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UN approval and food contact for pails, buckets and tins

Why a round pail is a drum and a square tin is a jerrican, where the UN mark actually goes, and which food-contact instrument follows a lacquer.

Tinplate pails on a paint filling line
The code follows the geometry, not the catalogue name.

Two questions decide whether a pail or a tin can actually be sold into a regulated market, and neither is answered by the price list. Does the container hold a UN approval for the contents going into it, and can the supplier produce a food-contact declaration for the surface the product touches. This is how both are settled for the pails, buckets and tins on this site, and where the answers differ from the jerry cans.

Why the codes are not the ones on our jerry cans

The UN code you need is decided by the shape of the container, not by what it is called in a catalogue. The definitions are precise and they cut across the way the trade talks:

  • A drum is a flat-ended or convex-ended cylindrical packaging.
  • A jerrican is a metal or plastic packaging of rectangular or polygonal cross-section.

So a round tinplate pail is a drum and certifies in the 1-series, while a square metal tin is a jerrican and certifies in the 3-series, the same series as the fuel cans elsewhere on this site, despite looking nothing like one. The word “pail” does not appear in the code list at all.

The rest of the code reads as it does everywhere: the first digit is the kind of packaging (1 drum, 3 jerrican, 4 box), the letter is the material (A steel, B aluminium, H plastic, G fibreboard), and the final digit is 1 for a non-removable head or 2 for a removable one.

Format on this siteCertifies asWhy
Round tinplate pail, lever ring or flower lid1A2Cylindrical steel, removable head
Round metal bucket, tight-head1A1Cylindrical steel, non-removable head
Round PP bucket1H2Cylindrical plastic, removable head
Rectangular PP bucket3H2Rectangular cross-section makes it a jerrican
Square metal tin, wide pouring head3A1Rectangular cross-section, non-removable head
Small tins inside a shipper4G outerCombination packaging; the mark is on the box

The code a design would take, not a claim that a given build holds it. Approval is per design type and per plant, and which packing instructions a substance permits is a separate question from the geometry. Ask us for the certificate that covers your specification.

Anatomy of the UN packaging code 1A2 The three characters of UN 1A2 read as: 1 for drum, which is any cylindrical packaging, A for steel, and 2 for a removable head. READING A PAIL CODE 1 Drum
Any CYLINDRICAL packaging. A round pail is a drum.
A Steel
The material. A = steel, H = plastic, G = fibreboard.
2 Open head
The design. 2 = removable head, 1 = non-removable.
UN 1A2, character by character. The first digit is decided by shape alone: make the same pail square instead of round and it becomes a jerrican, UN 3A2.

The mark on a small tin is usually not on the tin

Below about five litres the container normally travels as an inner packaging inside a fibreboard shipper, and the two are tested and certified together as a combination packaging. The UN mark goes on the 4G box. A buyer who inspects the tins for a stamped code and does not find one has not found a problem, and a buyer who assumes the tin is approved on its own has.

The consequence is that the approval belongs to the pair. Changing the shipper, the count per box or the internal fitments can put the consignment outside the tested configuration even though every tin in it is unchanged.

Limited quantities: the relief that does reach a tin

Our ADR reliefs guide rules limited quantities out. For a 20 litre can that is right. At tin scale the same relief is the one that applies, and it is the most useful number on this page.

The limited quantity value for UN 1263 PAINT in packing group II is 5 litres per inner packaging, in an outer not exceeding 30 kg gross, and a 5 litre paint tin sits exactly on that limit. Inside limited quantities there is no requirement for UN-approved packaging at all: the package carries the LQ diamond, no dangerous goods transport document is needed, and the consignment moves under simplified conditions.

Which is why the same physical tin can be a UN packaging question or not a UN question at all depending on the fill. Five litres of paint is inside the relief. The identical body filled to six is outside it, and now needs an approved design. Settle the fill volume before the tooling.

Inner packaging against the limited quantity limit, UN 1263 paintThe ADR limited quantity value for UN 1263 paint in packing group II is 5 litres per inner packaging. Tins at or below that move under the relief without UN-approved packaging; anything larger needs an approved design. INNER PACKAGING AGAINST THE LIMITED QUANTITY LIMIT, UN 1263 PAINT LQ limit, 5 L Sample tin Well inside the relief 0.25 1 L trade tin Inside the relief 1 5 L paint tin Exactly on the limit 5 6 L tin Outside. Approved design needed 6 20 L pail Outside by a factor of four 20 litres, log scale
The outer must also stay under 30 kg gross. Note how little separates the fifth and sixth litre: the same body, the same lid, and one is a labelling exercise while the other is a certification project. Settle the fill volume before the tooling.

Food contact follows the surface, not the container

The mistake worth naming: on a lacquered tin, the food-contact article is the internal coating, not the steel. That single fact redirects the whole documentation trail, because the plastics instruments people reach for do not apply to it.

MarketPP pail, the polymer is the surfaceLacquered tin, the coating is the surface
EUFramework 1935/2004 plus plastics Regulation 10/2011Framework 1935/2004; 10/2011 does not reach a coating
UKAssimilated Regulation 1935/2004 and the Materials and Articles in Contact with Food Regulations 2012
US21 CFR 177 for the polymer21 CFR 175.300, resinous and polymeric coatings
Australia and New ZealandFSANZ Food Standards Code 1.1.1 and AS 2070FSANZ 1.1.1; the coating carries the case

In every one of those the deliverable is the same document: a Declaration of Compliance naming the instrument, the contents it covers and the conditions of use. A DoC that names the wrong instrument is worse than none, because it looks like an answer.

