Amendments to the IMDG Code (42-24)

As instructed by CCC 9, E&T 39 finalized the draft amendments to the IMDG Code and directly submitted them to MSC 108. Accordingly, MSC 108 adopted a consolidated version of the IMDG Code, which includes the amendments 42-24. Amongst various amendments that were adopted at this session, attentions may be paid to the following matters.

Eleven (11) dangerous goods were newly added in the dangerous goods list under chapter 3.2 of the Code.

Special Provisions 388, 400, 401, 961, 962, and 977 relating to the transport of engine- or battery-powered vehicles were revised or established in chapter 3.3 of the Code.

The requirements on stowage and segregation of UN 3536 (i.e. lithium batteries installed in cargo transport unit) were amended as below to address its unique safety risk.

Data loggers, sensors and cargo tracking devices, attached directly to the interior or exterior of cargo transport units, such as freight containers, shall comply with explosion-, dust- and water-proof requirements in the revised paragraph 5.5.4.4 of the Code from 1 January 2028. Fixed devices on or in reefer containers shall comply with these requirements ASAP but not later than 1 January 2032.

The amendments 42-24 will enter into force on 1 January 2026 and may be applied voluntarily from 1 January 2025.

In conjunction with the amendments 42-24, ‘Revised emergency response procedures for ships carrying dangerous goods (EmS Guide)’ was approved as MSC.1/Circ.1588/Rev.3 at this session.

Source: resolution MSC.556(108) and MSC.1/Circ.1588/Rev.3 / MSC 108/WP.6, Annexes 8 and 21

Key amendments and their implications

Lithium Batteries

One of the most noteworthy changes is the large increase of references to lithium batteries. Including that articles that may contain lithium cells or batteries are now under the classification of articles containing dangerous goods N.O.S (Not Otherwise Specified). The amendments stipulate that lithium cells and batteries must meet the testing requirements of the Manual of Tests and Criteria, including pre-production prototypes transported for testing.

Packaging Requirements

New packaging requirements have been introduced for these articles. If a lithium battery installed in an article is damaged or defective, it must be removed, and special packaging instructions must be followed. Vehicles containing such batteries must comply with Special Provisions (SP376) unless otherwise approved by a competent authority.

New Additions to Class 9 - Miscellaneous Dangerous Goods

The amendments introduce new entries to Class 9:

• 3556 VEHICLE, LITHIUM ION BATTERY POWERED
• 3557 VEHICLE, LITHIUM METAL BATTERY POWERED

Packaging Instructions

Vehicles equipped with lithium batteries can now be transported without packaging, provided they can remain upright without additional support and offer sufficient protection to prevent any battery damage. For vehicles that might topple during transport, packaging instructions include using crates, pallets, or cargo transport units with appropriate support mechanisms like bracing, frames, or racking is required. Vehicles containing lithium batteries that are fully enclosed by packaging, crates, or other means that prevent ready identification must have the relevant marking, labelling and placarding in place.

UN 3171 Revisions

Additionally, lithium batteries have been removed from UN 3171. This entry now only applies to vehicles and equipment powered by wet batteries, metallic sodium batteries, or sodium alloy batteries.

Clarification on Test Summaries

The term “make available” in relation to the test summary for lithium batteries has been clarified. Manufacturers and subsequent distributors are required to ensure that the test summary for lithium cells, batteries, or equipment containing such components is accessible to allow verification of compliance by consignors or other supply chain participants.

New Class 9 Sub-Section – Miscellaneous Dangerous Goods

A new entry has been introduced under Class 9, specifically for Sodium Ion Batteries. The United Nations' Sub-Committee of Experts on the Transport of Dangerous Goods recently suggested that regulations governing lithium-ion batteries should be expanded to include sodium-ion batteries as well. This proposed applying the same classifications and safety standards to sodium-ion cells that are currently in place for lithium-ion cells, necessitating updates to the UN Manual of Tests and Criteria and the IMDG Code.

Charcoal/Carbon Cargoes

In relation to UN 1361 CARBON and UN 1362, CARBON, ACTIVATED, Special Provisions (SP) 925 and 223 have been withdrawn, with two new provisions, SP 978 and SP 979 introduced.

As per SP 925, previously the Code did not apply to non-activated carbon, carbons made by a steam activation process and carbon that passed the self-heating substances test (UN N.4 Test), meaning that the substance does not self-heat.

By removing SP 925, Charcoal will no longer be granted exemptions even if the material passes the UN N4 test. SP 979 exempts Charcoal that is steam activated or chemically activated provided the criteria of the provisions are met.

SP 978 provides conditions relating to weathering, packaging, including a temperature stipulation that the material does not exceed 40 °C on the day of packaging, and stowage requirements.

The updated amendments stand to have a large impact on charcoal in packaged forms, especially in containerised form. With the removal of exemptions for charcoal, it is anticipated that these stricter regulations will help decrease the occurrence of cargo being mis-declared by shippers.

Definitions

Updated Definitions

Recycled Plastics Material: The definition now includes that recycled plastic materials can be processed by industrial packaging and other types of plastic materials, such as intermediate bulk containers (IBCs). As part of the quality assurance program for processing recycled plastics, it is necessary to know the previous use and contents of the materials.

New Definitions

The amendments introduce new definitions for:

• Degree of Filling
• Explosive or Pyrotechnic Effect
• Metal Powders

Stowage and Documentation Changes

Stowage Plans

Stowage plans now need to specify primary and subsidiary hazard classes, along with the placement of all dangerous goods and marine pollutants. This can replace a manifest or special list, aiming to improve the clarity and safety of stowage operations.

Data Logging and Cargo Tracking

Data loggers, sensors, and cargo tracking devices used during transport must now be securely installed in the cargo transport unit and certified safe for the dangerous goods being carried within the cargo transport unit.

Documentation Clarity

The amendments clarify documentation requirements when exemptions are granted under a special provision and specify the roles of competent authorities in certain special provisions.