Comprehensive Analysis of the IMDG Code Amendment 42-24

As stipulated in Resolution MSC.556(108) adopted by the International Maritime Organization (IMO), the 42-24 Amendment to the International Maritime Dangerous Goods Code (IMDG Code) will formally enter into force mandatorily in China on January 1, 2026. This amendment introduces significant revisions to multiple provisions, directly impacting the compliant operations of ships, shipping companies, agents, terminals, and shippers.

 

I.Battery-Powered Vehicles: Refined Classification + Enhanced Regulation

(1)Optimized Entry Classification

The new version of the Code has meticulously restructured the classification of battery-powered vehicles, with specific adjustments as follows:

Revised UN3171: Defined as "Battery-powered vehicles or equipment", applicable only to vehicles and equipment driven by wet batteries, sodium metal batteries, or sodium alloy batteries when transported with batteries installed;

New UN3556: Vehicles, lithium-ion battery-powered;

New UN3557: Vehicles, lithium metal battery-powered;

New UN3558: Vehicles, organic sodium-ion battery-powered.

(2)New Special Provisions

SP404 (New): For vehicles powered by sodium-ion batteries and containing no other dangerous goods, if the battery has no residual electrical energy due to short circuit and the short-circuit status is easily verifiable (e.g., a busbar between terminals), the vehicle is exempt from other provisions of the IMDG Code;

SP405 (New): This provision establishes detailed exemption conditions and technical requirements for vehicles powered by lithium-ion, lithium metal, or sodium-ion batteries. When the vehicle is not fully enclosed, certain marking requirements may be exempted, provided the following strict conditions are met: the vehicle must remain visible and identifiable; the battery system must be in an absolutely safe state; the vehicle must be secured with reliable fixtures to prevent movement or tipping during transportation.

(3)New Packing Instruction P912

Scope of Application: Explicitly applies to vehicles under UN3556, UN3557, and UN3558;

General Requirements:

Outer packaging must be made of suitable materials with sufficient strength and rigidity;

Packaging design must consider the intended service environment and transportation conditions;

Must effectively prevent accidental operation or activation during transportation;

Special Provisions for Heavy Vehicles (Net weight exceeding 30 kg): The new regulations provide three optional solutions:

Loading in crates or securing on pallets;

Unpackaged transportation under specific conditions;

Equipping tilt-prone vehicles with specialized anti-tipping devices. 

 

II.Sodium-Ion Batteries: New Specifications + Full-Process Control

(1)New Entry Classification

UN3551: Sodium-ion batteries with organic electrolytes;

UN3552: Sodium-ion batteries installed in or packed with equipment.

(2)New Requirements in Chapter 2.9.5 (Sodium-Ion Batteries)

Test Verification: Each cell or battery pack model must pass all tests specified in Section 38.3 of Part III of the Manual of Tests and Criteria (i.e., UN38.3 Tests);

Safety Vent Design: Each cell and battery pack must be equipped with a safety vent device or designed to avoid sudden rupture under normal transportation conditions;

Short-Circuit Protection: Each cell and battery pack must be fitted with effective devices to prevent external short circuits;

Reverse Current Protection: Battery packs containing multiple parallel cells or cell series must be equipped with effective devices (e.g., diodes, fuses) to prevent hazards caused by reverse current;

Production Management: The production of cells and battery packs must comply with the quality management system requirements specified in 2.9.4;

Test Documentation: Manufacturers and subsequent distributors of cells or battery packs must provide a test summary as stipulated in Paragraph 38.3.5 of Section 38.3, Part III of the Manual of Tests and Criteria, with reference to the Safety Technical Requirements for Lithium Batteries Carried by Ships (JT/T 1543-2025).

(3)New Special Provisions

SP400 (New): Sodium-ion batteries are exempt from other Code provisions if they meet the following conditions:

1.The battery is short-circuited with no residual electrical energy, and the short-circuit status is easily verifiable;

2.The battery complies with the requirements of 2.9.5.1, 2.9.5.2, 2.9.5.4, 2.9.5.5, and 2.9.5.6;

3.Packages are marked in accordance with 5.2.1.10, with a minimum marking size of 100mm, including the "Lithium or sodium-ion battery mark" and a space for the UN number;

4.Packages pass a 1.2-meter drop test without damaging the internal cells or battery packs;

5.If the battery is installed in equipment, the equipment must be packed in a robust outer package, unless the equipment itself provides equivalent protection;

6.Each battery (including those as components of a battery pack) may only contain dangerous goods permitted for transport under Chapter 3.4, and the quantity of dangerous goods shall not exceed the limit specified in Column 7a of the Dangerous Goods List in Chapter 3.2.

SP401 (New): Sodium-ion batteries and battery packs with organic electrolytes shall be transported under UN3551 or UN3552 as appropriate; sodium-ion batteries with aqueous alkaline electrolytes shall be transported under UN2795 (Batteries, wet, alkaline, charged).

 

III.Carbonaceous Goods: Strengthened Safety + Detailed Control

(1)Clear Entry Classification

Under the IMDG Code, carbonaceous goods are categorized into three entries:

UN1361: Carbon, animal or vegetable origin (Packing Group II);

UN1361: Carbon, animal or vegetable origin (Packing Group III);

UN1362: Carbon, activated.

(2)Adjustments to Special Provisions

This amendment deletes the original Special Provisions SP925 and SP223, and adds SP978 for UN1361 and SP979 for UN1362, with specific requirements as follows:

SP978 (New, applicable to UN1361):

1.Test Exemption: The self-heating substances test (UN.N4 Test) is not applicable for exemptions of UN1361;

2.Packaging Requirements: Unverified carbonaceous goods must use packaging materials meeting at least Packing Group III standards;

3.Loading Requirements: To ensure adequate heat dissipation in containers, a minimum top clearance of 30cm must be reserved; the stacking height of packages shall not exceed 1.5m, or the stack volume shall not exceed 16m³, with a minimum spacing of 15cm between stacks;

4.Temperature Control: The temperature of carbonaceous goods shall not exceed 40°C on the day of packaging;

5.Weathering Treatment: Unpackaged carbonaceous goods after production must undergo outdoor weathering for at least 14 days before packaging and transportation; for unpackaged goods subjected to pyrolysis, steam treatment, cooling, and packaging under inert gas (e.g., nitrogen), the packages shall be stored under loose covers or left outdoors for at least 24 days before transportation.

SP979 (New, applicable to UN1362):

Exemption conditions for activated carbon:

1.The substance is accompanied by a certificate from the shipper certifying it as steam-activated carbon;

2.The substance is chemically activated carbon, accompanied by a certificate from a laboratory recognized by the competent authority, verifying that the substance does not meet Class 4.2 criteria as the self-heating test result is negative when tested in accordance with the UN Manual of Tests and Criteria (see 33.4.6).

 

IV.Marine Pollutants: Clarified Exemptions + Defined Boundaries

The 42-24 Amendment makes significant revisions to UN3077 and UN3082 (classified as marine pollutants) by adding a new special provision to clarify the exemption conditions for the maritime transport of marine pollutants in small packages.

New SP375: When marine pollutants under UN3077 and UN3082 are transported in small packages (liquids: net quantity ≤5L per single or inner package; solids: net mass ≤5kg per single or inner package), they are exempt from other provisions of the IMDG Code, provided the packages comply with the general packaging requirements specified in 4.1.1.1, 4.1.1.2, and 4.1.1.4 to 4.1.1.8.

 

 

END

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