IMDG Amendment 42-24 Is Mandatory from 1 January 2026: What Changed for Ocean Freight from China
· regulatory update · HANGRUI HOLDINGS LIMITED
The short answer: Since 1 January 2026, the IMDG Code’s 2024 Edition — Amendment 42-24 — is the mandatory edition worldwide, after twelve months of voluntary application. If you ship dangerous goods by sea from China, the immediate tasks are to confirm which edition your SDS and dangerous-goods declaration cite, and to re-check stowage and classification for the cargo types that changed. Documents that cleared in 2025 are not automatically correct in 2026.
The legal basis
The IMDG Code is not a voluntary industry standard. It applies under chapter VII of the SOLAS Convention, which makes compliance mandatory for ships carrying dangerous goods in packaged form, with MARPOL Annex III extending the same framework to marine pollutants (IMO, IMDG Code).
The Code is amended on a two-year cycle. Amendment 42-24 was adopted by IMO Resolution MSC.556(108) in May 2024; it was published for voluntary use from 1 January 2025 and became mandatory on 1 January 2026, replacing the 2022 Edition (Amendment 41-22). The parallel emergency-response guide was updated as well — the EmS Guide revision MSC.1/Circ.1588/Rev.3 supersedes the previous version (Britannia P&I, Dec 2025).
What changed in substance
| Area | Change under Amendment 42-24 |
|---|---|
| Battery-powered vehicles | Lithium-ion battery powered vehicles → UN 3556, lithium-metal battery powered → UN 3557, sodium-ion battery powered → UN 3558. The former generic entry UN 3171 no longer covers these |
| Sodium-ion batteries | New entries UN 3551 (batteries) and UN 3552 (contained in / packed with equipment), with full dangerous-goods documentation |
| Battery energy storage (UN 3536) | Stowage category changed to D — on deck only, prohibited on passenger ships |
| Other stowage moves | UN 3129, UN 3130 and UN 3148 also reclassified to stowage category D (on deck only, prohibited on passenger ships) |
| Carbon entries (UN 1361, UN 1362) | Previous special provisions deleted, new special provision SP 978 replacing SP 925; carbon of animal or vegetable origin now requires segregation from class 5.1 oxidisers |
| Documentation | Where a detailed stowage plan is used instead of a special list or manifest, it must now identify the primary and subsidiary hazard classes as well as locations; revised documentation requirements under 5.4.4.2 are referenced by a set of special provisions |
| Exemptions | New special provision SP 375 clarifies when UN 3077 / UN 3082 are exempt below 5 kg or 5 L even if not declared as marine pollutants — with documentation to prove the exemption where claimed |
Summaries of changes are published by classification-society and industry providers; the authoritative text remains the Code itself (NCB Hazcheck summary of changes).
Why this matters specifically for shipments booked out of China
- The edition reference is a document check. If your SDS Section 14 or your dangerous-goods declaration still cites IMDG 41-22 or an earlier edition, that is now a defect on its face — and port-state control has been enforcing documentation details more aggressively since the start of 2026.
- Compliance moved earlier in the process. Classification, packaging and documentation decisions are increasingly examined at booking and at the Chinese export DG yard, not only at the destination port. Fixing a classification after the container is gated in is expensive.
- The changes are not all battery-related. For chemical exporters the carbon segregation rule and the stowage-plan content requirement are the kinds of amendments that get missed precisely because they are not headline items.
What to check before your next booking
- Edition consistency. SDS, DG declaration and any stowage/special-list document should all be consistent with Amendment 42-24.
- Classification of anything battery-powered. Battery-containing machinery, vehicles and equipment now need the new UN entries; the generic entry is not a fallback.
- Stowage category. For the entries moved to category D, expect on-deck-only allocation — which affects space, cost and, for passenger-cargo routes, availability.
- Stowage plan content. If a detailed stowage plan is used, it must identify hazard classes.
- Special provisions in writing. Where an exemption is claimed, provide the certificate or documentation that supports it.
- Qualified people, current edition. Classification is a professional judgement made against the Code as amended. This article is a summary, not a classification service.
Sources
- IMO, The International Maritime Dangerous Goods (IMDG) Code — imo.org
- Britannia P&I, “International Maritime Dangerous Goods (IMDG) Code Amendment 42-24” (Dec 2025) — britanniapandi.com
- NCB Hazcheck, “IMDG Code A42-24 — free summary of changes” — hazcheck.com
For general information only — not legal or regulatory advice. Dangerous-goods classification must be confirmed with qualified personnel against the current edition of the IMDG Code and the requirements of the carrier, the port and the competent authority.
Tell us the product and the market — we route you to the right member company. info@hangr.hk