What Are Dangerous Goods｜Practical Maritime Transport with IMDG Code, SDS, and Dangerous Goods Declaration
Interlink編集部What are Dangerous Goods?
Dangerous Goods refer to cargo that may pose risks such as fire, explosion, toxicity, corrosiveness, or environmental pollution during maritime transport. When transporting cargo classified as dangerous goods, it is necessary to properly carry out classification, packaging, labeling, stowage, segregation, and documentation based on regulations such as the IMDG Code (International Maritime Dangerous Goods Code).
In maritime transport, dangerous goods cannot be handled in the same manner as general cargo. It is essential to verify the UN number, Proper Shipping Name, Class, Packing Group, applicability as a Marine Pollutant, Flash Point, EMS number, stowage and segregation requirements, and to accurately declare this information to the shipping line, NVOCC, freight forwarder, CFS, and customs broker.
Failure to declare dangerous goods, incorrect declaration, insufficient SDS (Safety Data Sheet) information, improper labeling or marking, and inappropriate packaging can lead to shipment refusal, cargo detention, additional costs, liability of the shipper in case of accidents, and insurance issues. In the practical handling of Dangerous Goods, it is important not only to determine whether cargo is classified as dangerous, but also to record based on which criteria, on which documents, who verified it, and to what extent the declaration was made.
Scope Covered in This Article
| Item | Contents Covered in This Article | Contents Covered in Other Articles |
|---|---|---|
| Basics of Dangerous Goods | Meaning of dangerous goods in maritime transport, handling differences from regular cargo, risks of undeclared goods | Details of each dangerous goods Class, item-specific judgment covered in Class-specific articles |
| Relationship with IMDG Code | Basic positioning of classification, packaging, labeling, stowage, segregation, and declaration of individual dangerous goods | Detailed provisions of IMDG Code by clause, latest amendment updates in specialized materials |
| Relationship with SDS | Checking transport information section in SDS, UN number, Proper Shipping Name, Class, Packing Group | How to read SDS, certificates of non-dangerous goods, chemical information verification in related SDS articles |
| Dangerous Goods Declaration | Roles of Dangerous Goods Declaration, Container Packing Certificate, and carrier-designated forms | Specific examples of declaration entries, signing authority, electronic declaration in documentary practice articles |
| Packaging, Marking, and Labeling | UN containers, dangerous goods labels, Marine Pollutant marking, container markings, leakage prevention measures | UN containers, small quantity dangerous goods, limited quantity goods, certificates of non-dangerous goods in individual articles |
| Differences Between LCL and FCL | CFS receiving, conditions for mixed loading, container stowage, segregation, verification of Container Packing Certificate | LCL, FCL, CFS in-gate, CY in-gate, and container stowage in respective transport mode articles |
| Consistency with B/L and Transport Documents | Consistency of B/L, Sea Waybill, Arrival Notice, Dangerous Goods Declaration, and SDS entries | B/L entries, B/L corrections, Sea Waybill, Arrival Notice in respective document articles |
| Accident and Insurance Response | Accident handling for undeclared or misdeclared goods, insurance, carrier liability, shipper liability, documentation for claims | Cargo insurance, survey reports, carrier liability, general average in dedicated articles |
Relationship with the IMDG Code
The IMDG Code serves as the international standard for maritime transport of individual dangerous goods. It specifies classifications, packaging, labeling, marking, dangerous goods declarations, container loading and segregation, and shipboard stowage methods.
In practice, it is not sufficient to only refer to hazard information listed on the SDS. It is necessary to confirm which UN number, Proper Shipping Name, Class, and Packing Group under the IMDG Code apply to the goods as dangerous goods for maritime transport.
In Japan, maritime transport of dangerous goods is regulated based on international standards such as the IMDG Code, and in accordance with the Ship Safety Act and related Dangerous Goods Ship Transport and Storage Regulations. Therefore, export and import operations must consider both international standards and Japanese procedural and verification requirements.
