The Pipeline and Hazardous Materials Safety Administration (PHMSA) has proposed new UN numbers for lithium metal and sodium ion batteries, new packing groups and added subsidiary hazards, as part of its regular update to match international transport rules. The proposal (HM-215S, docket PHMSA-2025-0048) was published on 27 October 2026. Comments are due by 28 December 2026.
Shippers, carriers and anyone who maintains Section 14 of a safety data sheet should check which of their products are affected.
Nine Hazardous Materials Table changes to know
The proposal aligns US rules with the 24th revised UN Model Regulations, the 2027–2028 ICAO Technical Instructions, IMDG Code Amendment 43-26 and GHS Rev. 11. These are the main changes to the Hazardous Materials Table.
| Entry | Proposed change |
|---|---|
| UN3536, batteries in cargo transport units | Split by chemistry: UN3536 for lithium ion, new UN3563 for lithium metal and UN3564 for sodium ion |
| Chlorophenols | New UN3561 (corrosive, toxic, solid) and UN3562 (corrosive, solid); UN2020 and UN2021 renamed |
| UN2348, butyl acrylates | New Packing Group II entry for low-flash-point grades such as tert-butyl acrylate |
| UN2862, vanadium pentoxide | New Packing Group II entry for material with 10% or more respirable particles |
| UN1040, UN1041, UN3300, ethylene oxide | Class 8 (corrosive) subsidiary hazard added |
| UN1727 and UN2372 | Subsidiary hazards added (6.1; 8 and 6.1) |
| UN2941, fluoroanilines | Entry removed; shipped under n.o.s. entries |
| UN2956, musk xylene | No longer allowed as a limited quantity |
| UN2857 and UN3358 | Heating machines added to the refrigerating machine entries |
PHMSA linked the battery split to a 2024 truck fire near Baker, California, where responders could not tell which battery chemistry was involved. New special provisions also cover hybrid sodium/lithium batteries, MRI scanners and LPG blends with up to 12% dimethyl ether.
Section 14 of your SDS may need updating
Section 14 lists the UN number, proper shipping name, transport hazard class and packing group. When the Hazardous Materials Table changes, the SDS has to change with it.
- New UN numbers: batteries shipped in cargo transport units need the correct one of UN3536, UN3563 or UN3564.
- New packing groups: some butyl acrylate and vanadium pentoxide grades move to Packing Group II.
- New subsidiary hazards: ethylene oxide, UN1727 and UN2372 gain extra hazard classes, which changes both Section 14 and package labels.
- New segregation rules: silane (UN2203) moves from stowage category E to D, and benzene sulfonyl chloride (UN2225) must be kept apart from alkaline compounds and cyanides.
The proposal does not set a compliance date. The international editions it adopts start to apply from 1 January 2027, so air and sea shippers will meet many of these changes regardless.
Check your products before comments close on 28 December
- Match your product list against the changed entries in the table above.
- Flag the SDSs whose Section 14 will change, starting with batteries and the chlorophenol, acrylate, vanadium pentoxide and ethylene oxide entries.
- Review the cost estimates in the Preliminary Regulatory Impact Analysis in docket PHMSA-2025-0048.
- Submit comments at regulations.gov by 28 December 2026.
Sources
Arysha Alif Khan
Arysha Alif Khan is an EHS and chemical safety specialist with a background in biochemistry, biotechnology, and public health. She works closely with the product and regulatory teams to turn complex chemical regulations, SDS requirements, and workplace safety standards into clear, practical guidance for people.