IMDG Code — Checks for Sea Transport of Dangerous Goods
Interlink編集部What Is the IMDG Code?
The IMDG Code stands for the International Maritime Dangerous Goods Code, which is an international regulation that specifies classification, packaging, labeling, documentation, stowage, segregation, and other requirements for the maritime transport of dangerous goods.
It establishes the fundamental rules for safely shipping dangerous goods by sea and is a critical regulation that shipping lines, freight forwarders, shippers, warehouses, CFS, and customs brokers must confirm.
In freight forwarder operations, the IMDG Code relates to sea bookings for dangerous goods, CFS in-gate procedures, container stowage, consolidation eligibility, labeling and markings, dangerous goods declarations, and confirmation of marine pollutants.
When shipping dangerous goods by sea, it is essential to organize the UN number, proper shipping name, hazard class, packaging group, marine pollutant status, packaging, labeling, and stowage and segregation requirements so that the shipping line, CFS, and warehouse can accept the cargo without issues.
Scope Covered in This Article
| Item | Content Covered in This Article | Content Covered in Other Articles |
|---|---|---|
| Basics of the IMDG Code | Organized as practical rules that freight forwarders should confirm for maritime dangerous goods transport. | Clause-by-clause commentary on the IMDG Code and detailed classification criteria are covered in the latest regulation publications and specialized training. |
| Checks for Maritime Dangerous Goods | Handles UN number, proper shipping name, hazard class, packaging group, packaging, marking, stowage, and segregation. | Detailed classification decisions for each hazard class are covered in the Dangerous Goods Classification and SDS articles. |
| Relationship with SDS | Based on the transport information section of the SDS, how to link to maritime dangerous goods classification. | Methods for creating SDS and detailed explanations of each section are covered in the SDS article. |
| Relationship with Dangerous Goods Declarations | Practical cross-checking of dangerous goods declarations, SDS, invoices, and physical markings. | Templates and examples of dangerous goods declarations are covered in the Dangerous Goods Declaration article. |
| Differences from the IATA Dangerous Goods Regulations | Focuses on differences in packaging, quantity limitations, labeling, and acceptance conditions between maritime and air transport. | Detailed air dangerous goods transport regulations are covered in the IATA Dangerous Goods Regulations article. |
| Acceptance Conditions of CFS, Warehouses, and Shipping Lines | Covers differences between regulatory classification and actual acceptance by CFS, warehouse storage, and shipping lines. | Details of CFS acceptance conditions are covered in the CFS Dangerous Goods Handling article. |
| Stowage, Segregation, and Compatibility | Practical checks on whether dangerous goods can be loaded together in the same container or alongside general cargo. | Detailed interpretation of segregation tables per hazard class should be confirmed with the IMDG Code text and specialized references. |
| Transshipment Ports and Undeclared Dangerous Goods | Restrictions at transshipment ports and initial response procedures when undeclared or misdeclared dangerous goods are discovered. | Legal liability, cost allocation, and claims after incidents are covered in the Cargo Damage & Cost Responsibility article. |
Overview of the IMDG Code
The IMDG Code establishes specific transport requirements for each type of cargo in the maritime transport of dangerous goods.
It covers classification, packaging, labeling, container transport, stowage, segregation, and emergency response related to dangerous goods.
Dangerous goods cannot be handled the same way as general cargo in maritime transport. Depending on the hazards involved, it is necessary to confirm declarations, packaging, markings, stowage, segregation from other cargo, carrier acceptance, and CFS or warehouse acceptance.
Freight forwarders must review the SDS and dangerous goods declaration as soon as the shipper indicates "this is dangerous goods," then determine the classification and transport conditions according to the IMDG Code.
Key Items to Check for Marine Dangerous Goods
For dangerous goods regulated under the IMDG Code, it is essential to verify not only the UN number and hazard class but also packaging, labeling, stowage, segregation, marine pollutant status, and acceptance conditions of the shipping line, CFS, and warehouse.
