Shipping Charcoal Briquettes: Dangerous Goods Rules Explained
Charcoal can heat itself and ignite during sea transport, so it is regulated under the IMDG Code. Since Amendment 42-24 became mandatory on 1 January 2026, the Code's UN 1361 entry no longer allows a self-heating test to exempt carbon of vegetable origin, and Special Provision 978 sets preparation, packing and stowage conditions. Exporters should still obtain written, shipment-specific confirmation from their forwarder or a dangerous goods professional before booking.
Important limits of this article. This is general information, not a classification decision or shipping clearance. Rules differ by transport mode, destination, carrier and edition of the regulations. Regulations were checked on 22 October 2026. A product's final classification and documentation must be confirmed by the shipper with a qualified dangerous goods professional.
Why does charcoal present a transport risk?
Charcoal is porous and can oxidise slowly in air. Inside a packed container, heat from that oxidation can build up faster than it escapes, and the cargo can self-heat and ignite. The Cargo Incident Notification System (CINS) recorded at least 68 fire incidents on board ships between January 2015 and December 2022, and most were caused by misdeclared cargo, so the carrier was unaware of the hazard (TT Club). Burgoynes, a firm that investigates cargo fires, states that it has encountered cargoes reported as exempt that still caught fire (Burgoynes).
What changed in the IMDG Code with Amendment 42-24?
IMO adopted Amendment 42-24 in May 2024 (Resolution MSC.556(108)). It could be applied voluntarily from 1 January 2025 and became mandatory on 1 January 2026 (Britannia P&I Club). For UN 1361 "Carbon, animal or vegetable origin", Special Provisions 223 and 925, which allowed exemptions, no longer apply to charcoal, and Special Provision 978 replaced them (Burgoynes).
Another amendment, 43-26, was adopted at MSC 111 in May 2026 (conference presentation). This research did not confirm whether it changes the requirements for UN 1361, and its application dates should be checked with the forwarder.
What does Special Provision 978 say?
The text reproduced by Burgoynes states, in summary (Burgoynes):
- Carbon of animal or vegetable origin means carbon produced in a manufacturing process, not formed geologically and not mined, and covers carbon made by pyrolysis of organic material such as bone, bamboo, coconut shell, jute or wood.
- The UN N.4 self-heating test must not be used to exempt the material from the Code.
- Without testing, the material is assigned to at least packing group III.
- Unless the competent authority approves otherwise, the unpacked material must be weathered (stored under cover but in open air) for at least 14 days before packaging, or, after pyrolysis, be treated with steam and cooling, packed under inert gas, and stored under loose cover or in the open for at least 24 hours before transport.
- The material may be packed only when its temperature does not exceed 40 °C on the day of packing.
- In a cargo transport unit, 30 cm of headspace must be kept, with a stowage height of no more than 1.5 m, or blocks of no more than 16 m³ with at least 15 cm between blocks.
Treat this as a summary. Use the official text of the IMDG Code edition in force for the final wording.
How is a general product description different from a formal classification?
Trade names such as "shisha charcoal", "coconut briquettes" or "natural charcoal" are not transport classifications. The IMDG entry is UN 1361, proper shipping name "CARBON, animal or vegetable origin", Class 4.2, listed with packing groups II and III (Britannia P&I Club). Activated carbon has a separate entry, UN 1362, and Amendment 42-24 introduced a separate Special Provision 979 for it (Britannia P&I Club). Britannia's guidance warns that carbonised material intended for manufacturing activated carbon has been misdeclared.
CINS also notes that other technical types of charcoal, such as art materials, have a different risk profile, and urges carriers to apply due diligence (TT Club). Briquettes that look similar may therefore not receive the same treatment. The exporter must classify the actual material, and a dangerous goods specialist should confirm the decision.
What changes with the transport mode?
The IMDG Code applies to sea transport. Air, road and rail transport are governed by other regulations, such as the ICAO Technical Instructions and IATA Dangerous Goods Regulations for air, and national or regional rules for inland transport. This research verified only the maritime requirements. Do not apply maritime provisions to other modes, and ask the forwarder to check the current rules for each leg.
Do carriers add their own requirements?
Yes. Carrier policies can be stricter than the Code. Examples from public carrier notices:
- CMA CGM stated that it would accept charcoal only from approved shippers from 1 June 2025 (CMA CGM).
- MSC stated that it would enforce the IMDG requirements on a mandatory basis from 1 November 2025 (MSC).
