IMDG Code Amendment 42-24: Regulatory Background

The International Maritime Dangerous Goods (IMDG) Code establishes the principal international framework for the safe carriage of packaged dangerous goods and marine pollutants by sea. It addresses classification, identification, packaging, marking, labelling, documentation, stowage, segregation and other transport-related safety requirements.

Amendment 42-24 was adopted by the International Maritime Organization (IMO) through Resolution MSC.556(108). Administrations could apply the amendment voluntarily from 1 January 2025, while its mandatory implementation date was 1 January 2026.

The amendment introduced changes affecting battery-powered vehicles, sodium-ion batteries, carbon and charcoal, dangerous goods documentation, stowage plans and devices containing dangerous goods that are used during transport. These provisions have practical implications for shippers, packers, cargo interests, vessel operators, Masters, terminal personnel and technical compliance teams.

Does IMDG Code Amendment 42-24 Require Third-Party Inspection?

Amendment 42-24 establishes requirements for the classification, preparation, documentation and transport of specified dangerous goods. It does not impose a universal requirement for an independent marine surveyor to attend and inspect every dangerous goods shipment.

The distinction is between compliance with the Code and the appointment of an independent third party to verify compliance. A particular approval, certificate, test, inspection or verification may be required by an applicable provision or another regulatory instrument. Other inspections may be commissioned by a shipowner, shipper, carrier, charterer, cargo owner or insurer as part of a risk-management process.

Battery-Powered Vehicles: Revised UN Classification

Amendment 42-24 introduces dedicated Dangerous Goods List entries for vehicles powered by lithium-ion, lithium-metal and sodium-ion batteries. The changes require the applicable vehicle entry to be selected according to the battery technology and the relevant Code provisions.

The former broad use of UN 3171 must not be assumed appropriate for every battery-powered vehicle. The applicable entry and any relevant special provisions must be verified before the dangerous goods declaration is prepared.

Battery-Powered Vehicle Inspection Considerations

• Verify the declared UN number and proper shipping name against the vehicle's battery technology and the applicable Dangerous Goods List entry.
• Check available shipment documentation and confirm that the declared classification is consistent with the information supplied by the shipper or manufacturer.
• Where included in the agreed inspection scope, examine accessible battery enclosures, visible damage, signs of leakage and apparent defects.
• Review the arrangements intended to prevent battery damage, short circuits and accidental activation during transport.
• Verify applicable securing, packaging, marking, labelling and cargo transport unit placarding requirements against the actual Code provisions.
• Record observable defects and discrepancies and refer classification or technical questions to the responsible shipper, manufacturer or appropriate competent party.

Vehicle Packing, Battery Protection and Securing

Amendment 42-24 includes consequential changes to the vehicle-related special provisions and packing requirements. Packing Instruction P912 and Special Provision 962 must be read in conjunction with the specific Dangerous Goods List entry and the applicable provisions of the Code.

What an Independent Survey May Cover

Subject to the survey instructions and safe access, an independent cargo inspection may document vehicle identity, visible condition, apparent battery damage, securing arrangements, packaging condition, visible leakage, labels and placards. These observations can assist the commissioning party in identifying discrepancies before shipment.

The surveyor should not certify compliance with provisions that require technical tests, information or approvals beyond the agreed scope and available evidence. The applicable edition of P912 and Special Provision 962 must be consulted before preparing a detailed inspection checklist.

Sodium-Ion Batteries: New Dangerous Goods Entries

Amendment 42-24 introduces dedicated entries for sodium-ion batteries. These entries distinguish batteries transported on their own from batteries contained in equipment or packed with equipment. The correct entry and its associated conditions must be verified before the shipment is declared.

Compliance Review Considerations

• Confirm the battery chemistry and the applicable Dangerous Goods List entry.
• Determine whether the batteries are shipped separately, contained in equipment or packed with equipment.
• Verify the applicable packing, marking, labelling and documentation provisions.
• Review available manufacturer and shipper documentation where required by the applicable provisions.
• Establish whether any special provision, exception or additional transport condition applies to the particular consignment.

