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Policy Watch

Japan proposes pulling open-type containers into radioactive sea-freight rules from January 2027

A draft transport ministry order would require open-type containers carrying radioactive material to follow the same marking and loading limits as closed ones from 1 January 2027, with public comments due by 6 November.

By Tokyo Brief DeskOct 8, 20262 min read
An open-top shipping container on a ship deck with blank hazard placards on its sides as a crane lowers another container.

Japan's transport ministry has put out for comment a draft order that would stop open-type containers escaping the rules on shipping radioactive material by sea. The Maritime Bureau's inspection and measurement division is amending the Dangerous Goods Ship Transport and Storage Regulations, and the draft would take effect on 1 January 2027.

What the draft changes

The ministry says the amendment follows the 43rd amendment to the IMDG Code, which the International Maritime Organization adopted in May 2026 and which enters into force on 1 January 2027.

The "large container" definition now covers only non-open-type containers over 3,000 litres. The draft extends it to open-type containers. The overview says open-type containers cannot work as receptacles for radiation protection and safety, so the requirements for large containers used as receptacles would still apply only to non-open-type ones.

For open-type large containers holding radioactive packages or low specific activity material, the overview says that:

  • all four sides must carry the prescribed marking;
  • where a container holds only radioactive material of one designation and travels as exclusive-use loading, the UN number must be displayed;
  • the same caps on the transport index apply per hold or deck area and per ship, and for containers holding radioactive packages the same caps on the criticality safety index apply too.

Open-type containers holding low specific activity material would also need the prescribed placard.

Other changes

Applications under Article 87(1) and transport plans under Article 99(1) could go straight to the minister, not via a regional transport bureau chief. The draft would also delete the provision that lets certain notified radioactive consignments go without a watchman against theft.

Timetable

Comments are open from 7 October to 6 November 2026, and must arrive by then, in Japanese, by email, fax, post or the e-Gov form. The ministry plans to promulgate in late November. Open-type containers already at sea with radioactive packages or low specific activity material when the order takes effect would follow the old rules until that voyage ends, and penalties for earlier acts would also follow them.

The changes apply to radioactive material, not to dangerous goods generally, and the text could still change after consultation.