Packaging Requirements for Dangerous Goods Under SANS 10228: A Practical Guide

Every year, South African authorities reject or detain dangerous goods shipments that fail packaging requirements — not because the product itself is non-compliant, but because someone selected the wrong box, used an uncertified inner container, or misread a UN packaging mark. SANS 10228, which incorporates the UN Recommendations on the Transport of Dangerous Goods, sets out detailed packaging requirements that leave little room for interpretation. Getting them wrong carries consequences: shipment delays, regulatory penalties, and genuine safety risks during transit.

Why UN-Certified Packaging Is Non-Negotiable

Dangerous goods packaging is not ordinary packaging with a hazard label stuck on it. Every outer packaging used for dangerous goods transport must be UN-certified — meaning it has been tested and approved to withstand the specific hazards associated with its intended contents. The certification process involves drop tests, stacking tests, leakproofness tests, and internal pressure tests, depending on the packaging type.

Using non-certified packaging is one of the most common violations found in South African DG audits. It does not matter that a heavy-duty industrial drum "looks strong enough." Without the UN certification mark physically embossed or printed on the packaging, the shipment is non-compliant, full stop.

Reading a UN Packaging Mark

The UN packaging mark is a coded string that tells inspectors everything they need to know about a container's certification. Understanding how to read it is a core competency for anyone preparing dangerous goods shipments.

A typical mark looks like this: 4G/Y145/S/24/ZA/1234

Breaking it down:

• 4G — Packaging type code. "4" indicates a box; "G" indicates fibreboard. Other common codes include 1A1 (steel drum, closed head) and 3H1 (plastic jerrican, closed head).
• Y — Packing group performance level. "X" means tested for Packing Groups I, II, and III; "Y" for Packing Groups II and III; "Z" for Packing Group III only.
• 145 — Maximum gross mass in kilograms (for solids) or specific gravity (for liquids).
• S — Indicates the packaging is tested for solids. "L" would indicate liquids.
• 24 — Year of manufacture.
• ZA — Country of manufacture (South Africa).
• 1234 — Manufacturer's or certification body's code.

The most critical element for day-to-day compliance is the packing group letter. A container marked "Z" cannot be used for Packing Group II goods, regardless of what else might seem acceptable about it. This mismatch is found with alarming frequency during inspections.

When Combination Packaging Is Required

Combination packaging — inner packagings contained within an outer packaging — is required whenever the dangerous goods cannot be safely transported in a single packaging unit. This applies to most liquids in smaller quantities and to substances that require cushioning, absorbent material, or separation from the outer wall of the shipping container.

SANS 10228, through the UN Model Regulations, specifies permitted inner and outer packaging combinations in the packing instructions for each UN number. For example, UN 1230 (methanol, Packing Group II) references packing instruction P001, which lists acceptable inner packagings (glass, plastic, or metal receptacles up to specified volumes) and compatible outer packagings (fibreboard boxes, plywood boxes, steel drums, and others).

Selecting inner packaging by packing group follows a straightforward hierarchy. Packing Group I substances (greatest danger) demand the most robust inner containers with the smallest permitted volumes. Packing Group III substances allow larger inner containers and a wider range of materials. Ignoring these volume and material restrictions is a compliance failure, even when the outer packaging is correctly certified.

Getting the Inner-Outer Match Right

The outer packaging must always be UN-certified for the combination as tested. A fibreboard box certified with glass inner bottles is not automatically compliant if you substitute plastic inner containers — the certification applies to the tested configuration. Any substitution requires re-evaluation against the relevant packing instruction.

Common Failures Found in DG Shipment Audits

South African auditors and inspectors consistently flag the same packaging failures:

Expired or damaged UN packaging. Fibreboard boxes degrade over time. A box manufactured three years ago and stored in a humid warehouse may no longer meet its certified performance standard, even if the UN mark is still legible.

Packing group mismatch. Shipping Packing Group I substances in "Y"-marked packaging remains one of the most dangerous errors in the supply chain.

Insufficient cushioning or absorbent material. Combination packagings for liquids must include enough absorbent material to contain the entire volume of the inner packagings in the event of breakage. Auditors measure this — estimates are not acceptable.

Missing or illegible UN marks. If the mark cannot be read, the packaging is treated as uncertified.

Incorrect closure. A UN-certified drum with an improperly secured lid is an uncertified drum. Closure devices must match the manufacturer's specifications exactly.

Where Avidara Fits

Packaging compliance sits at the intersection of product classification, packing instruction interpretation, and physical execution — all areas where documentation errors compound quickly. Avidara's Document Review service can assess your dangerous goods shipping documentation, packing instruction references, and packaging specifications against SANS 10228 and the current UN Model Regulations to identify gaps before an auditor does. To get started, book a review.