An independent survey can help document the apparent condition and transport preparation of a consignment. It does not replace the technical information, tests or declarations required from the responsible manufacturer, shipper or other party under the Code.

Carbon and Charcoal — UN 1361 and Special Provision 978

Amendment 42-24 revises the requirements for UN 1361 CARBON, animal or vegetable origin. The amendment removes the previous Special Provision 925 exemption for this entry and introduces Special Provision 978, which sets out additional requirements for applicable shipments.

The changes are particularly relevant to charcoal and other carbon cargoes that can present a self-heating or spontaneous-combustion risk. Cargo preparation, weathering, temperature, packaging and supporting documentation must be addressed in accordance with the applicable provisions.

Charcoal Cargo Inspection Considerations

• Confirm the cargo description, UN number, packing group and applicable Dangerous Goods List entry.
• Review available records for production, weathering, packing date and temperature information required by the applicable provisions.
• Check packaging type, package condition and the visible integrity of the cargo transport unit where these matters fall within the agreed inspection scope.
• Review the loading and stowage arrangements against the applicable packaging, headroom and stowage-height conditions.
• Document visible evidence of damage, unusual heating indicators, smoke, odour or other reported concerns, where safe to do so.
• Refer unexplained temperature concerns, suspected self-heating or potentially unsafe cargo conditions to the responsible technical parties before proceeding.

A visual cargo survey cannot prove that the prescribed weathering period has been achieved or that a cargo has passed a required test. Such matters require the prescribed records, test results or other acceptable evidence.

Dangerous Goods Documentation and Exemption Certificates

Dangerous goods documentation must identify the consignment accurately and include the information required by the IMDG Code and applicable SOLAS provisions. Amendment 42-24 adds paragraph 5.4.4.2 concerning certificates that exempt a substance, material or article from provisions of the Code.

Stowage Plans, Hazard Identification and Segregation

Amendment 42-24 clarifies the information required where a stowage plan is used instead of a special list or manifest for dangerous goods or marine pollutants. Under the amended paragraph 5.4.3.1, the stowage plan must identify the primary hazard class or classes, subsidiary hazards and the location of the relevant dangerous goods and marine pollutants.

This clarification is intended to make the existing documentation requirement clearer. It should not be represented as an entirely new obligation applying unconditionally to every stowage plan, irrespective of the document used and the circumstances of the shipment.

Independent Stowage and Documentation Review

Where commissioned, an independent review can compare the available stowage plan and dangerous goods information with the applicable requirements and identify apparent omissions or inconsistencies. The review may also examine whether the recorded cargo positions and stated segregation arrangements are consistent with the information supplied.

The surveyor must have sufficient information to perform the agreed review. A document-only assessment cannot confirm the actual physical position of a container unless the relevant physical arrangement has also been verified.

Data Loggers, Sensors and Cargo Tracking Devices

Amendment 42-24 revises IMDG Code section 5.5.4 concerning devices containing dangerous goods that are in use or intended for use during transport. The provisions address devices such as data loggers, sensors and cargo tracking equipment attached to or placed in packages, overpacks, bulk containers, freight containers and other cargo transport units.

The revised provision should not be interpreted as a blanket requirement for an independent inspection of every data logger or tracking device. The applicable requirements depend on the device, the dangerous goods it contains, its use during transport and the relevant Code provisions.

Packaging Marks and the Transitional Period

Amendment 42-24 revises provisions concerning the application of packaging marks, including the requirement in section 6.1.3.1 for marks to be applied directly to a non-removable component of the packaging, subject to the applicable provisions and transitional arrangements.

The transitional period associated with this marking change ends on 31 December 2026. As this date approaches, manufacturers, packers and other responsible parties should verify the current requirements for the packaging concerned and confirm whether the transitional arrangement applies.

