From January 2026, every bag of biochar or charcoal you load for sea is classified as Dangerous Goods (DG). In reality, the change is already here: many carriers are enforcing the new IMDG 42-24 rules during 2025, and Protection & Indemnity (P&I) clubs (insurers) are encouraging early compliance. The reason is simple and sobering—charcoal fires keep starting days after loading, deep inside containers (68 fires between 2015 and 2022). The old “tested-safe” exemptions didn’t capture that reality.
The new Special Provision 978 (SP 978) is the pivot point. It shuts the door on “tested-safe” exemptions and replaces them with practical controls that every shipper must follow if they want their containers to keep moving. This applies to UN 1361 – CARBON (animal or vegetable origin), which covers charcoal and biochar, Class 4.2 (self-heating substances):
Carriers and P&I clubs increasingly demand proof of these steps—temperature logs, weathering records, vanning photos—before they even accept a booking. In short: SP 978 is now your must-do. Skip it, and your boxes won’t move.
But let’s be honest: weathering is not always possible. Humidity can ruin the product, and animal-feed biochar cannot sit in the open without risking contamination (bird flu is a real concern). In those cases, the steam-cool + inert route is the only practical option. The Code gives you both paths, but whichever one you pick, you must document it.
For UN 1362 – CARBON, ACTIVATED (activated carbon, also Class 4.2, Packing Group III), SP 979 leaves one narrow escape:
If you can’t prove it’s exempt? It’s Dangerous Goods, period.
It’s important to remember that the IMDG Code governs sea transport, while ADR (road) and RID (rail) still operate on slightly different terms. Some producers worry whether any exemptions remain inland. In fact, there are two separate clauses in ADR:
These are still in the rules, but they stop at the port. Once your container is loaded for sea, IMDG applies, and SP 978 does not allow those carve-outs anymore. The practical lesson: inland moves may look different on paper, but at the port gate, the box must be IMDG-compliant.
In simple words: ADR/RID 2025 (rail and road transport) doesn't yet mirror the IMDG “no-exemption” language. You can still see national guidance or service providers using test-based logic on the road/rail legs. But that logic stops at the port gate—where your container must present as DG with the new IMDG data. That's the bottleneck Biochar Europe members need to solve operationally: align factory, forwarder, packer, and port on a single DG story.
Another concern raised is whether bulk shipments of biochar/charcoal can continue. Here, the distinction between IMDG and IMSBC Code matters: IMDG applies to packaged goods (bags, big bags, drums, containers). IMSBC covers solid bulk cargoes. Charcoal is listed as a Group B cargo (cargoes with chemical hazards) in Annex 7 of the IMSBC.
The problem is that IMSBC also states that materials classified as Class 4.2 (self-heating) cannot be carried in bulk. In practice, that means if your biochar is Class 4.2 (as UN 1361 normally is), the IMDG restrictions apply even in bulk contexts. Some members have heard conflicting messages from shipping providers on this point. The confusion is real, and it shows the need for the industry to align on one interpretation. At present, the conservative reading is: unless you can prove non-self-heating with testing under ADR 2.2.42.1.7 (and secure recognition from a competent authority), bulk shipments of biochar at sea are extremely restricted.
There is, however, a potential regional loophole: the Baltic Sea Memorandum of Understanding, which may allow certain exemptions for biochar in that area. This has been noted in Nordic industry discussions and could be explored further. It is not a global solution, but it may be a practical one for specific regional supply chains.
If it's biochar meant to burn—briquettes, pellets, tablets—it's still UN 1361. In fact, tablets for hookah/shisha can be higher risk due to ignition aids. Don’t try to re-label them as generic “self-heating n.o.s.”—carriers and P&I clubs are watching, and the CINS guideline is explicit. That said, there is a legitimate concern that industrial briquettes with binders and lower ignition risks are being treated the same as consumer BBQ charcoal. The current IMDG text does not distinguish between them. This may be an area where the industry could work with competent authorities to demonstrate differences and argue for more tailored regulation in the future.
Amendment 42‑24 applies voluntarily from 1 January 2025 and becomes mandatory on 1 January 2026. Many carriers are enforcing early.
Treat 2025 as your rehearsal and 2026 as non-negotiable. The members who standardise now—on weathering/cooling, temperature logging, and document quality—will be the ones whose boxes keep moving when space is tight and scrutiny is high.
Authorities to approach: DG Verkehr (Germany), Swedish Transport Authority, Finnish Transport and Communications Agency, Norwegian Maritime Authority.
