The shipment document set: COA, SDS, GHS labels and UN numbers

Wed, 23 Sep 2026 · RIBOLUO CHEMICALS (ZHEJIANG) CO., LTD.

Expect three documents to travel with a hazardous chemical (certificate of analysis, safety data sheet, hazard label) plus the transport papers the consignor signs. Each answers a different question: did the batch meet specification, what are the hazards, and how may the goods legally be carried. The UN number must be identical across all of them.

1. Sort the set by the question it answers

A transport document must carry the particulars set out in IMDG 5.4.1.4.1 — the five elements in section 5 — and a certificate of analysis is not among them. A COA rides on the contract.

2. The COA: a batch document and the three-way match

Three checks turn a COA into evidence: measured values with methods rather than the word “conforms” (a “≥99.9%” specification is unverifiable if the reporting limit is 0.1%); the batch number, on the certificate, the package label and the packing list line; and who issued it — a repacked lot’s certificate comes from a different laboratory. A COA certifies the batch it sampled, not packaging integrity (test dates, linings), origin, or destination-market admissibility.

3. The SDS: a product-level document

An SDS is triggered in the EU by REACH Article 31(1) where the substance or mixture meets the CLP hazard criteria, and must be compiled in accordance with Annex II — the 16-section format. The US requires the same 16 sections under OSHA 29 CFR 1910.1200(g)(2), which OSHA describes as consistent with GHS Revision 7. Four fields decide most disputes: Section 2 (classification and label elements), Section 14 (UN number, proper shipping name, class, packing group — it must agree with the shipping papers), revision date, and language.

4. Hazard labels and transport labels are two separate instruments

The market label is read by the buyer’s workforce; the transport label by carriers, terminals and emergency responders. ECHA notes the small-packaging exemptions (typically below 125 ml) where pictograms or statements may be omitted — set by the framework, not chosen by a shipper. The check is consistency: the class label and UN number must match the shipping papers and SDS Section 14.

5. The UN number, and the five-element description

IMDG 5.4.1.4.1 requires, per product: (1) the UN number preceded by “UN”; (2) the proper shipping name, with the technical name in parentheses for N.O.S. entries; (3) the primary hazard class or division; (4) any subsidiary hazard, in parentheses; (5) the packing group where assigned — in that order, with nothing interspersed (5.4.1.4.2). UN 1593, DICHLOROMETHANE, 6.1, PG III is complete; “methylene chloride, toxic liquid” is not.

The R-410A row shows a problem buyers meet: the same blend appears under different N.O.S. entries in different suppliers’ documents, because the entry follows the classification made for the product as supplied. The check is not “is this the number I expected” but “is it the same number in every document” — SDS §14, package mark, shipping papers, packing certificate.

6. The two papers the consignor and the packer sign

The dangerous goods transport document may take any form that carries the required information, plus a certification signed and dated by the consignor. IMDG 5.4.1.6.1 sets the wording: the goods are “fully and accurately described … by the proper shipping name, and are classified, packaged, marked and labelled/placarded, and are in all respects in proper condition for transport”.

The container/vehicle packing certificate (5.4.2.1) comes from the packer. It certifies that the unit was clean, dry and fit; that packages requiring segregation were not packed together in it (unless approved under 7.3.4.1); that every package was externally inspected; that drums were upright and the cargo braced; that unit and packages are marked and placarded; and that a transport document was received for each consignment. Total quantity and the number and kind of packages are required too (5.4.1.5.1); a limited-quantity consignment must say “limited quantity” or “LTD QTY” (5.4.1.5.2.1).

7. The China-side layer: what customs asks for before export

GACC Announcement 2020 No.129, in force since 10 January 2021, covers hazardous chemicals listed in the national Catalogue of Hazardous Chemicals. Before export the consignor or its agent files the producing enterprise’s declaration of conformity, the packaging performance test result form (《出境货物运输包装性能检验结果单》), a hazardous-properties classification appraisal report, and a label and SDS sample (with a Chinese translation where the sample is in a foreign language). Item 七 provides that export packaging passes both a performance test and a use appraisal, each producing its own result form. These are China-side documents for Chinese customs; they do not replace the destination market’s SDS and label obligations.

