Recently movement of bottled Scotch Whiskey from Hong Kong to other locations via ocean going vessels and feeder vessels are getting delayed due to shippers insisting Material Safety Data Sheet to accompany the consignments.
Let us look at the classification criteria of Dangerous Goods Transport regulations for Scotch Whiskey and analyze what is the basis of above requirement whether it is necessary or not.
In Dangerous Goods Regulations Alcoholic Beverages are listed under UN Number 3065 as below
- UN 3065, Packing Group II , ALCOHOLIC BEVERAGES with more than 70% alcohol by volume
- UN 3065, Packing Group III, ALCOHOLIC BEVERAGES, with more than 24% but not more than 70% alcohol by volume
Scotch Whiskey falls under second entry, Packing Group III, (more than 24% but not more than 70%)
Below are the entries in Dangerous Goods Regulations with special provisions for UN 3065 Packing group III
Above clearly states that, as per special provision 145, Scotch Whiskey, falling under UN 3065 Packing Group III, is not subject to provisions of IMDG Code if capacity per receptacle is less than 250 litres.
Hence, Scotch Whiskey packed in bottles further placed in cartons are not subject to any provisions of IMDG Code for sea transport.
Why shippers are insisting for MSDS?
Self believe this sudden requirement of MSDS asked by Hong Kong shippers are due to the same being asked by some of the shipping shipping lines. Somewhere in the booking desk or approval desk of certain shipping lines misunderstanding of the provisions of IMDG Code has demanded the MSDS for verification and this has sent a wrong message among shippers that all shipping lines need MSDS for transport of bottled Scotch Whiskey.
How to resolve this situation?
In case any shipping line ask for MSDS for shipment of bottled whiskey shipper can offer a non-hazardous declaration quoting special provision 145 of IMDG Code.
Training
Above misunderstanding reiterates the requirement of Training in IMDG Code.
IMDG Code Compliance Centre 
Hi Shaashi,
what’s the definition of “per receptacle”? is it referring to the inner packing like bottle or outer packing or total volume in a container ?
Per receptacle means per bottle of alcohol
Regards/Shashi
many thanks for your clarification, Shashi.
amounts under 1 ltr is allowed anything over 1 ltr will cause you problems. If it is more then 1ltr you are wanting to send it must be separately packaged.
Dear Shasi,
i Have an sea shipment inquiry to the destination Onne port. Pls note the commodity is Whisky ( Alcoholic Beverages ) kindly advice it can be move as NON HAZ or HAZ also i didn’t rcvd any MSDS from the customer. If HAZ want to know any s/line will accept this for transportation.
Awaiting your earliest reply.
Regards,
Johnson
Johnson,
What is the percentage of alcohol volume by volume
How it is packed, bottles in cartons? large quantity in drums ?
Regards/Shashi
Elton, Are you exporting from Malaysia or Importing into Malaysia?
You may quote above article to your agents in Malaysia, additionally may ask them to contact Malaysian Competent Authority on any of the below addresses
Director
Marine Department, Peninsular Malaysia
P.O. Box 12
42009 Port Kelang
Selangor
MALAYSIA
Telex: MA 39748
Director
Marine Department, Sabah
P.O. Box 5
87007 Labuan
Sabah
MALAYSIA
Director
Marine Department, Sarawak
P.O. Box 530
93619 Kuching
Sarawak
MALAYSIA
—
Regards/Shashi
Hi Shashi,
I’m facing the same issue, but why contacting Malaysian Competent Authorities?
Benny,, I suggested t contact Malaysian Competent Authority so your Malaysian Shipping Agents can get convinced there is no need for MSDS. Have you found out from your agents which shipping line is insisting for this?
Regards/Shashi
I’m having a huge headache now. Malaysian Shipping Agents considers this as DG Class III cargo and is insisting of MSDS. How can I avoid this ? My products is Fruit Wine – 14.5% Alcohol content and Vodka Coffee with 40% Alcohol content. Who should I contact that can help me get an MSDS for my products? I have tried Intertek and SGS but to no avail.
Sigh ! carriers are treating wines (brandy, whisky etc) as DG though it is under PG III.
Eric, shippers should quote relevant sections of IMDG Code to carriers while placing the shipment requests.
Though alcoholic beverages of packing group III is not subject to IMDG code if packed in receptacles lesser than 250l
It can still be carried as hazardous if shipper wants. See column 7a of dangerous goods list 🙂
Thanks Shashi.
Hi Shashi,
I want to send whisky samples in 375 ml bottles from India to Africa by “Air” and the alcohol content is more than 24% and less than 70% v/v. This again is UN3065, Packaging Group III ?? Please help me in this regard. Your reply much appreciated. Thanks.
Gopi,
Sorry, I do not cover Air transport (IATA DGR). you need to check with the carrier ( airline) or your forwarder.
Rgds/Shashi
Thanks, Shaahi.