IMO’s New Rules for the Transport of Biochar and Charcoal (IMDG 42-24)

From 2025—and mandatory from 1 January 2026—updated IMO regulations (IMDG Code, Amendment 42-24) come into force, fundamentally changing the requirements for the maritime transport of biochar, charcoal, and activated carbon.

Biochar and charcoal (UN 1361) are now always classified as Dangerous Goods for sea transport (Class 4.2, self-heating substances). The previous practice of granting exemptions based on laboratory testing has been removed. The key change is the introduction of Special Provision 978, which requires:

• 14 days of weathering or steam treatment followed by cooling and inert-gas conditions
• Cargo temperature ≤ 40 °C at the time of packing
• Controlled stowage with ventilation gaps and sufficient free space inside the container
• An expanded Dangerous Goods Declaration including the date of production, date of packing, and packing-day temperature.

Many shipping lines and P&I Clubs are already enforcing these requirements in 2025, requesting supporting documentation before accepting cargo.

For activated carbon (UN 1362), a limited exemption is available under SP 979, but only with official certification. Without such documentation, the cargo is also treated as Dangerous Goods.

Important: although road and rail regulations (ADR/RID) still allow certain exemptions, only IMDG applies at the port gate—the container must be fully DG-compliant for sea transport.