- A Maersk advisory (hosted on its Namibia export page) says that from 1 October 2025 it accepts charcoal only as dangerous goods from pre-audited shippers, requires a weathering certificate and vanning certificate from nominated surveyors, requires a thermal jacket in each unit, and does not accept shisha or hookah charcoal from certain origins (Maersk advisory).
These are examples, not universal rules. Requirements can differ by carrier, trade lane and date. Burgoynes notes that a weathering report and a vanning survey are not Code requirements but may be requested by carriers (Burgoynes).
What role do tests and documents play?
Under Special Provision 978, the N.4 test cannot exempt the cargo. It may still be relevant to packing group assignment, and a dangerous goods specialist can advise whether your shipment needs it. The packing group, the documents and any evidence the carrier requests depend on the product and shipment, so do not assume a single test report is enough. Typical items include a dangerous goods declaration, a safety data sheet, and the weathering and vanning records that carriers request, as in the Maersk example above.
flowchart TD
A[Product defined: raw material, binder, process] --> B[Classification decision with DG professional]
B --> C[Check regulations for each transport mode and the edition in force]
C --> D[Check carrier rules and shipper approval]
D --> E[Prepare product: weathering or approved alternative, temperature at packing]
E --> F[Packaging, marking, labelling, documents]
F --> G[Written confirmation from forwarder or DG professional]
G --> H[Book and pack]
What information should you give your forwarder?
- Exact product name, shape, raw material, binder and manufacturing process
- Production date, packing date and the measured product temperature at packing
- Whether weathering or the alternative treatment was used, with dates
- Any laboratory tests performed, with reports
- Packaging type and UN packaging marking, quantity per package and total quantity
- Container type and planned stowage, including headspace and stack arrangement
- Origin, destination, ports, transport modes and shipping line
Pre-booking checklist
- Product description matches the classification decision
- Forwarder or dangerous goods professional has reviewed the product and shipment
- Carrier rules and any shipper pre-approval checked
- Preparation requirements of Special Provision 978 met and recorded
- Packaging is suitable and certified as required, and marking and labels are correct
- Dangerous goods declaration data checked against the packing records
- Stowage plan reviewed against headspace and stacking provisions
- Written confirmation received
Questions to confirm before cargo is packed, declared or delivered to a terminal
- Which edition of the IMDG Code and which amendments apply to this sailing date?
- Does the carrier accept this cargo from this shipper on this trade lane?
- Which documents, and in what format, are needed before the container is released to the terminal?
- What are the cut-off times and any pre-notification steps?
- Which surveyor is acceptable to the carrier for the vanning survey?
- Who is responsible for each document, and who signs it?
The written confirmation you need
Before shipping, the exporter should obtain written confirmation from the freight forwarder or a qualified dangerous goods professional and, where required, from the carrier. It should address the actual product, the applicable classification, the required documents, packing and handling requirements, and any necessary testing or supporting evidence. A generic statement from a forwarder does not replace the shipper's legal obligations or the applicable regulations.
Planning to import charcoal briquettes? Contact Many Hands Origins to discuss product information, packaging, order quantities and shipment planning. We can share the product details your forwarder will ask for. We do not provide regulatory clearance, and shipment-specific confirmation must come from your forwarder or dangerous goods professional. Inquiry: https://manyhandsorgins.com/#quote or +62 851-3937-6965.
Suggested internal links
- Packing briquettes for export (packaging and container loading)
- Coconut shell briquettes: what buyers should check (specifications)
References
- Burgoynes (Dr Jim Mercurio, March 2025). Updated IMDG Code requirements for the carriage of charcoal (reproduces Special Provision 978).
- TT Club. Guidelines for the safe carriage of charcoal in containers (CINS, 2024).
- Britannia P&I Club. Safe carriage of charcoal in containers.
- Britannia P&I Club. IMDG Code Amendment 42-24 summary.
- CMA CGM. Changes to carbon/charcoal classification under Amendment 42-24.
- MSC. IMDG 42-24: regulatory changes to the transportation of charcoal (carbon).
- Maersk. Customer advisory: charcoal (one carrier's requirements at the date of the document).
- RPM/SAIOSH presentation. Key outcomes from MSC 111 on IMDG Code Amendment 43-26.
Editorial disclaimer: The factual, technical, regulatory, pricing, shipping, and product-specific statements in this draft are presented as supplied and are assumed correct for editorial purposes. This content is general information, not legal, customs, regulatory, financial, safety, or quality advice. Rules, standards, prices, and specifications can change; confirm current requirements before relying on this article for a transaction or shipment.