UN 1361, Class 4.2 and IMDG Amendment 42-24: Charcoal's Classification Explained
By Mohamad Sinno, Charcoal Expert · Last updated
Since IMDG Amendment 42-24 became mandatory on 1 January 2026, coconut charcoal ships as declared Class 4.2 dangerous goods under UN 1361 — the N.4 test-out route is gone; Special Provision 978 sets the carriage conditions. Classification is one leg of shipping coconut charcoal from Indonesia by sea. Below: what UN 1361 means, what 42-24 changed, and what an importer should now see from a supplier.
The classification, in plain terms
UN 1361 is the sea-transport classification — proper shipping name (PSN) CARBON, animal or vegetable origin — covering carbon and charcoal, coconut charcoal briquettes included, as Class 4.2 self-heating cargo under the IMDG Code, the IMO's dangerous-goods rulebook. Amended by 42-24, mandatory since 1 January 2026. Accurate as of July 2026.
Class 4.2 covers spontaneously combustible cargo: a self-heating substance takes up oxygen, warms, and sealed in a container can climb toward ignition.
Coconut shisha and hookah briquettes stay UN 1361 — quick-light or not
Coconut shisha and hookah charcoal briquettes are UN 1361 cargo. The entry covers carbon "produced by pyrolysis of an organic material such as bone, bamboo, coconut shell, jute or wood" — Special Provision 978's own definition, as reproduced by CINS (September 2024). Agglomerated briquettes stay in scope, quick-light or not.
The definition turns on how the carbon was made, not on additives or ignition aids. Hapag-Lloyd states it flatly: charcoal "must always be declared as Dangerous Goods, classified as UN1361 CARBON, animal or vegetable origin, Class 4.2" (December 2025). The distinction changes carrier scrutiny, not classification — coconut shell charcoal briquettes are classified for sea freight as UN 1361, Class 4.2.
Before vs after 1 January 2026
IMDG Amendment 42-24 — adopted by IMO Resolution MSC.556(108), 23 May 2024 — replaced the provisions governing UN 1361: SP 925/SP 223 removed, Special Provision 978 inserted (PHMSA, 91 FR 5996, 10 February 2026). The removed pair was an exemption regime; SP 978 a carriage-conditions regime.
- 23 May 2024 42-24 adopted
- 1 Jan 2025 voluntary application
- 1 Apr 2025 Hapag-Lloyd full DG compliance
- 1 Jan 2026 mandatory worldwide
IMDG rules for UN 1361 charcoal: pre-42-24 vs post-42-24
Before 2026 a consignment passing the UN N.4 self-heating test could ship as non-DG; after 42-24 it ships declared under SP 978 — no test result changes that:
| Aspect | Pre-42-24 (removed regime) | Post-42-24 (current) |
|---|---|---|
| Classification basis | UN 1361, Class 4.2 — but the Code could be switched off by testing. CINS fn 11, Sept 2024 | UN 1361, Class 4.2, always declared — the N.4 test "shall not be used to exempt". SP 978.2 via CINS, Sept 2024 |
| Exemption route (removed) | SP 925: passed self-heating tests + accredited-lab certificate → outside the Code; SP 223: similar test-based exclusion. CINS fns 11–12, Sept 2024 | None — SP 925/SP 223 replaced by SP 978. PHMSA 91 FR 5996, 10 Feb 2026; West of England P&I, 30 Sept 2024 |
| Required documents | Certificate from a competent-authority-accredited laboratory. SP 925 via CINS fn 11 | DGD stating production date, packing date, packing-day temperature. Hapag-Lloyd, Dec 2025; CINS §4.1 |
| Packing conditions | For an excepted consignment the Code's provisions "do not apply". SP 925 via CINS fn 11 | 14-day weathering or inert-gas route + 24 h; ≤40 °C packing day; 30 cm headspace; 1.5 m stow or 16 m³ blocks; UN-approved packaging; no containerized bulk. SP 978.4–.6 via CINS; Hapag-Lloyd, Dec 2025 |
| Effective dates | In force until 42-24; new rules voluntary from 1 Jan 2025. MSC.556(108) para 4 | Adopted 23 May 2024; accepted 1 Jul 2025; mandatory 1 Jan 2026. MSC.556(108) paras 1–3 |
| Carrier enforcement | Shippers could "seek acceptance" of charcoal as exempt, carrier by carrier. CINS §2, Sept 2024 | Hapag-Lloyd required full DG compliance from 1 Apr 2025 — nine months early; other carriers vary. Hapag-Lloyd, Dec 2025 |
The 'pass the test, ship non-DG' advice is dated — here is when it died
Any guide still advising charcoal shippers to "pass the self-heating test and book as general cargo" describes a regime that ended on 1 January 2026. It was once correct — old SP 925 really did take a tested, lab-certified consignment outside the Code on a passed N.4 test — which is what makes it dangerous now: it books a misdeclared container. The removal is stated by CINS (September 2024) and PHMSA (91 FR 5996); what the removed route measured is covered under the N.4 self-heating test charcoal used to pass.
What the change costs — and what ignoring it costs
Compliance shows up on the freight bill as a carrier DG surcharge; non-compliance as a refused booking or a misdeclaration case — the cheaper is not in question. Hapag-Lloyd re-introduces its Dangerous Goods Premium at USD 250 / EUR 210 per container (as of December 2025; other DG surcharges may apply). Behind it: the vessel fires history — at least 68 charcoal container-ship fires, January 2015–December 2022 (CINS, September 2024); the science and case record: why charcoal is classified Class 4.2.
