In a recent development, eBay took action, likely prompted by Royal Mail, by removing the majority of bioethanol fuel listings on July 23. This move affected Ekofuel, a prominent seller in the category. Consequently, eBay instituted a new requirement for bioethanol fuel sellers to demonstrate that their chosen courier permits the shipment of "Limited Quantity" (LQ) dangerous goods. Ekofuel successfully met this requirement, leading to the reinstatement of their listings.
So, what drove these changes? Despite explicit statements from Royal Mail and Parcel Force prohibiting the shipment of flammable liquids within their networks, many sellers continued to send these substances through these channels, disregarding their obligations under ADR. Often, these flammable liquids were dispatched in unmarked boxes without obtaining the necessary consent from couriers.
Understanding the Rules for Shipping Bio ethanol Fuels
Bio ethanol fuels, intended for use in bio ethanol fireplaces, contain a significant proportion of ethanol and other alcohols, added during the denaturing process. Typically, these fuels consist of more than 92% total alcohols and possess a flashpoint typically ranging from 13°C to 15°C, as indicated on the product's Safety Data Sheet (SDS).
Given their flammable nature, the transportation of bioethanol fuels falls within the scope of ADR (Accord Dangereux Routier), the European regulations governing the international transport of hazardous goods by road.
Within the bioethanol fireplace industry, two primary container sizes are prevalent: 1 litre and 5 litres. These sizes are subject to distinct treatment under ADR regulations, resulting in varying shipping obligations.
Shipping 1-Litre Bioethanol Fuel Containers
Bio ethanol fuels' low flashpoint subjects them to ADR regulations for "Limited Quantity" (LQ) dangerous goods when the flashpoint is <23°C and the initial boiling point is >35°C. Bioethanol fuels designed for bio ethanol fireplaces meet these criteria (as indicated in their product SDS), placing them in packing group II, class 3. Under ADR's "Limited and Accepted Quantities" guidelines, the maximum container size allowed for such substances is 1 litre.
To ensure proper labelling, any box containing 1-litre bio ethanol fuel containers must display the Limited Quantity diamond symbol on its external surfaces, akin to the symbol shown on Ekofuel's 2-litre box below. This requirement is part of ADR's provisions for packaging and labelling dangerous goods.
While certain couriers allow the transport of Limited Quantity goods within their networks, it remains crucial for the bioethanol consignor to communicate their intention to ship flammable liquids with the chosen courier. Notably, Royal Mail and Parcel Force prohibit the shipping of any flammable liquids within their networks, including those classified as Limited Quantity.
Shipping 5-Litre Bio ethanol Fuel Containers
Since bio ethanol fuels are categorised as packing group II, class 3 and the maximum Limited Quantity container size is 1 litre, larger 5-litre containers are governed by full ADR regulations. Transitioning to full ADR introduces a new set of obligations and challenges. Consignors may find themselves restricted to couriers specialising in hazardous materials transport, leading to increased costs and additional paperwork.
Vehicles compliant with ADR must bear proper labelling, and drivers must carry documentation detailing the transported products. In essence, shipping 5-litre containers is a more complex and costly endeavour.
Your Responsibilities as the Consignor
Understanding and adhering to ADR regulations can be daunting, leading to non-compliant practices. Instances of non-compliance, such as 1-litre bioethanol boxes lacking the required Limited Quantity diamond labels, incorrect classification of 5-litre containers as Limited Quantity when they should adhere to full ADR, and situations where couriers handle flammable liquids without adequate awareness, are unfortunately widespread.
These instances of non-compliance highlight the importance of ensuring accurate adherence to ADR guidelines.
As a distributor of bioethanol fuel, it is your responsibility to ensure the safe packaging, correct labelling, and informed courier selection for the goods you ship. By adhering to these measures, you safeguard all involved parties and mitigate your companies risk of non-compliance.
Disclaimer
This blog post endeavours to provide insights and information on shipping bio ethanol fuels under ADR regulations. It does not encompass all aspects of these regulations and should not be considered a substitute for professional advice on dangerous goods. If you're uncertain about your obligations when shipping dangerous goods, seek guidance from a certified dangerous goods consultant or professional.
