In mid-2023 the UN Recommendations on the Transport of Dangerous Goods updated the rules around how reconditioned IBC packaging may be re-marked. The update was technical and easy to miss. It also reshaped how we stencil totes that go out of our yard.
What changed
Before the update, a reconditioner could remove or obscure the original manufacturer marking if the original marking had become illegible. The reconditioner’s own marking would then be the controlling certification.
After the update, the original marking must be preserved if it is still identifiable, even partially. A reconditioner’s stamp must be additive — placed near the original, not over it. If the original marking has truly become unreadable, the tote is no longer eligible for reconditioning under the original certification; it must be re-certified from scratch through a more involved process.
Why it matters operationally
A meaningful percentage of incoming totes have markings that are scuffed, partially worn, or sun-faded. Under the old rule we could re-stencil over the scuff and call it done. Under the new rule we must read what is there, preserve what is readable, and add our stamp next to it.
Practically, this took us about three weeks to retool. We added a UV lamp at the marking station to bring out faint stencils that are not visible in normal light. We added an oblique-light inspection step to find pressed-in characters that are no longer pigmented. We trained operators on the new marking placement rules.
Why it matters legally
A reconditioned tote with improperly placed markings is a tote that a hazmat carrier can refuse, or that a regulator can flag. We have not had an incident, but several large logistics companies started auditing markings for compliance in 2024. The diligence is now a normal part of the cost of shipping.
The non-obvious result
A side effect: totes that come to us with completely illegible markings can no longer be cheaply restored to certified status. The economics of those totes have shifted toward repurposing (rain barrels, aquaponics, raised beds) rather than reconditioning. We have absorbed that shift without much trouble; the repurposing benches were under capacity anyway.