Applying for a licence
The import, transport and export of radioactive substances is regulated in the Transport of Fissionable Materials, Ores and Radioactive Substances Decree (Transport Decree).
For licences for transport of fissile material governed by the IAEA Convention on Physical Protection of Nuclear Material a fee is charged.
The following application forms are available:
- application form transport licence import and export radiopharmaceuticals and consumer goods
- application form transport licence high active sealed source (HASS)
- application form transport licence fissile material security category I, II, III
- application form transport licence other fissile material
- application form transport licence special arrangement
You can request for above mentioned application forms by sending an e-mail to firstname.lastname@example.org. Please mention in your e-mail which type of transport it concerns. You will receive the form within 2 working days by e-mail. The licence procedure will start after the Authority for Nuclear Safety and Radiation Protection (ANVS) has received the completed and signed application form.
Applications for transport licences are processed according to the Dutch General Administrative Law Act. This means that the maximum legal processing time of the application is in principle 8 weeks. If the licence is issued it can be used after an objection period of 6 weeks. During this period, the public can object to the licence. In case an objection is filed at the ANVS and an appeal is filed at the Council State, the licence cannot be used pending the decision of the Council State.
In total a period of at least 14 weeks should be taken into account between the moment a valid application is received by the ANVS and the moment a licence can be used.
Publication of licences
Unlike licences for the use of radioactive materials, there is no obligation to publish transport licences in the Government Gazette. Since the Dutch policy with regard to nuclear safety and radiation hygiene stands out because of its high degree of transparency, the decision has been taken to publish transport licences on a voluntary basis on the website of the Authority for Nuclear Safety and Radiation Protection (ANVS). The licences issued by the ANVS for the use of radioactive materials are published as well.
An important exception has been made with regard to the publication of licences for transport of fissile material of security categories I, II and III. The publication is limited to the announcement that a transport licence has been issued. The announcement is published on the website of the ANVS and in the Government Gazette.
Transport to or from Antwerp harbour through the Westerschelde
The transport of radioactive material across the Westerschelde to or from Antwerp harbor requires a notification. The shipment must be notified to the ANVS at least 3 weeks in advance. For further information please consult this webpage about notifications of transport.
Note: the requirement for a licence based on the Decree regulating the import, export and transfer of radioactive waste and spent fuel (Euratom 2006/117) for the transboundary movement of spent fuel and radioactive waste between EU member states across the Westerschelde still applies.
Radiopharmaceuticals and Consumer products
Depending on the radionuclide and the use of the radionuclide, a licence is required.
You can use the application form “transport licence import and export radiopharmaceuticals and consumer goods” to apply for a licence for import and export of radiopharmaceuticals and consumer products to which radioactive substances have been added intentionally during the production and manufacture processes.
High Active Sources (HASS)
A source is considered a high activity source if the activity equals or exceeds the values of Appendix 4 of the Dutch Decree basic safety standard for radiation protection.
Note: if the activity equals or exceeds the values of Chapter 1.10 of the ADR the source is considered high consequence dangerous goods and the transport requires extra security measures.
You can use the application form “ transport licence high active sealed source (HASS)” to apply for a licence for the import, transport, export and transit of high active sources.
You can use application form “transport licence fissile material security category I, II, III” to apply for a licence for the import, transport, export and transit of fissile material that falls within the IAEA Convention on Physical Protection of Nuclear Material (security category I, II or III). For the import, transport, export and transit of all other fissile and fissionable material and ores you can use the application form transport licence other fissile material.
Consignments for which compliance with a specific provision of the modal transport regulations (ADR, RID, IMDG Code and/or ICAO-TI) is impracticable shall not be transported except under special arrangement issued by the ANVS. Each consignment transported under special arrangement shall require multilateral approval.
An application for approval of shipments under special arrangement shall include all the information necessary to satisfy the competent authority that the overall level of safety in transport is at least equivalent to that which would be provided if all the applicable requirements of these Regulations had been met. The application shall also include:
A statement of the respects in which, and of the reasons why, the shipment cannot be made in full accordance with the applicable requirements;
A statement of any special precautions or special administrative or operational controls that are to be employed during transport to compensate for the failure to meet the applicable requirements.
Shipment of sealed sources between EU member states
In addition to a licence or a notification you are required to complete the EU Standard document for import or export of sealed radioactive sources to or from an EU member state (Euratom 1493/93).
The regulatory body of the importing country must confirm this standard document. This is the Authority for Nuclear Safety and Radiation in the Netherlands. The shipper of the sealed sources must have the standard document prior to the import and export. This document allows you to demonstrate that the consignee is entitled to receive the radioactive substances. You can use the standard document (shipment of sealed sources between the member states of the European Community) for the confirmation.
Authorisation for shipments of radioactive waste and spent fuel
For the transboundary movement of radioactive waste and spent fuel a separate licence (authorisation) is required based on the Decree regulating the import, export and transfer of radioactive waste and spent fuel (BIUDRABS). The BIUDRABS implements European Directive 2006/117, which lays down a community system for the supervision and control of transboundary movement of radioactive waste and spent fuel. The basic principle is that no cross-border transfers of radioactive waste or equivalent substances may take place without an explicit permission of the receiving country.
Note that the actual transport requires notification or a transport license, depending on the type of material.
Also note that the transboundary movement of radioactive waste that contains NORM (Naturally occurring radiation) residues is also regulated by the BIUDRABS.
Certification and validation of transport packages
Different transport package types are used for the transport of radioactive substances, fissionable material and ores. Within Europe the transport of radioactive substances, fissionable material and ores by road falls under the European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR).By rail the Regulations concerning the International Carriage of Dangerous Goods by Rail (RID) apply.
Depending on the package type, a package design approval by the competent authorities may be required. A certificate is issued for this.
Type A packages, industrial packages and excepted packages are packages which meet specific requirements, but not require competent authority approval.
Competent authority approval for the package design is required for all type B packages. Also special form radioactive material requires an approval by the Competent Authority.
Before a package of a package design approved by a non-ADR country can be transported in Europe by road or rail, the package design approval needs to be validated by an ADR country.
Package design approvals for the transport of fissile material in the Netherlands requires validation by the Dutch Competent Authority (ANVS).
For more information about the approval certificates and validations pleasecontact the Authority for Nuclear Safety and Radiation Protection (email: email@example.com). When compiling a safety file linked to an application, we recommend using the Package Design Safety Report Guide of the European Association of Competent Authorities.