Packing Group II vs III for UN 1361 Charcoal
By Mohamad Sinno, Charcoal Expert · Last updated
UN 1361 lists both Packing Group II and III: the test result decides
UN 1361 charcoal is listed in the IMDG Dangerous Goods List under both Packing Group II and Packing Group III. A consignment's group is set by its self-heating test result, and untested material must be assigned to at least Packing Group III under Special Provision 978.
UN 1361 — proper shipping name CARBON, animal or vegetable origin, Class 4.2 — covers coconut-shell charcoal; activated carbon travels separately as UN 1362. A packing group states the danger degree (PG II medium, PG III minor) and drives packaging requirements. Both rows sit inside charcoal's UN 1361 classification under IMDG Amendment 42-24, mandatory since 1 January 2026 (IMO Resolution MSC.556(108)).
The SP 978 no-test default settles the untested case. As reproduced by CINS (September 2024) and Britannia P&I (January 2025): "Without testing, the material shall be assigned to at least packing group III." The default is one line — SP 978's weathering and packing-temperature requirements set the rest of the carriage conditions.
Assignment is a test outcome, not a shipper's choice
The packing group for UN 1361 is assigned from the material's self-heating test classification — a shipper cannot pick it. Under 49 CFR § 173.125 (US criteria harmonized with the UN Manual of Tests and Criteria), Packing Group II follows a positive result with a 25 mm sample cube at 140 °C; Packing Group III when only the 100 mm cube tests positive, the threshold varying with packaging volume.
This test-based assignment runs on the N.4 method — since 42-24 it "shall not be used to exempt" UN 1361 from the Code (SP 978.2, naming Manual section 33.4.6; CINS, September 2024), but what the N.4 self-heating test still decides is the group: the self-heating test outcome maps a consignment to PG II or III. A buyer can ask for the classification report behind a declared group — a dated test result, or the honest no-test answer: SP 978's default.
What changes between PG II and PG III for UN 1361
Switching groups changes the packaging duty level — the P002/PP12 instructions rows below — and the digit on the declaration, with no label implications.
| Operational lever | PG II | PG III |
|---|---|---|
| Packing instruction | Identical: P002, max 50 kg of charcoal per bag (CINS, Sept 2024) | |
| PP12 special packing provision | Identical: removed by 42-24 — PP12's bag types are no longer allowed (Hazcheck, Oct 2024) | |
| Large packagings | Not available — LP02 is PG III-only | LP02, up to 3 m³, sift-proof (CINS, Sept 2024) |
| UN packaging mark letter | X or Y | X, Y or Z (49 CFR § 178.503) |
| DGD entry | "II" in the packing-group field | "III" in the packing-group field |
| Hazard label | Identical: the Class 4.2 label does not change with the group | |
The mark letter states which packing-group tests the packaging design passed: X for PG I–III, Y for PG II–III, Z for PG III only (49 CFR § 178.503, mirroring the UN mark scheme). Why the label never changes — the self-heating behaviour that makes charcoal Class 4.2 — is common to both groups.
Where the packing group shows up in your documents
The packing group appears in three places a carrier will actually check: the PG field of the dangerous goods declaration, the code letter inside the UN packaging certification mark on each carton, and the booking data the line screens before acceptance.
In the DGD field, the UN 1361 PG value sits beside the UN number, proper shipping name and class; since 42-24 the document adds the production date, packing date and packing-day temperature (IMDG 5.4.1.5.18; Hazcheck, October 2024):
Specimen — illustrative layout only, not a real shipment record
UN 1361, CARBON, ANIMAL OR VEGETABLE ORIGIN, 4.2, PG III
Date of production: __ · Date of packing: __ · Temperature on packing day: __ °C
Carrier scrutiny works by comparison: the declared group against the mark letter on the packages against the booking. A supplier claim alone fails that check — UN 1361 is a transport classification, not a certificate — a tested assignment (or any PG II claim) traces to a dated test report; an untested one, to SP 978's at-least-PG-III default.
Coco Reina declares and ships its coconut shell charcoal as UN 1361, Class 4.2, Packing Group III — consistent with the SP 978 default. A redacted line from a real shipment declaration: UN 1361 · Class 4.2 · Label 4.2/- · Packing Group III · 4G fibreboard boxes (classification fields only; the PSN field reads "CARBON"). The classification evidence behind the declared group: the SP 978 no-test default (SP 978.3, quoted above); no separate classification test report is held.
A wrong or unevidenced packing group surfaces at the carrier's document check, not at packing time. Ask the factory on WhatsApp (+628213924038) how its own UN 1361 paperwork is declared.
The NA 1361 trap: 49 CFR lookup data is not the IMDG answer
No — the NA 1361 domestic entry (charcoal briquettes) that US lookup sites surface is a 49 CFR § 172.101 row with a single fixed PG III and the symbol "D" — a domestic-only proper shipping name; NA numbers are not recognized outside the United States (eCFR). The international UN 1361 row in the same table lists both PG II and PG III, matching the IMDG Code. A lookup warning for sea exporters, not US-domestic compliance guidance.
Regulatory content accurate as of July 2026 (IMDG Amendment 42-24; eCFR point-in-time 21 July 2026). This page is general information on packing-group assignment for UN 1361, not dangerous-goods advice. Confirm current requirements with your carrier or a licensed dangerous-goods specialist before shipping.