UN 1993 Waste Flammable Liquid N.O.S.: ADR Requirements

Question asked to Palen

Revised on Sep 1, 2026

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My client is shipping 18 × 200 L drums of flammable liquid waste generated from the cleaning of paints and solvents. The available analysis indicates the presence of several Class 3 solvents, but the exact composition varies from drum to drum and is not precisely known. Can the entire shipment be classified under UN 1993, FLAMMABLE LIQUID, N.O.S., WASTE? What requirements must be met regarding classification, the proper shipping name, and transport documentation?

Yes—conditionally. The 18 drums may be consigned under UN 1993 only if the waste is demonstrably a Class 3 liquid with no subsidiary risk that would require a more specific collective entry. Classification must use the consignor’s waste-stream knowledge and all technical/safety data; where doubt remains, select the highest applicable degree of danger. UN 1993, Packing Group II may be used by default only when it can be demonstrated that Packing Group I criteria are not met. (ADR 2.1.3.5.2; ADR 2.1.3.5.5, Volume 1)

Each drum need not have identical solvent composition, but all must fit the same selected UN entry, hazard class, subsidiary-risk determination, and packing group. Known constituents must be assessed for toxic, corrosive, environmental, or other hazards; a Class 3 solvent indication alone does not establish UN 1993/F1. (ADR 2.1.3.5.3–2.1.3.5.5, Volume 1)

Proper shipping name

Use:
UN 1993 WASTE FLAMMABLE LIQUID, N.O.S. (technical name), 3, [I/II/III]

“WASTE” precedes the proper shipping name. As UN 1993 is subject to Special Provision 274, add the recognized technical name(s) of the constituent(s) predominantly contributing to the danger—for example, the known predominant solvents. A trade name or merely “paint and solvent waste” is not an adequate technical name. (ADR 3.1.2.8.1; ADR 3.3, Special Provision 274; ADR 3.2, Table A, UN 1993, Volume 1, page 390)

Transport document

State, at minimum: UN number; the above proper shipping name including WASTE and the technical name(s); Class 3; any subsidiary-risk label(s); packing group; number/type of packages; and total quantity. For this consignment, record 18 drums, 3,600 L. Include the tunnel restriction code where the journey involves a tunnel subject to restrictions, and any mandatory environmental-hazard statement where applicable. (ADR 5.4.1.1.1; ADR 5.4.1.1.3, Volume 1)

The 3,600 L shipment exceeds the 1.1.3.6 thresholds applicable to UN 1993 for Packing Groups I, II, or III; it cannot use the small-load exemption. (ADR 1.1.3.6.3–1.1.3.6.4; ADR 3.2, Table A, UN 1993, Volume 1, page 390)

Sources

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