The international transport of dangerous goods by sea is preparing for another significant regulatory update. The International Maritime Organization (IMO) has adopted IMDG Code Amendment 43-26 to the International Maritime Dangerous Goods (IMDG) Code, introducing changes that will affect shipping companies, freight forwarders, manufacturers, container packing facilities and businesses involved in preparing dangerous goods for maritime transport. The revised Code may be applied voluntarily from 1 January 2027, subject to the decisions of the relevant maritime administrations, and becomes mandatory on 1 January 2028. Until then, Amendment 42-24 remains the mandatory edition, having entered into force on 1 January 2026.
The latest revision reflects developments within the shipping industry, particularly the increasing movement of lithium batteries, electric vehicles, sodium-ion battery systems and other products associated with the energy transition. It also introduces changes concerning explosives, radioactive materials, chemical substances and emergency response arrangements.
For companies involved in international logistics, the amendments deserve attention well before they become mandatory. Incorrect classification, unsuitable packaging or inaccurate transport documentation can result in shipments being refused, delayed or handled under inappropriate safety conditions. Early preparation allows businesses to identify relevant changes without disrupting their everyday operations.
New Requirements for Lithium Batteries and Sodium-Ion Battery Systems
Battery technology is one of the most important areas addressed by Amendment 43-26. The rapid development of electric vehicles, energy storage installations and industrial battery systems has introduced products that do not always fit comfortably within transport provisions originally developed for smaller batteries and conventional equipment.
The revised Code introduces new UN entries for certain lithium and sodium-ion battery systems, allowing a more precise distinction between different technologies and transport configurations. This is particularly important for batteries installed in cargo transport units, where the energy capacity and potential consequences of thermal runaway may be substantially greater than those associated with ordinary consumer batteries. Lithium-ion batteries can present serious hazards if damaged, incorrectly manufactured or exposed to conditions that cause overheating. Thermal runaway may produce intense heat, flammable gases and fires that are difficult to control. Such incidents are especially concerning aboard ships, where access to containers may be limited and emergency intervention can be complicated by the vessel’s location and cargo arrangement.
Sodium-ion technology is also receiving increasing regulatory attention. Although sodium-ion batteries generally use different chemistry from lithium-ion batteries, they may still present electrical, thermal and fire-related hazards during transport. They must therefore be classified according to their actual characteristics and the applicable transport provisions.
For manufacturers and consignors, the important question is whether existing classifications remain appropriate. Companies should examine their battery specifications, test documentation, packaging arrangements and the intended configuration of the shipment. The distinction between batteries transported separately, batteries installed in equipment and battery systems installed in cargo transport units can have significant consequences for regulatory compliance. Businesses should not assume that all battery products fall under the same transport requirements simply because they share similar commercial applications.
Electric Vehicles and New Vehicle Safety Assessments
The maritime transport of electric vehicles has attracted increasing attention following incidents involving vehicle carriers and other cargo ships. Although electric vehicles are not inherently unsuitable for maritime transport, the characteristics of their battery systems require careful consideration when assessing potential fire risks and emergency response arrangements.
IMDG Code Amendment 43-26 introduces clearer provisions concerning the transport of vehicles, including electric vehicles. These changes include revisions to Special Provisions 961 and 962 and the introduction of Special Provision 980, addressing vehicle safety assessment. The amendments are intended to provide a more structured regulatory approach to determining the conditions under which vehicles may be transported. Vehicle design, condition, installed energy systems and relevant safety characteristics can influence the appropriate transport arrangements.
For vehicle manufacturers, exporters, logistics providers and shipping lines, this creates an additional reason to review the information exchanged before accepting vehicles for shipment. Accurate identification of the vehicle type and its propulsion system is important, particularly where the transport requirements depend on specific technical conditions.
Special attention should also be given to damaged, defective or otherwise compromised vehicles. A vehicle that has experienced a collision, battery damage or an electrical malfunction may present risks different from those associated with a vehicle in normal operating condition.
Companies involved in transporting vehicles should review their acceptance procedures and determine whether additional technical information or revised internal instructions will be necessary under the new provisions.
The amendments do not mean that every electric vehicle automatically requires the same dangerous goods documentation or handling arrangements. The applicable requirements depend on the relevant classification and special provisions.
IMDG Awareness Training for Employees
Regulatory changes can only be implemented effectively when employees understand how dangerous goods requirements affect their daily responsibilities. Personnel preparing shipments, checking documentation, handling containers or arranging maritime transport need appropriate knowledge of the IMDG Code 43-26.
SafetyNet Academy offers an English-language IMDG Awareness E-learning course covering dangerous goods classifications, hazard recognition and essential maritime transport requirements. The online training is suitable for employees who need a general understanding of the IMDG Code and their responsibilities within the transport chain.
