LOOSE LIDS?

ADR change: Now the UN mark must sit tight - literally!

Yes, you read that right.
Starting 1 January 2025, UN markings on packaging for dangerous goods may no longer be placed on any part that can be detached. In the new 2025 edition of ADR (chapter 6.1.3.1, for those who read ADR at night), a new requirement has been introduced:

The mark must be placed on a non-removable part of the packaging.

In other words: if you put the marking on a detachable lid - it’s game over.

What does this mean in practice?

All manufacturers and suppliers must ensure that the UN marking (and associated symbols, numbers and letters) is:

• Durable, clearly legible, and

• Placed on a part of the packaging that cannot be removed (so no, it does not help that the lid “sits tightly” – it must be a permanent part of the container itself).

For packaging over 30 kg gross weight, the mark must also be placed on the top or on one side of the packaging.

A small sigh…

Let’s all hope that manufacturers do not solve this the same way the juice and plastic-bottle industry has recently done - you know, the user-friendly caps that refuse to detach no matter how much you twist, pull or curse.

Transition period

Take a breath!
Packaging produced before 1 January 2027 may still be used even if it does not comply with the new requirement - as long as it was manufactured before that date (ADR 1.6.1.57).

In other words:
From 1 January 2025, all new packaging must have fixed, non-removable markings.
From 1 January 2027, it’s “full stop” for packaging that does not follow the rule.

Our recommendation

Talk to your packaging supplier already now - especially if you use lids with UN markings. When 2025 arrives, the marking must be glued, moulded, welded, or otherwise “unmistakably” fixed to the packaging.

Do you have questions about how this affects your products?

Contact us at NET - we will help ensure that your packaging is not only leak-tight, but also regulation-tight.

NET - your lighthouse in the dangerous goods universe