Use the 2026 revision
IS-39 revision 1, dated 23 February 2026, was published on 9 April and entered into force on 10 April 2026. It replaced the 2015 instruction, now repealed. Existing references should identify which version they use.
Identify the design and the responsible organisations
The instruction covers manufacturers, purchasers and consignors domiciled in Spain, and relevant control bodies. For Spanish-origin approved package designs, purchaser oversight includes manufacture abroad. A purchaser can have responsibilities even when it is not the eventual consignor. Consult the current scope and procedures.
For a review, distinguish the organisation buying the packaging from its manufacturer, design approval holder, user and consignor. Record the manufacturing country, design reference and intended transport modes. This avoids treating a purchase order as a complete account of the parties involved.
Approval, manufacturing evidence and transport use
The CSN explains the transport framework as a combination of modal rules, nuclear and radiological legislation, technical assessment, approval and inspection. An approval document and evidence of manufacturing conformity serve different purposes. The documents must relate to the packaging and use being reviewed.
The CSN safety guide catalogue includes GS 6.4 revision 1, published in February 2025, for approval and shipment authorisation documentation, and GS 6.6, published in June 2017, for compliance documentation of packages not subject to approval. Safety guides support application of the requirements; they are not authorisations.
The transition for existing documentation
The 2026 instruction gives a maximum of two years from entry into force to adapt the compliance documentation of packaging designs already in use before 10 April 2026 to Article 5. For new packaging designs that do not require design approval and are acquired from that date, the consignor must hold Article 5-compliant documentation before use. The documentation transition does not postpone other obligations. Read the additional and transitional provisions.
Create a design-by-design register of the documents needing review. Record acquisition and use dates, document revisions, gaps identified, the person responsible and the planned completion date. This is a way to organise the review; it does not determine whether a package is suitable for a particular radioactive content.
Prepare a focused document review
Gather the design reference, approval or compliance file, manufacturing records, purchaser checks and relevant correspondence. Ask the responsible specialists to establish which requirements apply to that design and operation. Track unresolved differences between the supplied packaging and its documented basis before relying on the file.
Package selection, acceptance and use require the appropriate technical assessment and applicable approval conditions.
For DGSA support, describe the parties involved, package type, manufacturing location and transport modes. Contact DGSA with the available documents and the questions needing clarification.