DG labels for the class and all subsidiary hazard(s), if any, of each type of DG shall be displayed, except for duplicate label(s), e.g. the DG concerned are of the same class or bearing the same subsidiary hazard(s).

According to Chapter 1.3 of the Code of Practice for Control of Dangerous Goods on Land, “Combination packaging” means a combination of packagings consisting of one or more inner packagings secured in an outer packaging.

“Composite packaging” means packaging consisting of an outer packaging and an inner receptacle so constructed that the inner receptacle and the outer packaging form an integral packaging.  Once assembled, it remains thereafter an integrated single unit; it is filled, stored, conveyed and emptied as such.

According to Chapter 3.3 of the Code of Practice for Control of Dangerous Goods on Land, The marking on a DG package shall be comprised of the following information:

(a)     For Class 3A DG, the HK number (i.e. H301) and the name of the DG (i.e. proper shipping name or true name) in either English or Chinese; or

(b)     For other DG, the corresponding UN number (i.e. the 4-digit number specified in column 1 of the DG List and preceded by the letter “UN”) and the name of the DG (i.e. proper shipping name or true name) in either English or Chinese.

Therefore, apart from marking the proper shipping name, the corresponding UN number shall also be marked on the package.  The relevant examples could also be found in paragraph 3.3.3.1.3 of the Code of Practice for Control of Dangerous Goods on Land.

Marking

According to paragraph 3.3.3.3.1 of the Code of Practice for Control of Dangerous Goods on Land, the letters / characters of the marks (i.e. UN number, HK number and the name of the Dangerous Goods) in respect of different package sizes shall be at least of the following height:

According to paragraph 3.3.3.2.1 of the Code of Practice for Control of Dangerous Goods on Land, all marks shall:

(a)     be readily visible and legible from the outside;

(b)     be clearly identifiable despite any exposure to open air and water;

(c)      be displayed on a background of contrasting colour on the outer surface of the packaging;

(d)     be displayed in an upright position or a flat position;

(e)      be so placed on the packaging that they are not covered or obscured by any part or attachment to the packaging or any other label or mark; and

(f)      not be located with other labels or marks that could substantially reduce their effectiveness.

According to paragraph 3.4.3.3.1 of the Code of Practice for Control of Dangerous Goods on Land, each label shall be square-shaped, with the minimum length of each side measuring 100 mm (minimum dimensions).  If it is not feasible to display a label of the minimum dimensions due to the size and shape of the packaging, it shall be of reasonable dimensions that are, having regard to the size or shape of the packaging, appropriate for the packaging and remain clearly visible and legible.  If a label is of dimensions different from the minimum dimensions, the dimensions of every feature in the label shall be adjusted proportionally.

According to paragraph 3.4.3.2.1 of the Code of Practice for Control of Dangerous Goods on Land, in order to properly display the labels, each label shall:

(a) be readily visible from outside;

(b) be clearly identifiable despite any exposure to open air and water;

(c) be displayed on a background of contrasting colour on the outer surface  of the packaging or, if a background of contrasting colour cannot be provided, have a dotted or solid outer boundary line;

(d) be displayed in an upright position or a flat position;

(e) be so placed on the packaging that they are not covered or obscured by  any part or attachment to the packaging or any other label or mark; and

(f) not be located with other labels or marks that could substantially   reduce  their effectiveness.

According to paragraph 3.4.3.2.3 of the Code of Practice for Control of Dangerous Goods on Land, if a package is of such an irregular shape or small size that the marking and DG label cannot be satisfactorily affixed, the marking and DG label can be attached to the packaging by a securely affixed tag or other suitable means.

All DG have to comply with the packing, marking and labelling requirements in the Ordinance, no matter if their quantity of storage and conveyance have exceeded the exempt quantity or not.  However, according to Sections 140 and 141 of Cap. 295G, DG with package size not exceeding the “limited quantity” will be exempted from the marking and labelling requirements while DG in consumer packs will be exempted from the packing, marking and labelling requirements. 

Packing for dangerous goods (“DG”) shall be designed and constructed of material suitable for storing the DG, and provided with adequate measure(s) to prevent any leakage or spillage of any contents.  Packaging shall also be maintained in good condition and free from any defect which may impair its performance.  All restrictions and technical requirements in the extant Dangerous Goods (General) Regulations (Cap. 295B) has repealed and new requirements are incorporated into the Code of Practice for Control of Dangerous Goods on Land issued by the Authority.

In gist, the “UN number” and the Chinese or English “Proper shipping name or true name” of the DG shall be clearly marked on the outermost packaging.  The appropriate label(s) shall also be clearly displayed on the same packaging.

According to Section 141 of Dangerous Goods (Control) Regulation (Cap. 295G), if the DG are packed in limited packs, the package will be exempted from the marking and labelling requirements.  For example, if a DG is given a “limited quantity” of “one litre”, DG with package size not exceeding one litre will be exempted from all marking and labelling requirements, yet packing requirements should still be complied with.

Accurate marking and labelling of DG can enhance public awareness and is therefore of paramount importance to the safe storage and conveyance of DG.  To this end, the amended legislation requires DG to be packed, marked and labelled accurately.