Special Provisions 961 & 962: When a Vehicle Is Exempt — and When It’s Class 9
A working guide to shipping vehicles by sea under IMDG Code Amendment 42-24 — with a side-by-side comparison and a step-by-step compliance check you can run against any vehicle before it’s loaded.
SP 961 and SP 962 govern how vehicles — cars, trucks, machinery — are shipped as cargo, and they work as a single decision: 961 tests whether a vehicle can skip the IMDG Code almost entirely; 962 is the fallback that applies the moment 961 isn’t met. Get the sequence right and most conventionally‑fuelled and battery vehicles move without full DG documentation. Get it wrong, and an undeclared vehicle with a full tank ends up misdeclared as general cargo.
SP961 (exempt) vs. SP962 (Class 9)
SP 961
- Vehicle is exempt from almost all of the IMDG Code — except P912, SP388 and SP977 where they apply.
- Exemption is earned by meeting any one of six standalone conditions (961.1–961.6) — stowage location, or a fuel/battery-specific condition.
- No marking, labelling or placarding required.
SP 962
- Applies automatically when a vehicle meets none of the SP961 conditions.
- Assigned to Class 9; must satisfy four requirements (962.1–962.4) covering leaks, fuel limits, valve closure and battery protection.
- Marking/labelling/placarding required only if the vehicle is enclosed (crated, overpacked) so it can’t be visually identified.
SP961 — six ways to qualify for exemption
Only one of the six needs to be satisfied. 961.1 is stowage-based and fuel-agnostic; 961.2–961.6 are fuel- or battery-specific and apply wherever the vehicle is stowed.
| Clause | Applies to | Condition to be met |
|---|---|---|
| 961.1 | Any vehicle, any fuel type | Stowed in a dedicated vehicle / special-category / ro-ro space, or the weather deck of a ro-ro ship, or a space designated under SOLAS II-2/Reg. 20 — and no visible leaks from battery, engine, fuel cell, gas cylinder, accumulator or fuel tank. Does not apply to a vehicle inside a CTU in a container cargo space of a ro-ro ship. |
| 961.2 | Flammable liquid fuel, flashpoint ≥ 38°C | No leaks in the fuel system · fuel tank(s) hold 450 L or less · installed batteries protected from short-circuit. |
| 961.3 | Flammable liquid fuel, flashpoint < 38°C | Fuel tank(s) empty — drained so the vehicle cannot run. Fuel lines, filters and injectors do not need to be cleaned or purged. Batteries protected from short-circuit. |
| 961.4 | Flammable gas fuel (liquefied or compressed) | Fuel tank(s) empty, positive pressure ≤ 2 bar · fuel shut-off/isolation valve closed and secured · batteries protected from short-circuit. |
| 961.5 | Wet/dry electric storage battery, or sodium battery, as the sole power source | Battery protected from short-circuit. |
| 961.6 | Sodium-ion battery as the sole power source | Battery short-circuited so it holds no electrical energy, using an easily identifiable method (e.g. a busbar across the terminals). |
SP962 — the Class 9 fallback requirements
All applicable clauses below must be met together — this is a cumulative checklist, not a choice of one.
| Clause | Applies to | Requirement |
|---|---|---|
| 962.1 | Every vehicle under SP962 | No visible leaks from batteries, engines, fuel cells, compressed gas cylinders, accumulators, or fuel tank(s), where applicable. |
| 962.2 | Flammable liquid-powered vehicles | Fuel tank(s) no more than ¼ full, and total flammable liquid on board does not exceed 250 L — unless the competent authority approves otherwise. |
| 962.3 | Flammable gas-powered vehicles | Fuel shut-off valve of the fuel tank(s) securely closed. |
| 962.4 | Vehicles with installed batteries | Batteries meet SP388 or SP977 as applicable, and are protected against damage, short-circuit and accidental activation. |
Which UN entry are you actually shipping?