Main Items to Check for Dangerous Goods Determination
| Item | Details to Confirm | Reference Materials | Practical Notes |
|---|---|---|---|
| UN Number | The United Nations number assigned to the dangerous good | SDS, IMDG Code, Dangerous Goods Declaration | Basic information for dangerous goods declaration and shipping line application |
| Proper Shipping Name | Official product name according to the IMDG Code | SDS transport information section, IMDG Code, shipping line forms | May differ from the general product or brand name |
| Class / Division | Classification of hazards such as explosives, gases, flammable liquids, corrosives | SDS, IMDG Code, Dangerous Goods Declaration | Acceptance, segregation, marking, and stowage conditions vary by class |
| Packing Group | Packing category according to hazard severity | SDS, IMDG Code, container information | Indicated as I, II, III, etc., affecting packaging requirements |
| Marine Pollutant | Whether it is classified as a marine pollutant | SDS, IMDG Code, ingredient information | If applicable, additional requirements for marking, declaration, and handling arise |
| Flash Point | Flash point checked for flammable liquids, etc. | SDS, test data, manufacturer information | Relevant for Class 3 classification and shipping line acceptance |
| Packing / Container | UN packaging, inner/outer packaging, weight limits, leak prevention | Container certification, packing specifications, photos, manufacturer data | Inappropriate packaging may lead to shipment refusal or gate-in prohibition |
| Stowage / Segregation Conditions | Compatibility with other cargo, segregation, deck stowage permission | IMDG Code, shipping line approval, CFS confirmation | For LCL shipments, also confirm acceptance conditions on the CFS side |
| Emergency Information | EMS, first aid measures, leak response, contact information | SDS, Dangerous Goods Declaration, shipping line forms | Affects initial accident response and shipping line approval |
Differences Between Regular Cargo, Dangerous Goods, and Non-Dangerous Goods Certificates
| Category | Main Characteristics | Commonly Required Documents | Practical Considerations |
|---|---|---|---|
| Regular Cargo | Cargo that does not fall under dangerous goods according to the IMDG Code and does not require a special dangerous goods declaration | Invoice, Packing List, B/L information | Do not determine safety based on the item name alone; check chemicals, batteries, liquids, and aerosols |
| Dangerous Goods | Cargo requiring declaration based on the UN number, Proper Shipping Name, Class, Packing Group, etc. | SDS, Dangerous Goods Declaration, Container Packing Certificate, Shipping Line Application Forms | Shipping line approval, in-gate deadline, labeling, marking, and container compliance are required |
| Non-Dangerous Goods Certificate Cargo | Cargo that appears to be dangerous but requires documentation to prove it is treated as non-dangerous for transport | SDS, Non-Dangerous Goods Certificate, Manufacturer Confirmation Letter | Shipping lines and CFS may request additional verification |
| Cargo with Unclear Regulatory Status | Cargo with outdated SDS, blank transport section, or unknown components or flash point | Latest SDS, component sheet, manufacturer response, test data | Do not rush to classify as dangerous or non-dangerous |
| Small Quantity or Trace Amount Dangerous Goods | Cargo that may be handled differently from standard dangerous goods under certain conditions | Applicable IMDG Code conditions, packaging information, quantity information | Even small or trace amounts may not be exempt from declaration |
Main Required Documents
Transporting dangerous goods requires more information and documentation than regular cargo. Typical documents include SDS, Dangerous Goods Declaration, Container Packing Certificate, dangerous goods details, and carrier-specific forms.
The SDS provides information to verify composition, hazards, handling, first aid measures, and transport precautions. In practice, the UN number, Proper Shipping Name, Class, Packing Group, and Marine Pollutant status listed in the transport information section of the SDS are checked for consistency with the contents of the Dangerous Goods Declaration.
The Dangerous Goods Declaration is a critical document for shipping as dangerous goods. It must accurately state the UN number, Proper Shipping Name, Class, Packing Group, number of packages, weight, Marine Pollutant status, and emergency information.
| Document Name | Main Role | Party to Confirm With | Impact of Deficiency |
|---|---|---|---|
| SDS | Basic reference for verifying composition, hazards, and transport information | Shipper, manufacturer, exporter | Dangerous goods classification may not be possible; carrier application process delayed |
| Dangerous Goods Declaration | Declaration form for shipping as dangerous goods | Shipper, freight forwarder, carrier | Declaration errors, shipment refusal, and correction costs may occur |
| Container Packing Certificate | Certification of dangerous goods stowage, securing, and verification inside the container | Shipper, warehouse, container loading operators | Impacts carrier approval and CY in-gate for FCL dangerous goods |
| Carrier-Specific Forms | Forms to provide required information for carrier dangerous goods acceptance review | Carrier, NVOCC, freight forwarder | Missed deadlines, booking cancellations, or loading refusals may result |
| Non-Dangerous Goods Certificate | Document explaining the basis for items not classified as dangerous goods | Manufacturer, shipper, freight forwarder | Carrier or CFS may place acceptance decisions on hold |
| Photos and Packing Documents | Materials to verify labels, markings, containers, and external packaging condition | Warehouse, shipper, packing contractor | Discrepancies between actual cargo and declaration content may be found |
Relationship with B/L and Shipping Documents
The fact that cargo is classified as dangerous goods must be consistent across all documents, including the B/L, Sea Waybill, Arrival Notice, Dangerous Goods Declaration, and SDS. If the description on the B/L only lists a general product name and there is a discrepancy with dangerous goods information on separate documents, the shipping line or local parties may conduct a verification.
