Charcoal shipment in packaged form – revised IMO regulations coming in...

Charcoal shipment in packaged form – revised IMO regulations coming into voluntary application on 1 January 2025

Published: 16 December 2024

The whole supply chain for charcoal cargoes leading up to sea transportation is about to change with the onset of amendments agreed at the International Maritime Organization (IMO). This will bring about major changes to how charcoal must be safely packed for sea transport in packaged form including containers, as well as ensuring safer transportation through improved packaging and stowage provisions and requiring mandatory dangerous goods transport documentation.

Due to the many container fire incidents with the shipment of charcoal that have been brought to the attention of the International Maritime Organization (IMO), as well as misdeclaration by shippers, new regulations affecting the shipment of charcoal under the International Maritime Dangerous Goods Code (IMDG) have now been finally adopted as part of Amendment 42-24.

The new regulations follow more than five years of intense discussion and debate at the IMO meetings in which BIMCO has actively participated. We are extremely pleased with the outcome.

One of the major changes is that charcoal shipments in packaged form included in containers will no longer be given exemptions to be shipped as non-dangerous goods under the IMDG Code even if the charcoal shipment has passed the UN N4 test for self-heating (IMO class 4.2 dangerous goods, ie, substances liable to spontaneous combustion).

Another change is the requirement for weathering and temperature controls required when packing and also during the voyage. Additional information is also required for the dangerous goods transport documentation when shipping such cargoes.

For full details of the charcoal amendments, please refer to our BIMCO cargo section (accessible only to BIMCO members “Charcoal -upcoming IMDG Code regulations about to make major impact on whole supply chain” for guidance.

Subsequent to the amendments made, CINS (Cargo Incident Notification System), together with the International Group of P&I Clubs and TT Club, has issued revised guidelines on the safe carriage of charcoal in containers incorporating these amendments.

As part of Amendment 42-24 to the IMDG Code, the charcoal amendments will come into voluntary application on 1 January 2025 and will enter into mandatory force on 1 January 2026.

Please note that these changes do not affect charcoal that is shipped in solid bulk form under the International Maritime Solid Bulk Cargoes (IMSBC) Code. Please also note that charcoal that is classed as 4.2 is not permitted to be shipped in bulk under the IMSBC Code. Please refer to our BIMCO cargo section for the requirements of charcoal shipped under the IMSBC Code.

We strongly recommend you ensure that your relevant stakeholders are informed and prepared for these changes.

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