Special Provision 978: The Conditions for Carrying Charcoal (Not an Exemption)
By Mohamad Sinno, Charcoal Expert · Last updated
IMDG special provision 978 is where charcoal's exact shipping requirements now live: each clause, its factory meaning, and its evidence document.
SP 978 sets the conditions for carrying charcoal as dangerous goods — not an exemption
Special Provision 978 is the set of carriage conditions IMDG Amendment 42-24 attaches to charcoal shipped as UN 1361, Class 4.2 — weathering, packing temperature, stowage geometry and transport-document statements. It is not an exemption: the exemption routes were SP 925 and SP 223, and 42-24 removed them.
Charcoal — a self-heating cargo — is always declared as dangerous goods; SP 978 is one clause of charcoal's UN 1361 Class 4.2 classification under IMDG 42-24. Behind it: 68-plus container-ship fire incidents, 2015–2022 (CINS, September 2024).
Mandatory since 1 January 2026 — and carriers enforced it earlier
The dated chain: adopted by IMO Resolution MSC.556(108) on 23 May 2024; voluntary from 1 January 2025; mandatory since 1 January 2026. As of July 2026 the transitional year is over — SP 978 is the operative regime. Enforcement ran ahead: Hapag-Lloyd required full DG compliance from 1 April 2025 (advisory, December 2025).
The SP 978 requirements matrix: provision → operational meaning → evidence document
SP 978 makes six numbered demands of a UN 1361 shipment. Provisions are quoted from the CINS Charcoal Guidance reproduction (September 2024).
| Clause | Requirement | Operational meaning | Evidence document |
|---|---|---|---|
| 978.1 | Defines the entry: carbon from pyrolysis of bone, bamboo, coconut shell, jute or wood — not mined | Coconut-shell briquettes in scope; activated carbon is a separate entry (UN 1362) | None — scope clause, reflected in the shipping name CARBON |
| 978.2 | The UN N.4 test (§33.4.6) shall not be used to exempt UN 1361 | No test-out exists — see why a passed self-heating test no longer exempts charcoal | Nothing to file — a test certificate is no longer exemption evidence |
| 978.3 | Without testing, at least packing group III | Untested cargo books at PG III; the PG sets the packaging level — see packing group II vs III for UN 1361 charcoal | The PG stated on the DGD |
| 978.4 | 14-day weathering, or the steam/inert-gas alternative (scope notes below) | Hold unpacked stock 14 days from end of pyrolysis | Weathering Report: production date, packaging date, packaging type, mean packing-day temperature |
| 978.5 | Packing temperature 40 °C max — material "does not exceed 40 °C on the day of packing" | A temperature check before stuffing, every stuffing day | The packing-day temperature record — DGD statement 3 |
| 978.6 | CTU headspace ≥30 cm; stacks ≤1.5 m or ≤16 m³ blocks with ≥15 cm gaps | Design the stuffing pattern to this geometry | None — carriers commonly ask a vanning survey ("no requirement in the Code", Burgoynes, Mar 2025) |
| Alongside SP 978 (same Code, other provisions) | Packaged cargo only (BK1/BK2 barred); P002 shall be used, PP12 no longer; marking, labelling, placarding | UN-spec packages, properly marked | UN-spec package marks + the DGD (CINS, Sept 2024) |
Scope notes on SP 978.4: competent-authority approval and the biochar-only steam route
Only 978.4 opens "Unless otherwise approved by the competent authority" — the N.4 prohibition, PG III floor, 40 °C limit and stowage geometry carry no such opener. And the steam-treated alternative with its 24 h rider "relates to a specialist product, 'Biochar', rather than commonly produced Charcoal" (CINS, September 2024); Hapag-Lloyd's bullet drops the steam step. Neither rider shortens the clock: ordinary charcoal plans for the 14-day hold.
What SP 978 does not do
- Not an exemption or waiver — meeting these carriage conditions means shipping compliantly as dangerous goods.
- Not a certificate a supplier can hold or print on a spec sheet (the "UN 1361 certified" misreading has its own page).
- Not the whole Code — P002 packaging, marking, labelling and placarding sit in other provisions.
- Not the last word at booking — carriers layer their own requirements.
Meeting each condition at a real factory: practice notes and the records they produce
The weathering clock starts when pyrolysis ends: the material sits under cover but in the open air, and packaging may not begin before day 14 (CINS, September 2024). Coco Reina holds its coconut shell charcoal briquettes 14 days — the SP 978 minimum — and the hold feeds the weathering report's four entries in the matrix above.
On each stuffing day the material temperature is checked before packing — measured 20–30 °C against the ≤40 °C ceiling; the check produces the temperature record the transport document states. The booking carries the classification itself: Coco Reina declares and ships as UN 1361, Class 4.2, Packing Group III.
The three SP 978 statements on the transport document
For UN 1361 the transport document additionally states three things (see special provision 978 of chapter 3.3 — CINS, September 2024; Hapag-Lloyd lists the same fields at booking level) — lines one and two from the 978.4 weathering hold, line three from the 978.5 packing-day check:
Date of production: ____
Date of packing into packagings: ____
Temperature of the material on the day of packing: ____ °C
What SP 978 compliance adds at booking: the DG surcharge line
Hapag-Lloyd's December 2025 advisory reintroduces a Dangerous Goods Premium (DGP) surcharge of USD 250 / EUR 210 per container (as of July 2026; other DG surcharges may apply). The matrix above is the SP 978 requirements checklist for charcoal; for the factory's DG document pack, WhatsApp +628213924038.
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.