| Check Item | What to Confirm | Possible Issues from Insufficient Confirmation | Practical Measures |
|---|---|---|---|
| Dangerous Goods Applicability | Confirm whether the cargo qualifies as dangerous goods under the IMDG Code. | Proceeding as general cargo may lead to stoppage during shipping line or CFS acceptance checks. | Cross-check SDS, GHS labeling, product specifications, and manufacturer documentation. |
| UN Number | Confirm the applicable UN number for transport. | The shipping line or CFS will not be able to judge acceptance eligibility. | Verify against the transport information section of the SDS and the dangerous goods declaration. |
| Proper Shipping Name | Confirm the Proper Shipping Name is correctly stated. | Discrepancies arise in dangerous goods declarations, SDS, or shipping line confirmation. | Verify the UN number together with the Proper Shipping Name. |
| Hazard Class and Subsidiary Risks | Confirm that both primary and subsidiary hazards are identified. | Labeling, segregation, stowage, and compatibility checks cannot be properly performed. | Cross-check SDS, dangerous goods declaration, and external labels. |
| Packing Group | Confirm whether a packing group classification is required for the cargo. | Packing standards and acceptance conditions cannot be verified. | Confirm in conjunction with packaging, quantity, and cargo packaging form. |
| Packaging and Containers | Confirm that packaging and containers are suitable for marine transport. | May result in repacking after in-gate or refusal of acceptance. | Confirm with the shipper, packer, and dangerous goods specialists. |
| Labels and Marks | Confirm the need for external labels, UN number markings, container placards, and marine pollutant marks. | Incorrect or missing markings may lead to in-gate refusal or shipment delays. | Verify with photos of external packaging or documentation before in-gate. |
| Stowage and Segregation | Confirm whether mixed stowage with other cargo is allowed, segregation requirements, and container stowage arrangements. | Issues will arise during LCL consolidation or container stuffing. | Clarify with CFS, consolidators, and the shipping line. |
| Marine Pollutant | Confirm whether the cargo is classified as a Marine Pollutant. | May cause omission in declarations or missing marks. | Verify against SDS, dangerous goods declaration, and external markings. |
| Acceptance by Shipping Line, CFS, and Warehouse | Confirm whether the shipping line, CFS, warehouse, and trucking company will accept the dangerous goods. | Even if allowed by regulations, practical acceptance and shipment may be denied. | Separate the confirmation of regulatory classification from acceptance capability checks. |
Differences from the IATA Dangerous Goods Regulations
The IMDG Code governs the transport of dangerous goods by sea, whereas the IATA Dangerous Goods Regulations apply to air transport.
Even for the same cargo, packaging, quantity restrictions, labeling, and acceptance requirements may differ between maritime and air transport. Some cargo not accepted by air may be accepted by sea, but sea transport could still be subject to restrictions based on carrier, CFS, port, or transshipment port conditions.
| Comparison Item | IMDG Code | IATA Dangerous Goods Regulations | Practical Notes for Freight Forwarders |
|---|---|---|---|
| Transport Mode | Maritime transport. | Air transport. | Dangerous goods classification must be reassessed when the mode changes. |
| Transport Environment | Checks assume shipboard, container, CFS, port storage, and transshipment ports. | Checks assume aircraft, airport warehouses, pressure and temperature changes, and cargo space. | Restrictions and verification points differ even for the same UN number. |
| Packing Standards | Packaging suitable for maritime transport is required. | Packaging suitable for air transport is required. | Packing allowed for sea may be prohibited for air shipment. |
| Quantity Limits | Check container load, carrier conditions, and port/CFS acceptance restrictions. | Check air-specific limits such as per package, per shipment, passenger vs. cargo aircraft. | Air transport may have stricter limits even for small quantities. |
| Labels and Markings | Verify maritime dangerous goods labels, UN numbers, container placards, and marine pollutant marks. | Verify air dangerous goods labels, Cargo Aircraft Only markings, lithium battery labels, etc. | Do not confuse maritime and air transport marking requirements. |
| Documentation | Mainly marine dangerous goods declarations, SDS, and checks with carriers, NVOCCs, and CFS. | Mainly air dangerous goods declarations, airline acceptance confirmations, and airport warehouse checks. | Even the same SDS requires mode-specific confirmation. |
| Acceptance Criteria | Acceptance depends on carriers, NVOCCs, CFS, dangerous goods warehouses, port regulations, and transshipment restrictions. | Acceptance depends on airlines, flight, aircraft type, passenger vs. cargo aircraft classification, and courier company policies. | Even if regulations permit, carriers or facilities may refuse acceptance. |
| Lead Time | Dangerous goods approval, CFS in-gate deadlines, container stuffing, and loading checks may extend lead times beyond general cargo. | Dangerous goods verification, airline pre-approval, document checks, and warehouse in-gate conditions may cause longer lead times. | Dangerous goods information should be confirmed from the quotation stage onward. |
For maritime and air transport, even the same UN number requires different practical confirmation points and restrictions. Freight forwarders need to verify requirements separately for each transport mode.
Relationship with UN Number and Proper Shipping Name
Under the IMDG Code, dangerous goods are organized based on the UN number and proper shipping name.
Declarations must use the proper shipping name prescribed by transport regulations, not product names or common names.
For example, even if the invoice lists "paint," "adhesive," "cleaner," or "fragrance," the IMDG Code may classify the cargo under a different proper shipping name.
| Items to Verify | Details to Check | Notes | Actions if Discrepancies are Found |
|---|---|---|---|
| Invoice Description | Check the commercial or product name, and common names used in the supply chain. | May not match the proper shipping name required by transport regulations. | Confirm the applicable product with the shipper or manufacturer. |
| SDS Transport Information Section | Verify the UN number, proper shipping name, hazard class, packaging group, and marine pollutant status. | Older or incomplete SDS may not provide sufficient information for classification. | Obtain the latest SDS, dangerous goods classification documents, or manufacturer confirmation letters. |
| Dangerous Goods Declaration | Check the declared UN number, proper shipping name, quantity, packaging, and labeling information for maritime transport. | Verify consistency with the SDS and actual cargo markings. | If inconsistencies exist, revise the declaration before submission. |
| Cargo Labels and Exterior Markings | Confirm dangerous goods labels, UN number, marine pollutant markings, and case marks. | Discrepancies between documentation and cargo markings may cause holds at the CFS or shipping line. | Conduct photo verification and inspection of packaging prior to in-gate. |
Freight forwarders should not rely solely on the invoice description but must also confirm the transport information section of the SDS and the dangerous goods declaration.
