Introduction
Effective January 1, 2026, the International Maritime Dangerous Goods Code (IMDG Code) Amendment 42-24, issued by the International Maritime Organization (IMO), will be enforced.
This update introduces significant changes to maritime compliance requirements, impacting industries such as chemicals, lithium/sodium-ion batteries, carbon materials, vehicles, and logistics.
What is the IMDG Code Amendment 42-24?
The IMDG Code, developed by the International Maritime Organization (IMO), is the primary technical reference for implementing the dangerous goods requirements of the International Convention for the Safety of Life at Sea (SOLAS).
The Amendment 42-24 introduces new exemptions, stricter compliance obligations, and operational details for companies involved in maritime transport of hazardous goods.
Key Dates to Remember:
January 1, 2025: Voluntary application of Amendment 42-24 begins.
January 1, 2026: Mandatory enforcement of Amendment 42-24.
Below is a detailed analysis of the key changes introduced in IMDG Code Amendment 42-24.
Updates to General Provisions and Definitions
New and Updated Definitions:
Recycled Plastics Material: Now explicitly includes Intermediate Bulk Containers (IBCs), regulating their use in packaging.
Degree of Filling: Defined as the ratio, expressed in %, of the volume of liquid or solid introduced at 15°C into the means of containment and the volume of the means of containment ready for use.
Adjustments to Classification Rules
Changes in Explosives and Organic Peroxides:
UN 3555: Added to the list of liquid desensitized explosives.
Organic peroxides: Three new substances added, with updates to classifications and technical names.
Sodium-ion batteries: Classified under Class 9, with UN 3551 and UN 3552.
New vehicle entries: UN 3556, UN 3557, and UN 3558 for lithium-ion, lithium metal, and sodium-ion battery-powered vehicles, respectively.
Marine Pollutant Exemptions:
UN 3077 / UN 3082: Clarified the application of exemptions for UN 3077 / UN 3082 under specific packaging size conditions (≤5kg or ≤5L), providing flexibility for low-dose and retail packaging.
Dangerous Goods List (DGL) and Special Provisions
Key Adjustments to Dangerous Goods Entries:
Carbon (UN 1361)
SP925 removed; SP978 added with stricter packaging and stowage requirements.
Prohibits specific bag types (5H1, 5L1, 5M1) for closed cargo transport units.
Enhanced documentation requirements: the date of production, date of packaging, and temperature of the material at packaging must be included.
Activated Carbon (UN 1362)
SP925 and SP223 removed; SP979 added, clarifying exemption conditions for steam-activated and chemically-activated carbon.
Other Adjustments
UN 3423: Reclassified from Class 8 to Class 6.1(with subsidiary hazard Class 8) with stricter packing group and transport conditions.
New UN Numbers
UN 3551, UN 3552 (sodium-ion batteries), UN 3556-3558 (new energy vehicles), and others reflecting advancements in materials and energy applications.
Packing Instructions and Tank Requirements
New Packing Instructions:
P303: For UN 3555 (liquid desensitized explosives).
P912: For battery-powered vehicles (UN 3556, 3557, 3558).
Tank Special Provisions:
TP42: Prohibits portable tanks for highly reactive substances like cesium/rubidium dispersions.
Shipping Documentation Requirements
Expanded Battery Marking Labels: Sodium-ion batteries are now subject to the Lithium Battery Mark and Class 9 label requirements, necessitating updates to packaging designs.
Enhanced Documentation for Carbon Products: Transport documents must include the date of production, date of packaging, and temperature of the material at packaging.
New Exemption Certificates: Goods granted exemptions must include corresponding certificates, as mandated by new Section 5.4.4.2.
Packing Structure and Testing
Updates align with the latest ISO/national standards and testing methods.
Transport Operations and Segregation Requirements
New Stowage Code: SW31: Requires specific substances emitting flammable gases when in contact with water to maintain safe distances from ignition sources.
Carbon Stowage Requirements: Carbon is now included in Class 4 stowage and handling provisions, emphasizing fire prevention and ventilation.
Key Takeaways for Companies
IMDG Code Amendment 42-24 introduces stricter requirements for batteries, vehicles, carbon materials, and documentation.
Companies should prioritize the following:
Transition Period: Use 2025 to upgrade systems, train staff, and review product lines.
Mandatory Compliance: Ensure readiness by January 1, 2026, to avoid compliance risks.
Proactive preparation will ensure safe and compliant maritime operations under the updated IMDG Code.
For more information and inquiries, please feel free to contact us at customer@reach24h.com.