8. The buyer’s cross-check

• Batch number: COA = package label = packing list line.
• UN number, PSN, class, PG: identical on SDS §14, package mark and shipping papers.
• SDS and labels: current revision, correct language, GHS elements matched to SDS §2, plus the transport class label.
• Packaging: UN code, test pressure and periodic inspection dates valid.

FAQ

Is a COA the same as an SDS? No. A COA is a batch document covering one lot against a specification; an SDS is a product document covering hazards and safe handling, with no batch number.

Is an “MSDS” acceptable? MSDS is the older name for the same document; the name used now is SDS (safety data sheet). What matters is the content: 16 sections in the destination market’s format and language, current as of the last classification change.

Do transport rules require a COA? No — the required particulars are listed in IMDG 5.4.1.4.1, and a COA is not among them. It is normally contractual.

Can one document cover several products in one container? The transport document may list several products, each with its own complete five-element line, and the packing certificate covers the container. Each product still needs its own SDS and label.

Ordering through a distributor: what Riboluo Chemicals can provide

RIBOLUO CHEMICALS (ZHEJIANG) CO., LTD. is a chemical distribution and trading platform — not a manufacturer. Goods are sourced from qualified Chinese producers, and one consignment may combine lines from more than one.

For a quotation we can send, per line: the SDS for the exact grade, the COA for the batch actually shipped, label artwork in the destination language where required, and the transport data (UN number, class, packing group, proper shipping name) for carrier approval. Send the product, specification, packing and destination port to tom@riboluo.com.

For general information only — not legal or regulatory advice. Documentation, labelling and packaging duties differ by jurisdiction, mode and carrier, and they change; verify current obligations before ordering.

Prepared by RIBOLUO CHEMICALS (ZHEJIANG) CO., LTD., a member of Hangrui Group — a chemical distribution platform (sourcing, consolidation and documentation), not a manufacturer. We buy from qualified producers and supply under our own documentation (COA, SDS and packing documents).

Related guides

• Can different chemicals travel in one container? Mixed loads, consolidation and the limits
• Low-GWP refrigerants: which grades are in our catalogue, and how to choose one

Sources

• IMDG Code ch. 5.4 Documentation (5.4.1.4.1, 5.4.1.5.1, 5.4.1.6.1, 5.4.2.1): https://moodle.lnu.se/pluginfile.php/7512192/mod_folder/content/0/05-04_pdf.pdf?forcedownload=1
• IMDG Code ch. 5.2/5.3, marking and placarding; current edition (Amendment 42-24): https://www.imo.org/en/publications/pages/imdg%20code.aspx
• UK Maritime and Coastguard Agency on IMDG 5.4.1.6 and 5.4.2: https://www.gov.uk/guidance/mca-guidance-for-container-packing-certificated-on-dangerous-goods-notes
• REACH (EC) 1907/2006 Article 31, Annex II: https://www.legislation.gov.uk/eur/2006/1907/article/31
• ECHA — labelling under CLP: https://echa.europa.eu/regulations/clp/labelling
• OSHA 29 CFR 1910.1200: https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1200
• GACC Announcement 2020 No.129 (in force 10 January 2021): http://www.mofcom.gov.cn/zcfb/zgdwjjmywg/art/2021/art_eff2c81ac9a04d0b98be093e4a53e492.html
• Product safety data sheets behind the UN number table, e.g. Daikin R-410A: https://www.daikinchemicals.com/library/pb_common/pdf/sds/Refrigerants/sds-R-410A-E_20230323.pdf ; NOAA CAMEO: https://cameochemicals.noaa.gov/report?key=UN1710