Relationship with SDS
The transport information section of the SDS may include the UN number, proper shipping name, hazard class, packaging group, and marine pollutant status.
When confirming maritime transport conditions under the IMDG Code, the SDS is a primary reference document. However, the mere presence of an SDS is not sufficient to determine whether transportation is permitted.
| SDS Condition | Practical Notes | Action | Parties to Confirm With |
|---|---|---|---|
| UN number and hazard class are listed on the SDS | Proceed to confirm maritime transport conditions, but acceptance by the carrier or CFS is not guaranteed. | Check dangerous goods declarations, packaging, labels, CFS acceptance, and carrier acceptance conditions. | Shipper, manufacturer, carrier, CFS |
| Transport information section on the SDS is blank | It is impossible to determine if the cargo is dangerous goods for transport purposes. | Confirm with the shipper, manufacturer, or dangerous goods specialists and obtain supporting classification documentation. | Shipper, manufacturer, dangerous goods specialists |
| SDS is outdated | Hazardous properties or transport information may have been updated. | Obtain the latest SDS and verify consistency with the dangerous goods declaration. | Shipper, manufacturer |
| SDS content is primarily based on air transport | Maritime transport conditions may not be fully determined. | Confirm handling under the IMDG Code, marine pollutant status, and carrier requirements in addition. | Shipper, manufacturer, carrier |
| SDS indicates cargo is non-dangerous goods | Additional verification may be needed depending on the proper shipping name, ingredients, GHS labeling, and actual cargo markings. | Obtain non-dangerous goods certificates, manufacturer statements, and product specifications. | Shipper, manufacturer, CFS, warehouse |
| SDS does not match the actual cargo labels | This may indicate an outdated SDS, SDS for a different product, or labeling errors on the cargo. | Cross-check photos of the cargo, product model number, and the latest SDS. | Shipper, manufacturer, warehouse |
Relationship with the Dangerous Goods Declaration
When transporting dangerous goods by sea, the content of the Dangerous Goods Declaration is critical.
The Dangerous Goods Declaration includes the UN number, proper shipping name, hazard class, subsidiary risks, packing group, quantity, packaging type, marine pollutant status, and emergency contact information.
Freight forwarders need to verify that the Dangerous Goods Declaration matches the SDS, invoice, packing list, actual cargo labels, and external markings. If this information does not align, acceptance confirmation by the shipping line, CFS, or warehouse may be halted.
When SDS and Dangerous Goods Declarations Contradict
If the SDS and dangerous goods declaration details do not match, the freight forwarder must not submit them as-is to the shipping line or CFS.
| Example of Contradiction | Issue | Recommended Action | Materials/Contacts to Confirm |
|---|---|---|---|
| Different UN numbers in SDS and dangerous goods declaration | Could indicate different cargo, classification, or outdated documents. | Clarify which classification applies for marine transport. | Shipper, manufacturer, latest SDS, dangerous goods classification documents |
| SDS lists non-dangerous goods, declaration treats as dangerous | Documents are inconsistent, preventing shipping line and CFS from making a decision. | Obtain manufacturer confirmation or classification documents to finalize handling approach. | Shipper, manufacturer, shipping line, CFS |
| SDS indicates marine pollutant but declaration does not | May lead to underreporting or missing markings for marine pollutants. | Confirm applicability, and if needed, update declaration, external labeling, and notify the shipping line. | Shipper, manufacturer, shipping line, CFS |
| Quantity or packaging details on declaration differ from actual cargo | Cannot verify packaging, labeling, container stowage, or segregation requirements. | Cross-check packing list, photos, and packaging details; then correct the declaration. | Shipper, warehouse, packer |
| Product name on SDS differs from name on invoice | Possible use of SDS for a different product. | Confirm product name, model number, manufacturer, and composition; obtain correct SDS. | Shipper, manufacturer |
| Differences in hazard class or subsidiary risk | Cannot determine required labels, segregation, stowage, or shipping line acceptance conditions. | Compare SDS, dangerous goods declaration, and shipping line requirements. | Shipper, manufacturer, shipping line |
When contradictions exist, cross-check the SDS, dangerous goods declaration, actual cargo, and manufacturer verification documents to confirm marine transport classification and conditions before proceeding with arrangements.