This change closes the biggest loophole —“testing out” of DG status for charcoal — by making safe process and packaging the heart of compliance. For producers, the cost isn’t in lab work anymore; it’s in process control and records (weathering, temperature checks, conservative packing). That’s manageable—and, for many, cheaper than repeated testing and disputes.
The upside is predictability: fewer arguments with carriers and insurers; fewer fires; faster acceptance at terminals. The friction point is mode-mismatch: ADR/RID tables haven't yet embedded SP 978-style conditions, so multimodal moves may feel uneven. The practical fix is to treat every leg like sea-mode — it's what carriers now expect and what underwriters recognise.
Q1: Are all biochar/charcoal shipments now Dangerous Goods at sea?
Yes — for UN 1361 under IMDG 42‑24. SP 978 removes use of the N.4 test to claim non‑DG status. Treat charcoal/biochar as Class 4.2, at least PG III unless otherwise directed by a competent authority.
Q2: Do I still need a lab test to ship charcoal/biochar by sea?
A: No, not to declare it. Under SP 978, charcoal/biochar ships as UN 1361 by default. The old “test-to-avoid DG” route is gone. You still have to treat the product and document what you did.
Q3: What exactly do I have to prove on the paperwork?
Your DGD (Dangerous Goods Declaration) must now include (i) date of production, (ii) date of packing, (iii) packing‑day temperature for UN 1361. If you are claiming an SP 979 exemption for UN 1362, submit the exemption certificate with the cargo information per 5.4.4.2. Carriers frequently also request a weathering certificate and a vanning survey report as part of booking—these are carrier overlays, not code text.
Q4: What does “good preparation” look like for biochar?
Follow SP 978 literally: weathering (14 days) or steam‑cooling/inert packing, confirm ≤ 40 °C at packing, keep ≥ 30 cm headspace, and respect stack height/block‑size geometry. Use CTU Code‑style packing, take thermal readings during vanning, and store the CTU away from heat.
Q5: Packaging—bags, big bags, or large packagings?
Use “P002” rules for UN 1361. That means pack charcoal/biochar in strong, sift-proof UN-approved packages (eg, sturdy bags/sacks, boxes, drums) suitable for Class 4.2. For PG III, LP02 (large packagings/big bags) is technically allowed, but many shipping lines don't accept LP02—check your carrier's policy before you pack. The old PP12 allowance (less water-resistant bags) is gone under the new amendment.
Q6: How are activated‑carbon shipments treated?
UN 1362 (CARBON, activated) can be outside the IMDG Code if steam‑activated with a shipper's certificate, or chemically activated with a recognized‑lab negative N.4 certificate — but the documentary requirement in 5.4.4.2 still applies (you must submit the exemption certificate). Without those proofs, it moves as Class 4.2, PG III.
Q7: What happens inland—on roads and rail?
ADR 2025 (road) and RID 2025 (rail) remain aligned to the UN Model Regulations for self‑heating classification: assignment can be based on experience and UN N‑tests (eg, N.4) rather than an IMDG‑specific SP. That means you may still see test‑based logic on inland legs — but the moment you hit the port gate, your CTU must present as IMDG‑compliant DG with the new UN 1361 data. Align your whole chain to the sea leg.
Q8: Do briquettes, pellets, and tablets (agglomerates) change anything?
If they're charcoal intended to burn, they're still UN 1361. Avoid re‑labeling as UN 3088 SELF‑HEATING SOLID, ORGANIC, NOS — industry guidance is explicit on this point. Note that hookah/shisha tablets often include ignition aids, lowering ignition temperature and raising risk; treat them conservatively and follow SP 978.
Q9: Where do vanning‑survey photos and temperature logs fit?
Not in the Code text for SP 978 — but carriers and P&I Clubs increasingly require a vanning survey (with photo story and temperature readings) and a weathering/cooling report at booking. Build them into the SOP; they reduce disputes and speed gate moves.
Q10: What about biochar‑based products and blends?
If the good is still essentially carbon of animal/vegetable origin produced by pyrolysis (the SP 978 definition), the UN 1361 entry applies at sea. If you've made an article or mixture where self‑heating is demonstrably not triggered and the material no longer fits the UN 1361 description, classification follows Part 2 rules (tests/experience). Expect scrutiny, keep your technical basis on file, and be ready for a carrier to require UN 1361 unless a clear case is made.
Q11: What changes for ship operations once my CTU is aboard?
Ships will seal CTUs post‑packing, take daily early‑morning hold temperature readings, and keep carbon cargoes away from heat. If temperatures rise excessively, ventilation may be restricted and water considered per the Code's explicit instructions. This is why your upstream controls matter.
About
📑 Official Documents & Resources
📑 Official Documents & Resources