Moving Refrigerant Cylinders by Road in China: The Document Set That Travels With the Load (JT/T 617 / GB 12268-2025)

Thu, 24 Sep 2026 · QUZHOU HUAFU NEW REFRIGERATION MATERIAL CO., LTD.

A road load of refrigerant cylinders is documented by two parties, and they own different documents. A load that leaves with only the carrier’s papers has already lost one of them.

1. Who owns which document

China’s road rules for dangerous goods are built around a division of duty. The consignor (托运人) has to describe the goods correctly and hand over the safety documentation. The carrier (承运人) has to be licensed for the class, with a qualified crew and vehicle. The vehicle-level rules and the loading rules belong to the carrier and to the loading operation — not to the party that sold the goods.

The technical basis is JT/T 617-2018 (Road transport rules for dangerous goods), published in seven parts:

That structure is carried into the 《危险货物道路运输安全管理办法》 (joint MOT order No. 29 of 2019, in force from 1 January 2020) and the 《道路危险货物运输管理规定》 (Ministry of Transport; current text as amended by the fourth amendment, MOT Order No. 6 of 2026, in force 20 March 2026).

⇒ The consequence of the split: a supplier can be complete on Parts 2, 4 and 5 and still hand you a load that cannot move, because Parts 1, 3, 6 and 7 sit with the carrier and with the route.

2. The consignor’s documents

The safety card is the one item above that travels with the vehicle rather than with the goods. The current regulation (第 35 条) requires the driver, or the escort, to carry it on the vehicle together with the 《道路运输证》, and its format and content are set by JT/T 617.5-2018 Annex D (a normative annex). It is carried by the crew, not packed in the cargo box — a packing list is not a substitute for it.

The consignor duty is not discharged by sending an SDS for the product family. The rule is correspondence with the goods actually consigned: the SDS and the label have to match what is on the truck, and where the goods are hazardous chemicals that documentation requirement is explicit.

3. What sits on the carrier’s side, not the supplier’s

⇒ A quotation that says “we arrange delivery” is not evidence of any line above. The checkable question is simpler: which licensed carrier is the load tendered to, and does its licence name this class?

⇒ The carrier’s qualification papers are held by the carrier, and we do not hold them on the carrier’s behalf. That boundary is drawn too widely, though, if it is read as “the consignor can prove nothing”. As consignor we are required to entrust the load to a carrier holding the corresponding dangerous-goods road transport qualification (《危险货物道路运输安全管理办法》第 9 条), and to keep the consignment record — the goods, the quantity and the carrier, in the form of the dangerous-goods consignment list — for not less than 12 months (the same measures, 第 13 条). Those checks and that archive are our own documents on our side of the split, and they can be produced on request.

4. Loading rules that decide whether the load may move

Loading is where the consignor’s paperwork meets physical reality.

• No mixing of dangerous goods with ordinary goods (《道路危险货物运输管理规定》第 29 条, current version) — a dedicated dangerous-goods vehicle may not carry food, daily necessities, medicines or medical devices, and other dedicated vehicles may carry ordinary goods outside those categories only after the vehicle has been decontaminated so as not to contaminate or damage them. The framework treats that separation as a hard rule, not a preference.
• Cylinders are secured upright, valve protection in place, and not rolled, dragged, dropped or impacted — handling is governed by GB/T 34525-2017.
• Shade, and separation from heat sources, in summer: a cylinder in direct sun is a temperature case. The limits that apply in storage — see cylinder storage and segregation — do not disappear while the cylinder is on a vehicle.
• Full and empty marked apart. A cylinder documented as “empty” still holds residual vapour and is carried as the class of its last contents.

5. The documents have to describe the load on the truck

6. The electronic waybill

Several provinces operate a mandatory electronic waybill (电子运单) for dangerous-goods road transport, and a national standard setting out its data elements is in preparation. Practically, the load’s identity data — the parties, the goods, the UN number, the quantity, the route — is entered into a system rather than written onto a form, which means the parties have to agree on those fields before the vehicle is loaded. A supplier whose packing list is organised by cylinder group makes that entry mechanical; one that ships “mixed refrigerants” makes it a conversation.

7. Scope of this article

This covers the domestic road leg — the part that ends at a Chinese port, a customer’s site or a warehouse. The export and sea legs are documented under a different framework (maritime dangerous-goods rules and the destination market’s requirements) and are not addressed here — see our notes on filling limits and the frameworks that set them and on storage segregation, temperature and full/empty rules.

What we can provide

Where we act as consignor, the documents on our side travel with the load: an SDS and GHS label set corresponding to the goods consigned, the package marks, and a packing list stating the UN number, class and net mass per cylinder group — the same list the receiving warehouse needs. We are a warehousing and filling operation, not a carrier: the vehicle, the crew and the operating licence for the road leg belong to the licensed carrier the load is tendered to. The carrier’s qualification originals stay with the carrier; what we hold and can produce is our own side of the consignment — the entrustment check against the carrier’s qualification (《危险货物道路运输安全管理办法》第 9 条) and the consignment record kept for at least 12 months (the same measures, 第 13 条).

Contact us with: the destination, the quantity and package format, and whether your receiving site needs the cylinder groups stowed separately.

Sources

• JT/T 617-2018 — 《危险货物道路运输规则》 / Road transport rules for dangerous goods, Parts 1–7 (Ministry of Transport, China).
• 《危险货物道路运输安全管理办法》 — joint MOT order No. 29 of 2019, in force 1 January 2020.
• 《道路危险货物运输管理规定》 — Ministry of Transport regulations for the administration of road dangerous-goods transport; current text as amended by the fourth amendment, MOT Order No. 6 of 2026 (in force 20 March 2026). 第 28 条: the consignor’s statement of name, quantity, hazards and emergency measures, and the handover of a safety data sheet and safety label corresponding to the goods; 第 30 条: the vehicle marking under GB 13392; 第 35 条: the 《道路运输证》 and the 《道路运输危险货物安全卡》 carried on the vehicle by the driver or escort.
• GB 6944-2025 — 《危险货物分类和品名编号》 (classification and name numbers); GB 12268-2025 — 《危险货物品名表》 (dangerous-goods name table) (SAMR/SAC, China).
• GB 190-2009 — 《危险货物包装标志》; GB/T 191-2025 — 《包装储运图形符号标志》 (SAMR/SAC, China).
• GB/T 16483-2008 — 《化学品安全技术说明书 内容和项目顺序》 (SDS content and order of sections).
• GB/T 34525-2017 — Safety rules for handling, loading and unloading, storing and using of cylinder.
• GB 13392-2023 — 《道路运输危险货物车辆标志》 (marking of road vehicles carrying dangerous goods).
• UN numbers and classes as published in the dangerous-goods name tables (GB 12268-2025 / GB 6944-2025).

Prepared by Quzhou Huafu New Refrigeration Material Co., Ltd — a warehousing and filling operation (storage and cylinder filling/repacking), not a manufacturer. This article describes the public framework for the domestic road leg only; which party holds each duty, and the requirements in force at the time of carriage, remain subject to the contract and to current local regulation.