Epichlorohydrin (ECH, CAS 106-89-8, EC 203-439-8) is transported as UN 2023, a Class 6.1/3 flammable toxic liquid with a closed-cup flash point near 33 °C and a boiling range of 115–117 °C. The material is a chlorinated oxirane monomer used primarily in liquid epoxy resin synthesis through condensation with bisphenol A, in synthetic glycerol, and in cationic polyacrylamide flocculants. Commercial terms do not modify ECH’s vapour pressure or hydrolysis behavior, but they fix the point at which a bulk parcel or ISO tank container shifts from seller’s risk to buyer’s risk. For this substance, that boundary determines who bears a nitrogen blanket failure, who must file an insurance claim after water contamination, and who carries the heat exposure of a dock-side hold at a port of entry.

FOB, CIF, and DDP are compared by buyers because they assign risk transfer, carriage, and duty obligations differently under ICC Incoterms 2020. The rules are published as ICC Publication No. 723. Under FOB and CIF, delivery for risk transfer occurs on board the vessel at the port of shipment; under DDP, delivery occurs at the buyer’s named destination after import clearance. Therefore, a buyer comparing FOB and CIF is not comparing different voyage risk windows—both have the same vessel-side risk point—but different freight, insurance, and documentary control. A buyer comparing CIF and DDP is comparing a seller-managed ocean insurance position with a seller-held risk window that continues into the destination yard.

Why Does On-Board Delivery Produce Different Insurance and Duty Outcomes for ECH?

Under FOB, the seller completes export clearance and delivers the ECH on board the vessel. The buyer bears loss from the moment the tank container or parcel tank is placed on board. In practice, a terminal transfer is documented by the bill of lading, the tank gauging records, and the surveyor’s loading report. Once the loading arm is disconnected, a leak from a manlid gasket, a blocked pressure/vacuum valve, or a failed nitrogen pad is a buyer-side casualty. The buyer must also arrange marine cargo insurance and destination import clearance.

Under CIF, the same on-board risk rule applies, but the seller arranges ocean freight and minimum marine insurance to the named destination port. The buyer should not assume that CIF marine cover is aligned with ECH’s hazards. The seller’s insurance obligation is usually satisfied by minimum Institute Cargo Clauses (C), which excludes many partial losses and temperature-related spoilage. A buyer using CIF should require an upgraded policy of Institute Cargo Clauses (A), or an explicit contractual clause for moisture and nitrogen blanket loss, before the shipment is loaded.

Under DDP, the seller must deliver the ECH after import clearance at the named destination, such as a buyer’s tank farm in Rotterdam or a customs-bonded tank terminal in Busan. The seller carries all risk until that delivery. For a buyer with limited insurance infrastructure, DDP increases certainty because the seller is responsible for the import duties, VAT, and port demurrage events that occur before delivery. The buyer’s residual exposure is limited to the period after discharge into its own storage.

At a Ulsan terminal, a 24,000 L ISO tank container of ECH is staged for FOB loading. The tank container is certified to ISO 1496-3, and the receiving vessel is cleared for UN 2023 under the IMDG Code. The transfer hose is purged with dry nitrogen before connection. The pump-in rate is controlled so that the tank relief valve does not lift, and the vapour return line is routed to the vessel manifold. When the container is secured in the cellular guides and the loading supervisor records the on-board time, risk moves to the buyer. A terminal delay after that point, including a summer berth congestion hold, is a buyer-side loss exposure if the nitrogen pad leaks and the container vapour space enters the flammable range.

When CIF Insurance Does Not Match the Moisture Sensitivity of Epichlorohydrin

CIF is selected by some ECH buyers because the seller manages ocean freight and provides baseline cargo cover. However, the risk point remains the on-board port of shipment. If the vessel encounters heavy weather and the tank ullage space is not maintained under a nitrogen pad of sufficient pressure, atmospheric moisture can be drawn into the breather vent. ECH hydrolyses slowly in the presence of water to 3-chloro-1,2-propanediol and hydrochloric acid by-products. That degradation may not be visible at discharge, but the buyer will later observe a chloride increase, color drift, or higher water content in storage. The buyer’s recourse under a standard CIF policy may be limited because inherent cargo perishability and temperature or moisture sensitivity are normal exclusions in Institute Cargo Clauses.

To manage CIF risk, procurement specifications should state that the cargo must be maintained under dry nitrogen, that the tank dew point must be below -20 °C, and that the voyage temperature must not exceed 40 °C. The marine insurance certificate should be issued for Institute Cargo Clauses (A), with no exclusion for contamination or heating. The buyer should also require a pre-shipment water content certificate, often expressed as mass fraction below 0.05 %, so that latent moisture damage can be distinguished from specification drift at loading.

A CIF shipment discharged at Antwerp may pass the first visual inspection while the ECH is still cold. The buyer’s sampler then draws top, middle, and bottom samples from the tank container using a closed-loop sampling device. If the water content exceeds the purchase specification and the chloride content is elevated, the buyer is already in the risk window because CIF risk passed at the loading port. The buyer must notify the insurer and the seller within the policy time limit, preserve the tank container logs, and retain the nitrogen pressure record. The claim may succeed only if the proximate cause is an insured peril, not inadequate inerting. This is why CIF buyers should obtain the vessel’s ullage and inert gas system records before the tank is discharged.

DDP Terminal Delivery, Import VAT, and REACH Poison Centre Responsibilities

Under DDP, the seller handles export clearance, transport, insurance, import duties, VAT, and delivery to the named destination. For ECH, the delivery location is typically a buyer-nominated tank farm, a road tanker transfer station, or a rail siding with suitable containment. The seller is responsible for providing the safety data sheet in the language of the destination country, for marking the package or tank with UN 2023, and for ensuring that the dangerous goods transport document is completed by the loader. Risk passes to the buyer when the product is placed at the disposal of the buyer at the named destination, after import clearance and after the transport unit is safely positioned for unloading.

DDP does not transfer compliance responsibility for the buyer’s post-delivery operations. Once the ECH is delivered into the buyer’s storage, the buyer is responsible for its own REACH obligations, including the preparation of a downstream user chemical safety report if required, and for Annex VIII poison centre notification to the applicable member state if the ECH is formulated into a mixture before resale. The buyer must also verify that the delivered tank has a clean dry certificate, that the tank container is not contaminated with amines or strong acids, and that the pressure relief valve is set correctly before the first transfer.

DDP can produce a higher invoice cost because the seller includes import VAT and duties. For buyers in the European Union, the customs value is normally the transaction value of the ECH plus freight and insurance to the EU border, and import VAT is applied at the member state rate. The seller’s responsibility for import clearance can reduce the buyer’s documentary burden, but the buyer should still review the customs tariff classification. ECH is classified under HS heading 2910 30 00, and any misclassification can delay the release and create a liability dispute even after delivery.

Upon receipt at a Rotterdam tank farm, a DDP shipment of ECH is offloaded from a road tanker into a fixed stainless-steel storage tank blanketed with nitrogen. The receiving line is grounded and the transfer is monitored for flow, pressure, and temperature. If the tank farm has not been pre-dried, atmospheric moisture can enter through the tank breather during displacement. ECH reacts with water to form chloropropanediols and hydrogen chloride, which can corrode carbon steel and accelerate polymer formation in the presence of iron ions. The buyer should therefore maintain the storage tank under closed-circuit nitrogen, avoid shared lines with amines or mercaptans, and keep the storage temperature below 40 °C. At this point, the DDP seller has discharged its delivery obligation, and the operational risk belongs to the buyer’s tank farm.