Discrepancies in Acceptance Decisions Among Shipping Lines, CFS, and Warehouses
Even with proper classification under the IMDG Code, actual acceptance may differ depending on the decisions of the shipping line, CFS, warehouse, or trucking company.
| Example of Discrepancy | What Happens | Parties to Confirm With | Practical Response |
|---|---|---|---|
| Shipping line accepts, CFS does not | Booking may proceed, but cargo will be held at CFS in-gate. | Shipping line, CFS, consolidator | Check CFS acceptance conditions, dangerous goods warehouse options, alternative CFS, alternative services, and next vessel availability. |
| CFS accepts, shipping line does not | Cargo can be prepared for in-gate, but cannot be loaded onto vessel. | CFS, shipping line, NVOCC | Confirm alternative shipping lines, routes, next vessel schedules, and reconfirm cargo details. |
| Shipping line and CFS accept, warehouse does not | Cargo is held up during pre-delivery storage or inland delivery arrangements. | Warehouse, delivery company, shipper | Consider using dangerous goods compliant warehouses, direct delivery, or adjusting in-gate dates. |
| Regulation permits, but shipping line's internal rules prohibit acceptance | Acceptance cannot proceed based only on IMDG Code classification. | Shipping line, NVOCC, overseas agent | Verify each shipping line’s specific dangerous goods acceptance conditions. |
| LCL consolidation prohibited, FCL possible | Issues arise from mixing cargo with others or CFS storage limitations. | CFS, consolidator, shipping line | Consider FCL shipment, alternative vessels, other CFSs, or arranging dangerous goods separately. |
| Acceptance at loading port but restrictions at transshipment port | Transshipment port may prohibit cargo transfer or temporary storage. | Shipping line, overseas agent, personnel at transshipment port | Consider direct shipment routes, alternate transshipment ports, or different shipping lines. |
| Delivery company can transport, but receiving location refuses | Cargo may be transported but rejected at CFS or warehouse. | Delivery company, CFS, warehouse | Confirm in-gate appointments, acceptance requirements, and required documentation. |
| Shipper requests general cargo treatment, shipping line and CFS require dangerous goods handling | Differences arise between shipper’s explanation and operational judgments. | Shipper, manufacturer, shipping line, CFS | Reconfirm using SDS and dangerous goods classification documentation as basis. |
For maritime dangerous goods, it is essential to separate regulatory classification confirmation from actual acceptance confirmation.
Verification of Stowage and Segregation
In the IMDG Code, conditions for stowage and segregation of dangerous goods are critical.
Loading cargoes with different hazards in the same container or adjacent spaces can increase risks such as leakage, heat generation, fire, chemical reactions, and contamination.
| Example Combination | Reason for Concern | Points to Confirm | Recommended Measures |
|---|---|---|---|
| Oxidizing substances and flammable materials | Leakage or damage may heighten the risk of combustion. | Check compatibility for co-loading, segregation requirements, and stowage conditions by the shipping line and CFS. | Consider separate containers, separate shipments, or switching to FCL. |
| Corrosive substances and metal products | Leakage can corrode metals, causing cargo damage and container deterioration. | Confirm container condition, leakage prevention measures, stowage location, and distance from other cargo. | Consider changing stowage position, adding protective materials, or separating cargo. |
| Toxic substances and food-related cargo | Contamination or odor transfer can significantly affect food-related cargo. | Verify whether mixed loading is permitted, segregation, separate container use, and CFS storage conditions. | Avoid mixed loading and consider separate containers or shipments. |
| Flammable liquids and cargo sensitive to high temperatures | Risks increase depending on temperature control and ventilation conditions. | Check container types, stowage locations, shipping line requirements, and route-related risks. | Confirm stowage conditions, shipping route, and storage environment. |
| Marine pollutant substances and containers prone to leakage | Leakage may cause environmental pollution and issues for shipping lines and port authorities. | Examine packaging, outer packaging, markings, declarations, and emergency response information. | Reinforce packaging, correct markings, and conduct additional confirmation with the shipping line. |
| Lithium battery-related cargo and heat-generating cargo | Thermal events, short circuits, and fire response can be problematic. | Confirm battery type, packaging, short-circuit prevention, and stowage conditions. | Verify shipping line and warehouse storage conditions, and co-loading acceptance. |
Even if dangerous goods themselves are accepted for carriage, combinations with other cargo in mixed loading may result in refusal by the CFS or shipping line.
Relation to Marine Pollutants
Some dangerous goods fall under the category of marine pollutants.
When cargo qualifies as a marine pollutant, in addition to the usual dangerous goods markings, special marine pollutant marks and declaration confirmations may be required.
Freight forwarders should verify marine pollutant status using the SDS and dangerous goods declaration, and accurately convey this information to the shipping line and warehouse.
| Verification Item | Details to Verify | Points of Caution | Actions if Deficiencies Are Found |
|---|---|---|---|
| SDS | Check environmental hazards, transportation section, and marine pollutant applicability. | Ensure the SDS information matches the dangerous goods declaration. | Confirm with the manufacturer or request amendments to the declaration. |
| GHS Labeling | Confirm if environmental hazard pictograms are present. | Presence of GHS environmental hazard markings serves as an initial indicator for marine pollutant status under maritime transport. | Cross-check with the SDS transportation section. |
| Dangerous Goods Declaration | Verify whether the cargo is declared as a marine pollutant. | Omitting this declaration may cause delays during shipping line approval or at in-gate. | Correct the declaration and resubmit it to the shipping line. |
| Exterior Markings | Check that all required marks and labels are properly displayed. | Improper markings may result in refusal of in-gate or require re-labeling. | Correct exterior markings before in-gate. |
GHS environmental hazard labeling provides a useful starting point to identify marine pollutant applicability under the IMDG Code. However, conclusions should not be based solely on GHS labels but made through cross-checking the SDS and dangerous goods declaration.
