MEMO Gas oil/Diesel fuel + CMR

Important changes have been made to the classification of several Diesels and Gas Oils.
What does this mean for transport and for practical operations on board or at terminals?

Introduction
Recently, significant changes have been implemented in the classification of several Diesels and Gas Oils. These products, which were previously often not classified as CMR, are now categorized as:

 H360 – May damage fertility or the unborn child (Category 1B, CMR)

This adjustment has direct consequences for both the Safety Data Sheets (SDS) and the ADN classification of these products.

What does CMR mean under ADN?
A substance is considered CMR under ADN when it carries at least one of the following hazard statements (see Section 2 of the SDS; more info at the bottom of this memo):

• H350 → Carcinogenic (may cause cancer)
• H340 → Mutagenic (may cause genetic defects)
• H360 → Reprotoxic (may damage fertility or the unborn child)

Important: The presence of any one of these hazard statements is sufficient for a substance to be classified as CMR.

However, when assigning CMR properties, the ADN does not consider the route of exposure. In this case, the reprotoxic properties were established following oral exposure (ingestion); a route of exposure that is unlikely to occur during transport. More about this later

According to information from, among others, Concawe, this concerns the following CAS numbers:
64742-46-7, 64742-79-6, 64742-80-9, 64741-43-1, 64741-44-2, 68814-87-9, 68915-96-8, 64741-49-7, 64741-58-8, 64741-77-1, 68334-30-5, 68476-30-2, 68476-31-3, and 68476-34-6.

This includes both gas oils and regular automotive diesels (including diesel in accordance with EN590). However, it does not apply to, for example, HVO or GTL

Key Implications for Transport (ADN)
The new CMR classification has significant impact on operational requirements, including:

• Mandatory vapour return:
  Loading CMR products must be carried out in closed mode with vapour return.

• Previous cargoes:
  When the previous cargo was Diesel or Gas Oil with CMR, loading with vapour return is also mandatory.
  
  
• Sampling onboard:
  Open sampling of CMR products onboard an inland tanker barge is not permitted as of ADN 2025.

Implications for Terminals / Fillers
For several terminals this will cause practical challenges. Some diesel and gas oil loading terminals do not have vapour return systems installed on all jetties, as this was previously not required.

For terminals that handle only diesel- or gas oil, or that do not store products requiring vapour return, this may pose an even greater challenge, as these installations may be completely absent.

This also affects terminals handling only FAME or other non-ADN substances:
If the previous cargo was diesel or gas oil with CMR properties, loading FAME would also have to be performed with vapour return. 

A potential solution, cleaning cargo tanks after a CMR pre-load, is costly and burdensome. Due to the low vapour pressure of diesel, degassing is not possible, meaning washing at a specialized facility (e.g. ATM) would be required. This increases pressure on already limited capacity and generates additional waste streams, contrary to the principles of the CDNI Convention, which aims to reduce waste by transporting compatible cargoes.

Possible Solution: ADN 2027
Because this classification change has arrived unexpectedly and has far-reaching consequences, the ADN Committee is currently working on a structural solution with associated transitional provisions. These are expected to be included in ADN 2027. However, these are not yet fully clear, and further work is needed here!

In the meantime, new SDS’s containing H360 are already being published.

Temporary Approach Until ADN 2027 Guidance Is provided
Transafe is in discussions with the Dutch authorities, including IL&T, regarding the practical implications of this change.

IL&T has indicated that it will not enforce these requirements until the ADN Committee has established clear, future-proof guidelines. A transitional period, similar to previous cases such as with heavy fuel oil, is expected. These are expected to be included in ADN 2027. However, they are not yet completely clear and there is still work to be done!

This means that for now (for Diesel and Gas Oil containing only H360):

1. Loading without vapour return remains permitted (though recommended where available)
2. A previous cargo of Diesel/Gas Oil (H360) does not trigger vapour return requirements for the next load (like FAME).
3. Open sampling remains permitted (provided other conditions also allow it)

Important Note: UN 1202 Diesels/Gas Oils containing H350 and/or H340 were already classified as CMR and fall outside this scope. For these substances, vapour return and (semi-)closed sampling remain mandatory.

 

Required Adjustments

• Safety Data Sheet (SDS)
  SDSs for these Diesel and Gas Oil products must be updated to include H360.

• Transport Document (pending further clarification from ADN2027)
  Do not change the Proper Shipping Name, but optionally add: (CMR; H360)**

Examples:
UN1202 Diesel fuel, 3 (N2, F), III, Environmentally hazardous (CMR; H360)**
UN1202 Diesel fuel according to EN590, 3 (N2, F), III, Environmentally hazardous (CMR; H360)

**Note: if only UN1202 Diesel Oil, 3 (N2, F), III Environmentally Hazardous is communicated, without mentioning CMR, this is also sufficient, as it is not enforced until ADN2027.

• ADN Checklist – Proper Shipping Name
  Ensure addition of (CMR; H360) as described above.
  
  
• ADN Checklist – Previous Cargoes
  Do not include any CMR indication if the previous cargo’s transport document already listed “(CMR; H360)”.

ADR / RID
For road and rail transport (ADR/RID), this change has no direct impact. These regulations do not take CMR properties into account. However, additional requirements may apply under environmental permits or occupational health legislation (ARBO).

Example SDS for Diesel with only H360 (no H340/H350):

 

 

Background to the H360 Classification
Research has shown that oral exposure of rats to these substances resulted in harmful effects on the unborn offspring. As a result, these substances have been classified as Reprotoxic Category 1B.

The European Chemicals Agency (ECHA) has informed all registrants that they must update their REACH registration and SDS no later than 30 September 2025.

From now on, Section 2 of the SDS will include hazard statement H360FD, and in Section 14 the substance will be treated as a CMR substance for ADN transport purposes.

Health and Safety
The health and safety of employees working with these products always remains a priority. In this case, the reprotoxic properties were established following oral exposure, an unrealistic exposure route during handling or transport. Nevertheless, vigilance, correct handling, and compliance with procedures are essential.