Moreover, dangerous goods must align not only with the shipping documents but also with the actual cargo labels, markings, packaging, and container markings. Even if declared as dangerous goods on paper, shipment or in-gate may be stopped if the required markings are missing on the actual cargo.
Differences in Handling Between LCL and FCL
| Item | LCL Dangerous Goods | FCL Dangerous Goods | Practical Considerations |
|---|---|---|---|
| Receiving Location | Received at CFS | Container delivered to CY or designated location | For LCL, the dangerous goods acceptance conditions at the CFS are critical |
| Consolidation Permitted | Whether mixed with other cargo is a major issue | The shipper can better manage the container’s cargo composition | Even within the same Class, mixed loading may be prohibited |
| Cutoff | Usually earlier delivery and document cutoff than general cargo | Cutoff for carrier application, CY delivery, and container inspection must be observed | Confirm dangerous goods application cutoff at booking |
| Packing Responsibility | Depends on CFS’s operational and storage conditions | Packing, securing, and leakage prevention inside the container are important | For FCL, verify consistency with the Container Packing Certificate |
| Risk of Refusal | CFS may refuse to accept dangerous goods | Carrier or port may hold shipment | Check conditions not only with the carrier’s approval but also with CFS and port |
| Impact in Case of Accident | Likely to affect other companies’ cargo | Usually isolated and inspected on a container basis | Be aware of damage, cleaning, disposal, and additional costs related to co-loaded cargo |
Common Misconceptions
| Common Misconception | Actual Consideration | Practical Notes |
|---|---|---|
| If the SDS does not state it is dangerous goods, it can be treated as regular cargo | SDS may be outdated, shipping information section incomplete, or maritime transport info missing | Confirm the latest SDS, components, UN number, and Class |
| The product name is generic, so it is not dangerous goods | Dangerous goods classification cannot be determined from product or trademark names alone | Check components, flash point, form, concentration, and use |
| No dangerous goods declaration is required if the quantity is small | Even small or minute quantities have applicable conditions and marking/packing requirements | Verify the small quantity exceptions under the IMDG Code |
| If the shipping company accepts it, then the CFS will also accept it | Shipping company approval and CFS acceptance often require separate confirmation | Confirm CFS acceptance conditions, cut-offs, and storage terms for LCL cargo |
| Dangerous goods declaration is easier for FCL shipments | FCL requires attention to container loading, securing, leakage measures, and Container Packing Certificate | Confirm consistency between container condition and declaration |
| A non-dangerous goods certificate guarantees acceptance | Shipping companies or CFS may request additional documents or SDS | Retain basis for non-applicability, manufacturer responses, and SDS |
| It is sufficient to write a general description on the B/L | It must be consistent with the dangerous goods declaration, SDS, labels, and markings | Check for consistency across all transport documents |
| No problem if undeclared, as long as there is no accident | If discovered before loading, at port, or during transshipment, shipment may be rejected or extra costs incurred | Check dangerous goods applicability at booking |
Risks of Non-Declaration and Misdeclaration
If dangerous goods are declared as regular cargo, and discovered before shipment, consequences may include refusal of shipment, booking cancellation, storage fees, repacking costs, and document correction charges.
If non-declaration or misdeclaration is identified after shipment, responses from the shipping company, port authorities, customs, and related agencies will be required. This could result in cargo unloading, isolation, disposal, additional expenses, and impact on other cargo.
Moreover, in case of incidents such as fire, explosion, leakage, or contamination, the shipper or exporter may be held responsible for declaration, packing, and information provision. Simply claiming unawareness that the cargo was dangerous or failing to check the SDS may not suffice to mitigate practical liability.