The course can be followed online, making it accessible to individual participants and companies with employees working at different locations.
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IMDG Code Amendment 43-26: Changes to Segregation, Dangerous Goods Information and Emergency Procedures
The IMDG Code contains detailed provisions intended to prevent incompatible dangerous goods from creating additional hazards during transport. Segregation requirements are particularly important because containers carrying different substances may be stored close to one another aboard a vessel, sometimes for extended periods.
Amendment 43-26 includes updated segregation distances for radioactive cargo. These provisions are relevant to operators handling Class 7 materials and organisations responsible for planning their stowage aboard ships.
Segregation decisions must be based on the actual dangerous goods involved and the requirements applicable to the shipment. General assumptions about compatibility can be misleading, especially when substances have subsidiary hazards or specific segregation provisions.
The amendments also introduce changes affecting explosives, chemical substances and other dangerous cargoes. Businesses should review the Dangerous Goods List and the relevant special provisions for the UN numbers they regularly ship rather than assuming that all existing arrangements remain unchanged.
Another important development concerns the Emergency Response Procedures for Ships Carrying Dangerous Goods, commonly known as the EmS Guide. Consequential amendments accompany the revised IMDG Code to reflect changes in dangerous goods entries and applicable emergency arrangements.
The EmS Guide provides practical information to support responses to fire and spillage incidents involving dangerous goods aboard ships. While it cannot replace professional judgement or ship-specific emergency planning, it forms an important part of the information available to crews when incidents occur.
Shipping companies and operators should ensure that emergency information remains consistent with the dangerous goods actually carried. Outdated references or incorrect identification of cargo hazards can complicate an emergency at precisely the moment when reliable information is most important.
The same principle applies to shoreside personnel. Freight forwarders, consignors and container packing companies may never be physically present aboard the vessel, but the quality of the information they provide directly influences the ability of the ship’s crew to manage transport risks.
What Should Companies do Before 2028?
The introduction of a revised IMDG Code does not necessarily mean that every dangerous goods shipment will require substantial changes. For many businesses, the practical impact may be limited to particular products, updated special provisions or revised internal instructions. Nevertheless, organisations should begin by reviewing the dangerous goods they regularly transport. Particular attention should be given to lithium batteries, sodium-ion batteries, vehicles, radioactive materials and shipments involving specialised packaging or stowage requirements.
Classification records, shipping documentation, container packing instructions and operational procedures should then be checked against Amendment 43-26. Companies should also establish which edition of the Code is being applied by the relevant maritime administration and accepted by the carrier during the voluntary implementation period.
Communication between consignors, freight forwarders, shipping lines and container packing facilities is essential. A classification error introduced early in the logistics chain may not become apparent until a container reaches the terminal, potentially causing significant delays and additional costs.
Employee competence deserves equal attention. Chapter 1.3 of the IMDG Code establishes training requirements for shore-based personnel engaged in dangerous goods transport activities. Training must reflect the responsibilities performed by individual employees, while refresher training should address relevant changes in regulations and practices.
An awareness course provides an important foundation, but personnel performing specialised functions may also require additional function-specific training covering their particular responsibilities.
Improve Dangerous Goods Knowledge with SafetyNet Academy
Preparing for Amendment 43-26 provides an opportunity to strengthen dangerous goods knowledge across the organisation.
SafetyNet Academy offers a selection of English-language online courses covering maritime dangerous goods, ADR road transport, IATA air transport, chemical safety and other workplace safety subjects.
Companies can arrange training for individual employees or groups, helping teams develop a consistent understanding of safety requirements across different locations and departments.
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Preparing for the Next Generation of Maritime Dangerous Goods Transport
Amendment 43-26 reflects the changing nature of dangerous goods transported through international supply chains. Battery technology, alternative energy systems and increasingly complex cargoes require regulatory provisions that address their specific characteristics and potential hazards. For manufacturers, freight forwarders and shipping companies, the coming transition offers an opportunity to review existing arrangements and identify areas where procedures or employee knowledge need improvement.
The voluntary application IMDG Code Amendment 43-26 period beginning on 1 January 2027 gives organisations time to become familiar with the new requirements before they become mandatory on 1 January 2028. Ultimately, safe maritime transport depends on more than regulatory compliance alone. Accurate classification, suitable packaging, correct documentation, responsible container packing and properly trained personnel all contribute to preventing incidents.
Businesses that understand the changes introduced by IMDG Code Amendment 43-26 will be better equipped to maintain safe, reliable and compliant dangerous goods operations as the international shipping industry enters its next regulatory period.