Precautions at Booking
Dangerous goods should be confirmed with the shipping line earlier than regular cargo.
| Check Item | Details to Confirm | Points of Caution | Recommended Action |
|---|---|---|---|
| Dangerous Goods Information | Confirm the UN number, proper shipping name, class, packaging group, quantity, and packaging condition. | The shipping line cannot decide acceptance without sufficient information. | Request missing documents from the shipper. |
| SDS and Dangerous Goods Declaration | Confirm the latest SDS, dangerous goods declaration, and dangerous goods classification data. | Approval will be halted if documents are inconsistent. | Verify all documents before submission. |
| Shipping Line Conditions | Confirm whether the shipping line accepts the specific dangerous goods. | Acceptance criteria and required documents may differ by shipping line. | Record the shipping line’s response. |
| CFS/Warehouse Conditions | Confirm if the CFS or warehouse will accept the dangerous goods. | Even if the shipping line accepts, the CFS or warehouse may reject. | Check both the in-gate and storage conditions. |
| LCL Consolidation Feasibility | Check if consolidation with other cargo is possible. | If consolidation is not allowed, FCL shipment or alternative arrangements may be necessary. | Confirm with the consolidator and CFS. |
| Labels and Placards | Confirm the need for exterior labels, markings, and container placards. | Incorrect or missing markings could result in rejection at in-gate or shipment delays. | Verify exterior markings prior to in-gate. |
| Route and Transshipment | Confirm whether the shipment is direct or involves transshipment, and check for restrictions at transshipment ports. | Acceptance may be denied due to restrictions at transshipment ports. | Confirm acceptance status across the entire route. |
Differences Between Direct Shipment Routes and Transshipment Routes
For dangerous goods, acceptance conditions may vary depending on the route, vessel, loading port, discharge port, and transshipment port.
Particularly when transshipment is involved, issues may arise concerning cargo transfer, storage, local regulations, and acceptance conditions set by shipping lines and terminals at the transshipment port.
| Check Item | Direct Shipment Route | Transshipment Route | Practical Notes for Freight Forwarders |
|---|---|---|---|
| Point of Confirmation | Primarily check the conditions at the loading port, discharge port, and shipping line requirements. | In addition to the loading and discharge ports, check conditions at the transshipment port and for the connecting vessel. | Confirm acceptance for dangerous goods across the entire route, including intermediate ports. |
| Storage Conditions | Focus is on handling during vessel stowage and at loading and discharge ports. | Temporary storage may occur at the transshipment port, making storage conditions and restrictions critical. | Confirm whether storage is allowed at the transshipment port. |
| Regulations and Operations | Focus on regulations at the loading and discharge ports and shipping line conditions. | Confirm regulations of transshipment countries and ports, terminal operations, and shipping line connection conditions. | Verify whether the shipping line’s response covers the entire route. |
| Delay Risks | Mainly depend on approval at the loading port and vessel space availability. | Delays can occur due to inability to transfer cargo at the transshipment port, failed connecting vessel bookings, or storage restrictions. | Confirm the possibility of connecting vessel availability and potential changes to transshipment ports. |
| Freight Forwarder Confirmation | Check the shipping line’s acceptance conditions at the booking stage. | Confirm dangerous goods acceptance for the entire route, including the transshipment port. | Do not treat direct and transshipment shipments under the same acceptance conditions. |
For dangerous goods, it is insufficient to simply confirm that the shipping line accepts the cargo. When transshipment is involved, it is necessary to verify whether cargo transfer, storage, and vessel connections are permissible at the intermediate port.