Common Practical Issues
| Case | What Becomes Problematic | Cause | Practical Response |
|---|---|---|---|
| SDS transport information section left blank | Unable to determine dangerous goods classification, causing carrier application to stop | Outdated SDS or lack of information tailored for maritime transport | Obtain latest SDS, manufacturer confirmation, and ingredient information |
| Incorrect UN number | Class, packaging, segregation, and labeling all become incorrect | Reused generic product names or past documents without verification | Cross-check IMDG Code, SDS, and manufacturer information |
| Marine Pollutant marking omitted | Shipment halted by carrier or port due to incomplete marking/declaration | Insufficient review of environmental hazard in SDS | Verify SDS, ingredient data, and Marine Pollutant section of the declaration |
| CFS does not accept LCL cargo | Booking changes, alternative CFS arrangement, and additional costs incurred | Did not confirm CFS acceptance conditions before booking | Confirm CFS acceptance early for LCL dangerous goods |
| Labels and markings not applied to actual cargo | In-gate stoppage, re-labeling, and shipment delays occur | Insufficient cross-check between documents and actual markings | Confirm labels and markings by photo before in-gate |
| Used packaging not compliant with UN container standards | Repackaging, refused shipment, and increased costs arise | Did not verify dangerous goods packaging requirements | Confirm container standards, packaging specifications, and weight limits |
| Inadequate securing and leakage prevention inside FCL | Container inspection, leakage incidents, and cargo collapse risk arise | Poor container loading management | Keep Container Packing Certificate, photos, and loading records |
| Declared as non-dangerous after which identified as dangerous goods | Booking cancellation, reapplication, shipment delays, additional costs incurred | Insufficient basis to declare non-applicability | Retain non-dangerous certificate, SDS, and manufacturer confirmation |
Comparison Table of Freight Forwarder Involvement Scope
| Category | What Can Be Supported | What Should Not Be Concluded | Practical Response |
|---|---|---|---|
| Initial Confirmation of Dangerous Goods Applicability | Check the possibility of dangerous goods based on product name, SDS, and component information | Make final professional chemical judgments or legal applicability determinations | Encourage confirmation with the manufacturer, shipper, or specialized department |
| SDS Verification | Check transport information fields, UN number, Class, and Packing Group | Guarantee that the SDS content is always accurate | Request the latest SDS or manufacturer responses if any doubts arise |
| Shipping Line Application | Provide information on the shipping line’s designated forms, dangerous goods declaration, and deadlines | Guarantee the shipping line will always accept the shipment | Confirm approval conditions, route, transshipment, and deadlines |
| LCL/FCL Arrangement | Confirm acceptance at CFS, consolidation conditions, and container loading documents | Assume that LCL and FCL can be transported under the same conditions | Check acceptance conditions separately according to the transport mode |
| Label and Packaging Inspection | Check photos, container information, markings, and packaging condition | Conclude compliance without physically inspecting the cargo | Save photos, container proof, and packaging details before in-gate |
| B/L and Document Consistency | Check for inconsistencies between B/L, SDS, and dangerous goods declaration | Consider B/L notation alone sufficient for dangerous goods handling | Verify the overall consistency of all transport documents |
| Accident Response | Organize the SDS, declaration, photos, survey report, and shipping line notices | Make definitive judgments on insurance claim approval or shipper liability | Contact the insurance company, shipping line, and surveyor promptly |
Checklist for Verification
| Verification Stage | Party to Verify With | Items to Confirm | Actions if Issues Are Found |
|---|---|---|---|
| Before Booking | Shipper, Manufacturer, Freight Forwarder | Possibility of classified dangerous goods | Obtain SDS, composition information, or non-dangerous goods certificate |
| During SDS Review | Shipper, Manufacturer, Exporter | UN Number, Proper Shipping Name, Class, Packing Group | If information is incomplete, request the latest SDS or confirmation from the manufacturer |
| When Applying to Shipping Line | Shipping Line, NVOCC, Freight Forwarder | Acceptance of dangerous goods, cutoff time, required forms, route restrictions | Do not proceed with in-gate or shipment before approval |
| When Arranging LCL | CFS, Consolidator, Shipping Line | Acceptance for consolidation, storage location, in-gate deadline, acceptance restrictions | If not accepted, consider FCL, alternative CFS, or different route |
| When Arranging FCL | Shipper, Warehouse, Container Loading Operator | Container loading, securing, leakage prevention, Container Packing Certificate | Retain photos, loading records, and certificates |
| Before In-Gate | Shipper, Warehouse, CFS | Labels, markings, UN containers, external condition | If deficiencies, consider re-labeling, re-packing, or delaying in-gate |
| When Creating B/L | Shipper, Freight Forwarder, Shipping Line | B/L description, dangerous goods declaration, SDS, Sea Waybill consistency | Correct discrepancies before issuing |
| In Case of Incident | Shipping Line, Insurance Company, Surveyor, Shipper | SDS, declaration forms, loading records, photos, incident notification | Prioritize evidence preservation, damage containment, and notifying relevant parties |
Relationship with Cargo Insurance and Incident Response
In the event of an accident involving dangerous goods cargo, issues such as cause investigation, damage containment, recovery, disposal, cleaning, third-party damages, and general average can be more significant than with regular cargo.