When Is an Independent Third-Party Cargo Inspection Appropriate?

Independent inspection may be useful where the commissioning party needs documented evidence of cargo condition, visible transport preparation, securing arrangements or discrepancies identified during a defined inspection. It is particularly relevant where the cargo presents specific physical risks or where the parties require an independent record before loading.

The inspection scope must be established against the cargo type, applicable IMDG provisions, available documents, access arrangements and the purpose of the engagement.

Inspection Limitations and Responsibilities

• The inspection scope must be agreed before attendance or document review.
• The report should distinguish physical observations from statements or documents supplied by other parties.
• A visual inspection does not substitute for prescribed laboratory tests, battery diagnostics or other required technical testing.
• A surveyor should not certify a dangerous goods declaration or statutory approval unless specifically authorized and competent to perform that function.
• Any unsafe condition identified during inspection should be communicated promptly to the responsible parties in accordance with the agreed procedures.
• Final acceptance, loading authorization and regulatory decisions remain subject to the applicable responsibilities and authority arrangements.

Practical IMDG Code Compliance Workflow

The following workflow is a practical planning aid for cargo interests, technical managers and maritime stakeholders preparing shipments affected by Amendment 42-24. It is not an additional mandatory procedure prescribed verbatim by the amendment.

Common Compliance Oversights Under Amendment 42-24

A systematic review of cargo identity, documentation, packaging, transport preparation and the specific provisions applicable to the consignment can help identify deficiencies before loading.

Practical Pre-Shipment Compliance Checklist

Classification and Cargo Information

• Confirm the correct UN number and proper shipping name.
• Verify the applicable class, subsidiary hazards, packing group where applicable and special provisions.
• Confirm battery chemistry and the applicable vehicle or battery entry.
• Verify that the cargo description is consistent across the relevant documents.

Packaging and Cargo Preparation

• Confirm the applicable packing instruction and packaging conditions.
• Verify applicable vehicle battery protection and securing arrangements.
• For applicable UN 1361 cargoes, review the requirements of Special Provision 978 and the required supporting records.
• Check the applicable packaging marking provisions and transitional arrangements.

Documentation and Stowage

• Check the dangerous goods declaration and other required transport information.
• Confirm whether an exemption certificate is required under paragraph 5.4.4.2.
• Verify applicable stowage plan hazard identification and cargo location details.
• Review relevant segregation and cargo securing arrangements.

Independent Verification

• Determine whether the applicable provision requires a specific test, certificate or approval.
• Agree the scope of any independent cargo inspection or technical review.
• Record discrepancies and refer unresolved compliance questions to the responsible party.
• Retain relevant records and evidence of corrective action in accordance with applicable requirements.

Official Regulatory Sources and Reference Documents

The following sources provide official regulatory information and supporting guidance concerning Amendment 42-24. Always verify the current applicable edition, corrections and subsequent amendments before using a document for operational or compliance decisions.

Independent Technical Support for Dangerous Goods Compliance

PAMS Pacific Admiralty Maritime Services provides independent marine surveying, technical inspections, engineering consultancy and regulatory compliance support for maritime stakeholders. Technical engagements are defined according to the vessel, cargo, project requirements and information available for assessment.

Where appropriate, independent technical work may include cargo condition assessment, review of available transport documentation, examination of accessible packaging and securing arrangements, recording of visible discrepancies and preparation of a technical report.

The scope of an engagement must clearly distinguish physical inspection from document review, prescribed testing, certification and statutory approval. Any findings should be reported with the relevant limitations and supporting evidence.

PAMS Pacific Admiralty Maritime Services is an independent technical consultancy based in Manila, Philippines. It is not a flag Administration, classification society or statutory certification authority. Its consultancy services do not replace required approvals, prescribed tests, statutory surveys or decisions reserved to competent authorities.