Comparison Table of Freight Forwarder Involvement
| Category | Practical Support | What Should Not Be Assumed Definitively | Operational Response |
|---|---|---|---|
| Stage of Checking Possible Dangerous Goods at Quotation | Request submission of SDS, product name, components, quantity, and packaging details. | Assuming cargo is general freight based solely on product name or small quantity description. | If there is a possibility of dangerous goods, place quotation conditions on hold and proceed with confirmation. |
| Stage of Receiving SDS | Verify UN number, proper shipping name, class, and marine pollutant status. | Assuming that having an SDS alone guarantees shipment acceptance. | Confirm dangerous goods declarations, shipping line conditions, and CFS acceptance. |
| Stage of Receiving Dangerous Goods Declaration | Check consistency among SDS, invoice, packing list, and physical markings. | Assuming that submitting the declaration means detailed content confirmation is unnecessary. | If inconsistencies exist, correct them before submission. |
| Stage of Confirming with Shipping Line | Verify UN number, class, quantity, route, and shipping line’s acceptance conditions. | Assuming that if the shipping line accepts, then CFS and warehouse will also accept. | Confirm conditions with CFS, warehouse, and consolidation operators as well. |
| Stage of Confirming with CFS and Warehouse | Check acceptance for in-gate, storage, labeling, and documentation requirements. | Assuming that if permitted by the IMDG Code, the site will always accept. | Confirm acceptance conditions specific to each facility. |
| Stage of Confirming LCL Consolidation | Confirm whether mixing with other cargo is allowed, isolation requirements, and stowage conditions. | Assuming that if dangerous goods can be accepted as single cargo, mixing is also possible. | If consolidation is not possible, consider switching to FCL, alternative shipments, or different CFS. |
| Stage of Using Transshipment Route | Confirm transshipment port, connecting vessel, storage acceptance, and local restrictions. | Assuming that approval by the origin port shipping line alone guarantees the entire route is acceptable. | Confirm acceptance for all transshipment ports along the route. |
| When Undeclared or Misdeclared Dangerous Goods Are Discovered | Notify relevant parties, obtain correct documentation, reconfirm, and organize records. | Continuing to handle cargo as general freight or immediately assigning liability. | Stop operations, prioritize safety confirmation and corrective measures. |
Common Practical Issues
| Case | Issue | Documents/Parties to Confirm | Recommended Actions |
|---|---|---|---|
| Late declaration of dangerous goods results in missing carrier approval deadline | Dangerous goods often require more time for approval than regular cargo. | SDS, Dangerous Goods Declaration, Carrier Response | Consider next vessel, alternate carrier, immediate document submission, and explain delay to shipper. |
| Mismatch of UN numbers between SDS and Dangerous Goods Declaration | Classification cannot be finalized, preventing carrier or CFS from accepting the cargo. | SDS, Dangerous Goods Declaration, Manufacturer Confirmation | Verify with shipper and manufacturer and correct either the SDS or declaration accordingly. |
| Deficiencies in exterior labels or container placards | May result in in-gate refusal, re-labeling, or shipment delays. | Photos of exterior, Dangerous Goods Declaration, CFS Response | Check labels, UN number, placards, and marine pollutant marks before in-gate. |
| CFS cannot accept dangerous goods of the relevant class | Even if the carrier accepts, the cargo is held up at CFS in-gate. | CFS Response, Carrier Response, Dangerous Goods Information | Consider alternative CFS, dangerous goods warehouse, switching to FCL, or using a different service. |
| LCL consolidation faces segregation issues with other cargo | Dangerous goods may be accepted alone but cannot be loaded into a mixed container. | CFS Response, Consolidator Response, Dangerous Goods Class | Evaluate consolidation acceptance, container splitting, FCL conversion, or alternative vessel options. |
| Omission of marine pollutant declaration | May be treated as incomplete marking or declaration. | SDS, Dangerous Goods Declaration, Exterior Markings | Cross-check SDS and declaration, correcting any missing required markings and declarations. |
| Dangerous goods restrictions at transshipment ports | Cargo may be accepted at loading port but not allowed for transshipment or storage at intermediate ports. | Carrier Response, Routing, Transshipment Port Conditions | Consider direct routing, alternative transshipment ports, different carriers, or next vessel options. |
| Undeclared or misdeclared dangerous goods discovered | This poses severe risks such as vessel fire or major accident, and is the most critical risk to avoid in practice. | SDS, Actual Cargo, Dangerous Goods Declaration, Responses from Related Parties | Immediately notify relevant parties and follow instructions from carrier, CFS, and warehouse for safety checks and corrective actions. |
When Undeclared or Incorrectly Declared Dangerous Goods Are Discovered
Undeclared or incorrectly declared dangerous goods pose one of the highest risks in practice, as they can lead to ship fires or serious accidents.
When discovered, such cargo should not be handled as regular freight. The relevant parties must be notified immediately, and safety verification and corrective actions should be taken.