SP961/962 sit on five UN entries. Confirm the correct one first — it determines which extra provisions survive the SP961 exemption.
| UN No. | Proper shipping name | Also carries |
|---|---|---|
| 3166 | Vehicle, flammable gas/liquid powered — or fuel-cell powered (gas or liquid) | SP356 (metal hydride storage systems), SP388 (classification rule) |
| 3171 | Battery-powered vehicle or battery-powered equipment (wet, sodium, or sodium-alloy battery) | SP388, SP971 — the equipment half of this entry uses SP971, not SP961/962: no leaks + short-circuit protection is enough on its own. |
| 3556 | Vehicle, lithium ion battery powered | SP384, SP388, SP405, P912 (packing instruction, when the vehicle is packaged rather than driven aboard) — always Class 9 unless 961.1 stowage applies; no battery-specific exemption exists. |
| 3557 | Vehicle, lithium metal battery powered | SP384, SP388, SP405, P912 — always Class 9 unless 961.1 stowage applies; no battery-specific exemption exists. |
| 3558 | Vehicle, sodium ion battery powered | SP384, SP388, SP404 (near-duplicate of 961.6, sodium-ion short-circuit), SP405, SP977, P912 |
- SP388 — the classification rule: confirms which of the five UN entries above applies, and requires installed lithium batteries to meet §2.9.4 (a damaged or defective battery must be removed and shipped under SP376).
- SP977 — sodium-ion batteries must meet §2.9.5 (the sodium equivalent of §2.9.4).
- P912 — only relevant to UN 3556/3557/3558 when the vehicle itself is packaged (crated, palletized, or braced unpackaged) rather than driven or rolled aboard — e.g. wheelchairs, mobility scooters, lawn tractors.
Check a vehicle against SP961 / SP962
Answer for one vehicle at a time. The tool walks through 961.1, then the fuel/battery-specific clause, and drops into the SP962 checklist automatically if the vehicle doesn’t qualify for exemption.
1. Any signs of leakage right now?
From the battery, engine, fuel cell, compressed gas cylinder, accumulator, or fuel tank — check applicable sources for this vehicle.
2. What powers this vehicle?
3. Is the battery damaged, defective, or untested (fails UN 38.3 / §2.9.4 / §2.9.5)?
Includes: known leaking/venting cells, physical or mechanical damage, a failed or inconclusive UN 38.3 test, or a battery that cannot be diagnosed prior to transport.
4. Where will the vehicle be stowed?
5. Does it meet the condition for that power source?
6. Does it meet the SP962 fallback requirement?
Do not load until the leak is fixed
Both SP961 (961.1) and SP962 (962.1) require no visible leaks before a vehicle qualifies for either pathway. Repair or address the leak, then re-check.
Remove the battery and ship it separately under SP376
SP388 requires that a damaged or defective lithium battery installed in a vehicle be removed and transported under SP376, unless the competent authority approves otherwise — this applies regardless of stowage location. A vehicle that would otherwise qualify for the 961.1 stowage exemption still cannot use it while a damaged/defective battery remains installed.
- Remove the battery; reclassify it under UN 3090/3091 (lithium metal) or UN 3480/3481 (lithium ion), as applicable.
- Pack per P908 or, if liable to rapid disassembly/dangerous reaction/flame/heat/toxic emission, P911 (or LP904/LP906 for large batteries).
- Mark the package “DAMAGED/DEFECTIVE”; transport document must state “Transport in accordance with special provision 376.”
- If the competent authority has approved alternative conditions, a copy of that approval must accompany the transport.
Treat as SP376, but confirm with your competent authority
SP388’s damage/defective removal clause is written for lithium batteries specifically — SP977 (sodium-ion) doesn’t repeat it for vehicles. SP376 itself does list damaged/defective sodium-ion cells and batteries within its own scope, so removing the battery and shipping it separately under SP376 is the safer reading. This isn’t an explicit vehicle-specific requirement the way it is for UN 3556/3557, so get this confirmed before proceeding either way.
Ships as a vehicle, not as dangerous goods
Correct stowage location with no visible leaks satisfies 961.1 on its own — no fuel-type check is needed.
- No marking, labelling or placarding required.
Ships as a vehicle, not as dangerous goods
This vehicle meets the condition for its power source, so it qualifies for exemption under SP961 even though it isn’t stowed in a dedicated vehicle space.
- No marking, labelling or placarding required.
Ships under Class 9, per SP962
The vehicle doesn’t qualify for the SP961 exemption, but it meets the SP962 fallback requirement for its power source (plus 962.1, no leaks).
Marking/labelling/placarding apply only if the vehicle is fully enclosed (crated/overpacked).
Neither SP961 nor SP962 conditions are met
Options: bring the vehicle within the SP962 limit stated above, or seek competent authority approval where the provision allows it.
Need this checked at fleet or terminal scale?
SKSC runs SP961/962 classification reviews and function-specific IMDG training for shippers, freight forwarders and vessel operators.
Talk to Shashi Kallada →Discover more from IMDG Code Compliance Centre
Subscribe to get the latest posts sent to your email.