Multilateral Agreement M366

Starting from September 1, 2025, due to Delegated Regulation (EU) 2024/197 (21st ATP of the CLP), the harmonized classifications listed in Annex VI of Regulation 1272/2008 (CLP) have been modified for lead powder (particle diameter < 1 mm) and massive lead (particle diameter ≥ 1 mm), with important implications also from the point of view of the transport of dangerous goods.

Italy, through the Ministry of Infrastructure and Transport, has submitted to UNECE the Multilateral Agreement M366, requesting a derogation from the application of ADR for lead metal alloys.

The multilateral agreement applies only to metal alloys assigned to UN 3077 ENVIRONMENTALLY HAZARDOUS SUBSTANCE, SOLID, N.O.S., packing group III, containing:

a) ≥0.25% massive lead (particle diameter ≥1 mm);
b) ≥0.025% lead powder (particle diameter <1 mm).

These metal alloys may be transported without being subject to ADR provisions, provided that the following conditions are met:

a) they do not fulfil the criteria of any class other than Class 9; 
b) metal alloys are sparingly soluble in water; 
c) they are carried:

I. in packagings, IBCs and large packagings that meet the general provisions of 4.1.1.1, 4.1.1.2 and 4.1.1.4 to 4.1.1.8 and are sift-proof and water-resistant or are fitted with a sift-proof and water-resistant liner; or
II. in bulk according to VC1 or VC2 codes.

 A copy of this agreement shall be carried on board the transport unit.

This agreement shall be valid until 31.08.2027 for the carriage on the territories of those ADR Contracting Parties signatory to this agreement. If it is revoked before then by one of the signatories, it shall remain valid until the above mentioned date only for carriage on the territories of those ADR Contracting Parties signatory to this agreement which have not revoked it.

To confirm the validity of the agreement, the signature of at least one other ADR Contracting Party is expected.