| Step | Points to Check | Response Approach | Precautions |
|---|---|---|---|
| 1. Stop the operation | Confirm at which stage the issue was found: before in-gate, inside the CFS, before loading, or after loading. | Do not continue processing as regular cargo. | Safety confirmation takes priority. |
| 2. Notify relevant parties | Identify and confirm shipper, shipping line, NVOCC, CFS, warehouse, and other stakeholders as needed. | Share information promptly with all involved parties. | Failure to notify may escalate the incident. |
| 3. Obtain accurate dangerous goods information | Verify SDS, dangerous goods declaration, UN number, class, quantity, packaging, and labels. | Correct the details of the incorrect declaration. | Avoid making judgments based on product name alone. |
| 4. Reconfirm acceptance eligibility | Confirm whether the shipping line, CFS, and warehouse can accept the identified dangerous goods. | Decide whether to continue in-gate, arrange re-export, or opt for alternative arrangements. | Even if regulations permit, acceptance may be denied by the site. |
| 5. Clarify additional costs and responsibilities | Check costs related to repacking, re-labeling, storage, re-export, shipment delays, or cancellations. | Determine whose information omission or misdeclaration caused these costs. | Avoid hasty decisions; record the process and evidence. |
4-Column Verification Checklist
| Verification Situation | Party to Confirm With | Items to Confirm | Actions If Issues Are Found |
|---|---|---|---|
| When receiving a maritime transport quotation request | Shipper / Manufacturer | Confirm SDS, product name, components, quantity, packaging, and dangerous goods applicability. | If information is insufficient, hold the quotation conditions and request submission of documents. |
| When the SDS includes a UN number | Shipper, Shipping Line, CFS | Confirm proper shipping name, dangerous goods class, packaging group, and marine pollutant status. | Check dangerous goods declaration, packaging, labeling, and acceptance feasibility. |
| When the transport information section in the SDS is blank | Shipper, Manufacturer, Dangerous Goods Specialist | Confirm dangerous goods classification documents, non-dangerous goods certificates, and manufacturer confirmation letters. | Do not proceed treating as regular cargo without confirmed classification. |
| When receiving a dangerous goods declaration | Shipper, Dangerous Goods Declarer, Shipping Line | Confirm consistency with SDS, invoice, packing list, and physical markings. | If discrepancies exist, submit corrected documentation. |
| When arranging CFS in-gate | CFS, Consolidator, Dangerous Goods Warehouse | Confirm acceptance of the relevant class, in-gate date, storage conditions, and exterior markings. | If not accepted, consider alternative CFS, dangerous goods warehouse, or FCL shipment. |
| When confirming LCL consolidation | CFS, Consolidator, Shipping Line | Confirm whether mixing with other cargo is allowed, segregation requirements, and stowage conditions. | If mixing is not allowed, consider separate shipment, cargo separation, or conversion to FCL. |
| When using transshipment routes | Shipping Line, Overseas Agent | Confirm transshipment ports, connecting vessels, storage feasibility, and local restrictions. | If not possible at the transshipment port, consider direct shipping routes, different transshipment locations, or alternative shipping lines. |
| When undeclared or misdeclared dangerous goods are discovered | Shipper, Shipping Line, NVOCC, CFS, Warehouse | Confirm location of discovery, correct dangerous goods information, acceptance status, safety checks, and additional costs. | Do not continue processing as regular cargo; notify stakeholders and take corrective action. |
Example 1: Carrier Accepts but CFS Rejects Dangerous Goods
In this case, the shipper provided the SDS and dangerous goods declaration, and upon confirming dangerous goods booking with the carrier, the carrier responded that acceptance was possible.
However, when confirming acceptance with the CFS, they replied that dangerous goods of the relevant class could not be accepted due to their storage facilities and consolidation operations.
In this situation, acceptance by the carrier and acceptance by the CFS are separate decisions. Even if the carrier accepts the cargo, it does not guarantee that the CFS will permit in-gate.
The freight forwarder should organize alternatives such as using a different CFS, a dangerous goods warehouse, converting to FCL, other services, or the next vessel, and inform the shipper of possible schedule impacts and additional costs.
Example 2: Case of Discrepancy Between SDS and Dangerous Goods Declaration for Marine Pollutant Labeling
In this case, the SDS indicates the cargo qualifies as a Marine Pollutant, but the dangerous goods declaration does not include this designation.
Submitting documentation in this state to the shipping line or CFS may lead to delays due to incomplete declaration or insufficient external labeling.
The freight forwarder should cross-check the SDS, dangerous goods declaration, external markings, and GHS environmental hazard labels, then reconfirm the Marine Pollutant status with the shipper or manufacturer.
If the cargo is indeed subject, the freight forwarder should correct the dangerous goods declaration, external labeling, and declarations to the shipping line, then reconfirm acceptance with the CFS and warehouse before in-gate.
Example 3: Dangerous Goods Restricted at a Transshipment Port
At the port of origin, the shipping line confirmed acceptance of the cargo as dangerous goods. However, upon route verification, it was found that transshipment or temporary storage of these dangerous goods is not permitted at the transshipment port.
For dangerous goods, acceptance by the shipping line at the port of origin does not automatically guarantee transport feasibility for the entire route. Conditions at transshipment ports, connecting vessels, terminals, and local regulations may affect acceptance.
The freight forwarder should consider direct routing, alternative transshipment points, different carriers, or later vessels, and explain lead time and cost differences to the shipper.
When transporting dangerous goods involving transshipment, confirming acceptance for the entire route before booking is essential.
Example 4: Case Where Undeclared Dangerous Goods Are Discovered After CFS In-Gate
This case concerns cargo delivered by the shipper as general goods. Upon inspection at the CFS, the actual labels and SDS revealed the cargo might qualify as dangerous goods.
In this situation, continuing operations as if the cargo were ordinary goods should be avoided. Undeclared or misdeclared dangerous goods pose risks of shipboard fire or severe accidents.
The freight forwarder should promptly contact the CFS, shipping line, NVOCC, shipper, and warehouse to verify the SDS, UN number, dangerous goods class, quantity, packaging condition, and exterior markings.
