IMDG Code Amendment 42-24 (2024 Edition) introduced major changes for transporting charcoal by sea under UN 1361 (Carbon, animal or vegetable origin) and UN 1362 (Carbon, activated).

These changes came in voluntarily from January 1, 2025, and will become mandatory from January 1, 2026. Basically, old exceptions, like special Provisions SP223 and SP925 that let some charcoal ship without full dangerous goods rules are removed.

Now, new Special Provisions SP978 (for UN 1361) and SP979 (for UN 1362) apply to ensure enhanced safety during transport.

Why did these changes take place? It’s all about safety after various fires. Between 2015 and 2022, there were at least 68 reported container fires linked to charcoal, often starting days after loading due to self-heating.

SP 978 New Special Provision for UN 1361

Special Provision 978 applies to charcoal/carbon from animal or vegetable sources. It removes exemptions and sets clear rules on classification, packing, and stowage to prevent self-heating fires.         

• SP 978.1 Covers charcoal made from bone, bamboo, coconut shell, jute, wood, or similar natural materials via carbonization (heating without air).
• SP 978.2 No exemptions from IMDG Code allowed, even if it passes UN Manual of Tests and Criteria for self-heating; must always follow dangerous goods rules.
• SP 978. Assigns packing group based on a screening test: PG II or PG.
• SP 978.4 Requires weathering: after production, the unpacked charcoal must be subject to weathering (stored under cover, but in the open air) for a minimum period of 14 days before being packaged for transport, or
• after pyrolysis, steam and cooling must be applied to the unpacked charcoal and the charcoal must be packed under an inert gas atmosphere (e.g. nitrogen); packages must then be stored under loose cover or in the open air for a minimum of 24 hours before transport. (Unless approved by competent authority).
• SP 978.5 Temperature during packing: Must only be packed into packagings when the temperature of the charcoal does not exceed 40 Degrees C on the day of packing.
• SP 978.6 Stowage in CTUs: 30 cm Headspace must be maintained; and stowage height of the package(s) in the unit should not exceed 1.5 m or maximum block size of the packages should be 16 m3 and a minimum of 15 cm of space between blocks should be maintained

SP 979 New Special Provision for UN 1362

SP979 applies to activated carbon (treated to increase surface area). It keeps some exemptions but adds documentation and clarifies conditions.

• SP 979.1 Exempt from most IMDG provisions (documentation mentioned in 5.4.4.2 of IMDG Code is mandatory) if steam-activated and shipper certifies it’s not self-heating under UN tests, or,
• SP 979.2 exempt if chemically activated, accompanied by a certificate issued by a laboratory recognized by the competent authority, stating that the substance does not meet the criteria for class 4.2 based on a negative test result for self-heating substances when tested in accordance with the UN Manual of Tests and Criteria (see 33.4.6).

Full text of SP 978 & SP 979

Further readings

• CINS-Charcoal-Guidance-Final-Version-September-2024.pdf
• Updated IMDG Code requirements for the carriage of charcoal, by Dr. Jim Mercurio