For accidents involving undeclared or misdeclared dangerous goods, cargo insurance payment, carrier liability, shipper responsibility, and indemnity relationships may also be affected. At the time of an incident, it is necessary to promptly organize the SDS, dangerous goods declaration, B/L, container stowage records, photos, survey reports, and notifications from the shipping company.
Scenario 1: When Dangerous Goods Information Is Missing from the SDS and Carrier Application Is Delayed
When exporting chemicals, if the transport information section of the SDS submitted by the shipper is blank or outdated, it may not be possible to verify the UN number, Proper Shipping Name, Class, or Packing Group, resulting in a delay in the dangerous goods application process with the carrier.
In this case, the freight forwarder should not assume the cargo is regular goods based solely on the product name. Instead, they should verify the latest SDS, obtain the manufacturer's response, check the ingredient information, and confirm whether a non-dangerous goods certificate is required. Rather than rushing to conclude whether the cargo is hazardous or not, it is important to record the basis for the judgment as documentation.
Scenario 2: When a CFS Does Not Accept Dangerous Goods in LCL Shipments
Even if dangerous goods are booked as LCL cargo, the CFS may refuse to accept cargo under that specific Class or UN number. At the CFS, concerns such as mixed loading with other cargo, storage space, worker safety, port regulations, and cutoff times can lead to the cargo being held, even if the shipping line has approved it.
In such cases, options to consider include using a different CFS, switching to a different shipping line, converting to FCL, postponing shipment, repacking, or submitting additional non-dangerous goods certification. For LCL dangerous goods shipments, confirming the CFS acceptance conditions early on is necessary, in addition to shipping line approval.
Scenario 3: Labeling or Marking Deficiencies Found in FCL Cargo
For FCL dangerous goods, even if the dangerous goods declaration is completed on the paperwork, the actual cargo may lack required labels, markings, Marine Pollutant indication, or UN container markings. In such cases, cargo could be held at the time of CY in-gate, by the port authority, the shipping line, or local parties.
The freight forwarder should check not only the documents but also photos before in-gate, container markings, packaging condition, and external container markings. If deficiencies are found, it may be necessary to consider re-labeling, repackaging, postponing in-gate, or resubmitting the declaration to the shipping line.
Scenario 4: Cargo Declared as Non-Dangerous but Later Found to Be Dangerous Goods
After the shipper states “This is not dangerous goods” and books the shipment as general cargo, it may be discovered through review of the SDS or ingredient information that the cargo actually qualifies as dangerous goods under the IMDG Code. In such cases, cancellation of the booking, reapplication as dangerous goods, delayed in-gate, storage fees, and repacking costs could occur.
For cargo that appears to be dangerous goods—such as chemicals, liquids, aerosols, batteries, paints, adhesives, and cleaning agents—it is necessary to verify the SDS and transport information rather than judging by the product name alone. Even if treated as non-dangerous goods, it is important to retain grounds for that determination.
Scenario 5: Discovery of Undeclared Dangerous Goods After an Incident
After shipment, incidents such as fire, leakage, unusual odors, or contamination may occur, and during investigation it could be revealed that the dangerous goods were undeclared. In such cases, the response will involve the carrier, port authorities, customs, relevant government agencies, insurance companies, and surveyors.
In incidents caused by undeclared or misdeclared dangerous goods, responsibilities may simultaneously arise concerning the shipper’s declaration duty, packaging obligations, information provision, damage to other cargo, cleaning costs, disposal expenses, general average, and insurance issues. At the time of the incident, it is necessary to promptly organize the SDS, dangerous goods declaration, B/L, container stowage records, photographs, survey reports, and notifications from the carrier.
Summary
Dangerous Goods are critical cargo in maritime transport that cannot be handled in the same manner as regular cargo. In practice, it is essential to verify classification based on the IMDG Code, UN number, Proper Shipping Name, Class, Packing Group, SDS, Dangerous Goods Declaration, packaging and labeling, carrier approval, compatibility for mixed loading, and procedures for liability handling in case of accidents.
When transporting dangerous goods, it is important not to rely on intuition to determine whether cargo is hazardous. It is necessary to cross-check the SDS, IMDG Code, manufacturer’s response, carrier approval, CFS acceptance conditions, and actual cargo labels and markings, keeping the basis for the decision documented as a record.
Undeclared or misdeclared dangerous goods may lead not only to shipment refusal or additional charges but also to fire, explosion, leakage, contamination, damage to other cargo, and insurance complications. Freight forwarders and NVOCCs should not simply accept shippers’ declarations as is; they must confirm the consistency of the SDS, Dangerous Goods Declaration, packaging and labeling, and carrier approval.