Based on this, the freight forwarder should determine whether to continue acceptance, re-export, repackage, relabel, postpone shipment, or arrange alternative handling, while documenting any additional costs and the cause of the incident.
Points to Confirm with the Shipper
Even if the shipper explains, "The quantity is small, so it’s fine," "It’s a sample, so it’s fine," or "We are shipping it as general cargo," the nature of dangerous goods by sea cannot be assessed solely based on quantity or purpose.
- Whether the latest SDS is available.
- Whether the cargo qualifies as dangerous goods under the IMDG Code.
- Whether the UN number, proper shipping name, hazard class, and packaging group have been confirmed.
- Whether the cargo is classified as a marine pollutant.
- Whether a dangerous goods declaration is required.
- Whether exterior labels, UN number markings, and marine pollutant marks are necessary.
- Whether LCL consolidation is permitted or FCL booking is required.
- Whether acceptance has been confirmed with the CFS, warehouse, and shipping line.
- Whether there are restrictions at transshipment ports.
- If the cargo is not classified as dangerous goods, whether supporting documentation confirming this is available.
Common Misunderstandings
| Misunderstanding | Practical Consideration | What Should Be Checked |
|---|---|---|
| Shipment is possible if the UN number is known | The UN number alone is insufficient; the official proper shipping name, class, packing group, packaging, labeling, and stowage conditions are also required. | Confirm the SDS, dangerous goods declaration, and the shipping line’s acceptance conditions. |
| If there is an SDS, cross-checking with the dangerous goods declaration is unnecessary | If the SDS and dangerous goods declaration do not match, the shipping line or CFS may halt the acceptance process. | Verify the UN number, proper shipping name, quantity, packaging form, and marine pollutant status. |
| If the shipping line accepts it, the CFS will also accept it | Acceptance by the shipping line and acceptance by the CFS are separate decisions. | Check the CFS acceptance conditions, in-gate date, storage requirements, and whether consolidation is allowed. |
| If allowed under the IMDG Code, shipment is always possible | Even if regulations permit it, shipment may be refused based on the conditions of the shipping line, CFS, warehouse, port, or transshipment port. | Confirm the shipping line’s conditions, CFS conditions, and transshipment port restrictions. |
| There is no problem if dangerous goods are accepted individually, even for LCL consolidation | Consolidation may be prohibited due to segregation requirements or CFS operational rules. | Check whether consolidation is permitted, stowage conditions, and segregation requirements. |
| Marine pollutants can be identified just by GHS labeling | GHS labeling is an initial checkpoint, but marine pollutant classification under the IMDG Code should be confirmed using the SDS and dangerous goods declaration. | Verify marine pollutant classification, outer packaging markings, and declaration details. |
| Shipping lines automatically check transshipment ports | For dangerous goods, transshipment port handling, storage, and connecting vessel conditions may cause issues. | Confirm transshipment port rules, connecting vessel acceptance, and transshipment restrictions. |
| If undeclared dangerous goods are found, just proceed as normal cargo if urgent | Undeclared or misdeclared dangerous goods can cause serious accidents and must not be processed as normal cargo. | Stop operations, notify all relevant parties, confirm correct dangerous goods information, and check acceptance feasibility. |
Points Freight Forwarders Should Note
The IMDG Code is an essential practical regulation that freight forwarders cannot overlook when handling dangerous goods by sea.
- Dangerous goods should be confirmed at the quotation stage.
- Verify the UN number, proper shipping name, class, and packaging group together.
- Cross-check the SDS, dangerous goods declaration, actual cargo labels, and invoice.
- Confirm in advance whether mixed loading is permitted, segregation requirements, and CFS acceptance.
- Check the dangerous goods acceptance conditions for each shipping line.
- Confirm whether the cargo qualifies as marine pollutants.
- Verify acceptance conditions for the entire route, including transshipment ports.
- If there is any uncertainty, consult the shipper, manufacturer, shipping line, or dangerous goods specialists.
Summary
The IMDG Code is an international regulation that governs the classification, packaging, labeling, documentation, stowage, and segregation of dangerous goods for maritime transport.
In freight forwarder operations, the IMDG Code relates to dangerous goods sea bookings, CFS in-gate, container stowage, compatibility for mixed loading, labels and markings, dangerous goods declarations, marine pollutants, and restrictions at transshipment ports.
The key is not to memorize the text verbatim but to check the SDS, UN number, proper shipping name, hazard class, packing group, dangerous goods declaration, and stowage/segregation requirements, and to arrange these so shipping lines, warehouses, and CFS can safely accept the cargo.
For maritime dangerous goods, even if the shipping line accepts the cargo, shipments may be held up at CFS, warehouse, or transshipment ports. Confirming dangerous goods information from the quotation stage and organizing acceptance status throughout the entire transport route is fundamental to preventing shipment delays and serious accidents.
The main point of this article is to approach the IMDG Code not simply as maritime dangerous goods regulations, but as practical confirmation criteria linking SDS, dangerous goods declarations, CFS in-gate, loading compatibility, shipping line acceptance conditions, and transshipment port restrictions.
