ADR 2021 change in marking of IBCs

ADR 2021 change in marking of IBCs – One of the few changes affecting IBCs in ADR 2021 versus the 2019 version concerns the “UN” marking. In paragraph 6.5.2.2.4 there is an addition for IBCs whose inner container is not visible from the outside. This concerns both the VARIBOX FC and the VARIBOX CC, these double-walled containers have an outer container that fully encloses the inner container. To enable a quick inspection of the production date of the inner container, this date now will be marked on the outer container as well.

Two “UN” markings on the same IBC?

Consequently, both VARIBOX FC and CC are showing two markings that look alike; one UN design type mark for the complete IBC and a second for the inner container. They normally show the same date of manufacture, but after repair/replacement of the inner container, this may show two different dates!

What does the second marking show?

The second marking lacks the UN symbol but otherwise shows practically the same information as the UN marking. It can be found after the words “Inner receptacle” and is a duplicate of the inner container marking. The date indicated here shows how old the inner container is and can be used to determine whether the IBC still can be used. The maximum period of use is 5 years (or in some case 2 years) after this date of manufacture of the inner container.

Marking of IBCs after repair/replacement

When the inner bottle is replaced by a new one, the mark on the outer container must be updated.  ADR 6.5.4.5.3 instructs the Party performing the tests and inspections after a repair or replacement to durably mark the IBC near the manufacturer’s UN design type mark. This mark should show the State, a Symbol, and the Date of repair. And on VARIBOX FC and CC IBCs manufactured from July 2021 onwards, also the date of manufacture of the inner container.

Make sure to duplicate the date (MM, YY) shown on the new inner container, after the wording “Inner receptacle” on the outer container.

How to mark

The duplicate mark shall be “durable and legible”. Standard labels may not be durable enough on a plastic surface. Select a suitable method of marking, for example, engraving or embossing. The height of the dates shown must be 12 mm.