Ask for these four things

Enough to tell a specified pail from an unspecified one, and short enough to put in an email:

  • The coating system, not its colour. “Gold lacquer” is a look. The chemistry is what survives the contents or does not, and it is what a DoC has to name.
  • Tinplate temper and tin coating weight. A thickness in millimetres does not specify tinplate. The temper and the coating weight in g/m² do.
  • Resin grade and melt flow index on the plastic side, plus recycled content, which decides whether the UK plastic tax is charged at all.
  • The UN certificate, with the plant named on it. Approval is per design type and per plant, so a certificate for another factory covers nothing.
Which food-contact instrument reaches which surfaceOn a polypropylene pail the polymer is the food-contact article and the plastics instruments apply. On a lacquered tin the internal coating is the article, so the plastics instruments do not reach it and the coatings ones do. PP pail Lacquered tin Framework 1935/2004 Framework 1935/2004: suitable for PP pail Framework 1935/2004: suitable for Lacquered tin Plastics 10/2011 Plastics 10/2011: suitable for PP pail Plastics 10/2011: not suitable for Lacquered tin 21 CFR 177, polymer 21 CFR 177, polymer: suitable for PP pail 21 CFR 177, polymer: not suitable for Lacquered tin 21 CFR 175.300, coating 21 CFR 175.300, coating: not suitable for PP pail 21 CFR 175.300, coating: suitable for Lacquered tin AS 2070, plastics AS 2070, plastics: suitable for PP pail AS 2070, plastics: not suitable for Lacquered tin Declaration of Compliance Declaration of Compliance: suitable for PP pail Declaration of Compliance: suitable for Lacquered tin
The framework regulation and the DoC are the only two rows that hold for both. Everything between them turns on what the liquid actually touches, which is why a declaration written against the steel answers nothing.

Where we stand on this

Stated plainly, because the useful answer here is the specific one. We do not publish UN codes, coating systems, tempers or food-contact declarations against the standard range, and those fields are marked quoted-on-enquiry on every product page rather than left blank. They are build-specific: the same body gets a different lacquer, a different certificate and a different declaration depending on what goes in it, and publishing one figure would be wrong for most buyers.

What that means in practice is that the specification is settled at enquiry rather than discovered afterwards. Tell us the contents, the fill volume and the destination market, and we come back with the code the design certifies under, the coating specified against your product, and the declaration that covers it. If one of the three would have to be obtained, we say which.

Where to start

Your use caseRecommended canWhy this one
Solvent-based paint and adhesives Metal Pail with Flower Lid or Lever Ring, 4L to 35LMetal Pail with Flower Lid or Lever Ring, 4L to 35L Cylindrical steel, removable head: the 1A2 case.
Thinners and automotive fluids Square Metal Tin Can & Bucket, 250ml to 25LSquare Metal Tin Can & Bucket, 250ml to 25L Rectangular, so it certifies as a jerrican.
Retail tins under 5 litres Round Metal Tin Can, 50ml to 6LRound Metal Tin Can, 50ml to 6L Where limited quantities does the work.
Food and non-hazardous liquids Round PP Bucket, 2.5L to 20LRound PP Bucket, 2.5L to 20L Polymer is the contact surface; 10/2011 applies.

Common questions

What UN code does a steel pail have?

A round tinplate pail with a removable head certifies as UN 1A2. The first digit is the kind of packaging and a drum is defined by its shape: a flat-ended or convex-ended cylindrical packaging. A is steel and the final 2 is a removable head. A tight-head round metal bucket is 1A1 on the same logic.

Why is a square metal tin coded as a jerrican?

Because the UN definitions go by cross-section. A jerrican is a metal or plastic packaging of rectangular or polygonal cross-section, and a drum is cylindrical. A square tin therefore falls in the 3-series alongside fuel jerricans, and a round pail of the same capacity falls in the 1-series. The catalogue name has no bearing on it.

Where is the UN mark on a small tin?

Usually on the box, not the tin. Below about five litres a tin normally travels as an inner packaging inside a fibreboard shipper, and the two are tested together as a combination packaging with the mark applied to the 4G outer. Changing the shipper or the count per box can put the consignment outside the tested configuration even if the tins are unchanged.

Do I need UN approved packaging for 5 litre paint tins?

Often not. For UN 1263 PAINT in packing group II the limited quantity value is 5 litres per inner packaging in an outer not exceeding 30 kg gross. Inside that relief there is no requirement for UN approved packaging: the package carries the LQ diamond and no dangerous goods transport document is needed. Fill the same tin to six litres and the relief is lost.

Which food-contact regulation applies to a lacquered tin?

The framework regulation, 1935/2004 in the EU, applied to the internal coating rather than to the steel, because the coating is the article that contacts the food. Plastics Regulation 10/2011 does not reach a coating. In the US the corresponding instrument is 21 CFR 175.300 for resinous and polymeric coatings, where a polypropylene pail would be assessed under 21 CFR 177 instead.

References

The standards and regulations this page relies on, at their issuing body. Where a market rule is named here, check the current revision before you specify against it.

Last reviewed .

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