SP 978: conditions, not an exemption
SP 978 is the set of conditions under which UN 1361 charcoal is carried as dangerous goods — weathering or inert-gas conditioning, a packing-day temperature ceiling, headspace and stowage limits — not a route out of DG status.
The shape of the provision, per the CINS reproduction (September 2024, pp. 7–8) — not another bullet list. Conditioning: after production the unpacked material weathers — under cover, in open air — for at least 14 days, or takes the steam-and-inert-gas route plus a 24-hour rest (SP 978.4). Temperature: packing only when the material does not exceed 40 °C on the day of packing (SP 978.5) — a stuffing-day ceiling, not an average. Geometry: 30 cm minimum headspace, stow 1.5 m or 16 m³ blocks 15 cm apart (SP 978.6). Untested material: at least packing group III (SP 978.3). Each carriage condition has an operational meaning and an evidence trail — unpacked SP 978 requirement by requirement.
What the Code requires vs what carriers add on top
SP 978 sets the legal floor; weathering certificates, vanning-survey photos and DG surcharges are carrier and P&I policy layered on top — negotiable in a way Code text never is.
| IMDG Code text | Carrier / P&I overlay |
|---|---|
| Weathering or inert-gas conditioning; ≤40 °C ceiling; headspace and stow limits; at least PG III untested. SP 978.3–.6 via CINS, Sept 2024 | Compiled Weathering Report made available at vanning — guidance, not Code text. CINS §4.1, Sept 2024 |
| The N.4 test cannot exempt UN 1361. SP 978.2 via CINS, Sept 2024 | Independent vanning survey — "there is no requirement in the Code for such a survey". Burgoynes, March 2025; CINS fn 15 |
| Mandatory application from 1 January 2026. MSC.556(108) | Early enforcement and DG surcharges — Hapag-Lloyd from 1 Apr 2025, DGP USD 250 / EUR 210 (as of December 2025). Hapag-Lloyd advisory, Dec 2025 |
Per-carrier acceptance policy — which carriers accept charcoal and on what terms — is its own subject.
What an importer should ask the supplier for before booking
Before booking, an importer should hold four proofs from the supplier: a DGD stating production date, packing date and packing-day temperature; the weathering or cooling record behind it; the packing-temperature log; and whatever vanning evidence the carrier demands. Call that the proof chain: the declaration plus the records behind it.
| Document | What it proves | Code requirement or overlay |
|---|---|---|
| DGD with the three data points | The consignment is declared; the three facts are on record | Declared carriage per 42-24; trio per Hapag-Lloyd, Dec 2025 + CINS §4.1 |
| Weathering or cooling record | The conditioning route was actually run | Condition: SP 978.4; the report format is CINS guidance — overlay |
| Packing-temperature log | Material ≤40 °C on packing day | Condition: SP 978.5 |
| Vanning-survey evidence | Packing, securing and packaging condition at stuffing | Overlay — independent survey per CINS fn 15; no Code requirement (Burgoynes, March 2025) |
What this factory practices: Coco Reina holds its coconut shell charcoal 14 days post-production before packing — the SP 978 minimum — and checks material temperature each stuffing day, measured 20–30 °C against the 40 °C ceiling. Production date, packing date and packing-day temperature are kept in the factory's production/batch log and entered on the DGD for each shipment. The weathering record and vanning survey are supplied to buyers on request — ask for them with the DGD.
The DGD sits inside a larger stack — B/L, certificate of origin, MSDS — covered in the full charcoal export document set. For this summary and the factory's own DG declaration practice: WhatsApp +628213924038.
What SP 978 does not do
SP 978 does not make charcoal non-DG, does not certify anyone, and does not oblige any carrier to accept the booking.
- Meeting every condition still ships declared UN 1361, Class 4.2.
- It certifies no supplier — see Q1 below.
- It governs the sea leg; inland ADR/RID rules are a separate framework, not covered here.
Classification Q&A
Five buyer-side questions.
Is UN 1361 a certificate a supplier can hold?
No — UN 1361 is a cargo classification, not a certificate. It identifies charcoal (PSN CARBON, animal or vegetable origin) in the IMDG Code's Dangerous Goods List; no body issues it to a company. "UN 1361 certified" describes a classification, not proof — unpacked at UN 1361 is not a certificate.
Does charcoal ship packing group II or III?
Packing group II or III. Under Special Provision 978.3, as reproduced by CINS (September 2024), untested material "shall be assigned to at least packing group III". Coco Reina declares its shipments UN 1361, Class 4.2, Packing Group III. Differences are tabulated under packing group II vs III for charcoal.
My supplier says a lab test exempts our charcoal shipment — is that current?
No — that claim describes the pre-2026 regime. Since Amendment 42-24 became mandatory on 1 January 2026, SP 978.2 bars the N.4 test from exempting UN 1361 (CINS reproduction, September 2024). A lab report supports quality claims, not DG status. Ask instead for the proof chain — the DGD and the records behind its three data points.
What must a charcoal dangerous goods declaration state?
A charcoal DGD must state the production date, the packing date, and the temperature of the material on the day of packing — per Hapag-Lloyd's advisory (December 2025), matching the CINS Weathering Report items (September 2024).
Does every declared charcoal container pay a DG surcharge?
Carrier-dependent. Hapag-Lloyd re-introduced its Dangerous Goods Premium at USD 250 / EUR 210 per container (advisory December 2025; as of December 2025); other carriers set their own rates. A booking line item to confirm for UN 1361 cargo under IMDG 42-24, not a fixed market rate.
This page is general information on the transport classification of charcoal, not legal or dangerous-goods advice. Confirm current IMDG requirements with your carrier or a licensed dangerous-goods specialist before shipping.