Some types of paint fall under the ADR hazardous materials regulation. This means it is considered a hazardous substance and transport must meet certain requirements. It is usually indicated on the pot of paint under which hazard class the paint belongs. The paint may have one of the following UN numbers: UN 1263, UN 3066, UN 3469 or UN 3470.

Transporting paints is not always easy. The use of hazardous substances and restrictions on the transport of paints and varnishes are laid down in Regulation (EC) No. 1272/2008. This article provides an overview.

Transporting paint appears to be dangerous or not, depending on the type of paint. It is important which classification is assigned because different laws and regulations apply. There are three types:

- Lead pigment-based paints (not used since 1982)

- Dyeing with organic solvents

but no flammable solvents

- Paints containing flammable solvents

The transport of these paints is subject to the requirements of ADR, RID and CLP. Regulations related to road and rail transport (ADR), inland waterway and sea transport (RID, e.g. in RoRo refrigerated containers) and the EU Regulation on Classification, Labeling and Packaging of Substances and Mixtures (CLP).

The CLP establishes basic safety requirements for the transportation of dangerous goods. This also applies to paint. The European Parliament published an article in December 2014 stating that only products labeled with a "hazard symbol." A number and a hazard name can be linked to the respective ADR, RID or CLP classifications.

Paint may be classified as dangerous goods, but that does not mean that everything must be transported as such. If you want to transport paint (or any expanded item), you only need a permit if the product is classified as dangerous goods. If you want to transport paint in tank containers, you need a permit regardless of classification.

Netherlands: transportation without restrictions

There are no regulations in the Netherlands for paints and varnishes transported in closed containers (tank containers). These may be transported without special permit or notification. There is no obligation to label the product as a "dangerous good."

Exceptions: paints and varnishes containing organic solvents

If a paint contains organic solvents, it may also qualify as a "hazardous substance." This is the case if it contains more than 0.1% by weight of organic solvents with a boiling point lower than 65 degrees Celsius. Here you do need a permit for transportation, but only in closed containers (tank container). Regulations require that this product be labeled as "hazardous."

Paints and varnishes containing hazardous solvents must be labeled as "dangerous goods" regardless of how it is transported.

If a product contains both hazardous and non-hazardous solvents, the strictest provisions for transport apply. In this case, always transport paints or varnishes containing organic solvents in closed containers (tank container).