The International Maritime Dangerous Goods Code is continuously developing in response to new technologies, new types of cargo and lessons learned from incidents involving dangerous goods at sea. The current IMDG Code, Amendment 42-24, became mandatory on 1 January 2026. However, companies involved in the maritime transport of dangerous goods should already start looking ahead. The International Maritime Organization has adopted the next revision, Amendment 43-26, through Resolution MSC.587(111). The new 2026 Edition of the IMDG Code is scheduled for publication in October 2026.
Amendment 43-26 is expected to be available for voluntary application from 1 January 2027 and will become mandatory on 1 January 2028. This makes 2027 an important transition year. Companies may still operate under Amendment 42-24 during that year, but organisations that ship significant volumes of dangerous goods would be wise to use the transition period to update procedures, software, documentation systems and employee training. IMO follows a two-year amendment cycle, allowing industry a transition period between successive editions.
Batteries continue to reshape dangerous goods transport
One of the clearest themes within Amendment 43-26 is the continuing development of rules for batteries. Lithium batteries have already become one of the most closely monitored categories of dangerous goods in international transport. Their use is expanding rapidly in vehicles, equipment, energy storage systems and industrial installations. At the same time, sodium-ion technology and battery systems combining different chemistries are becoming commercially relevant.
Amendment 43-26 responds to this development with new and revised provisions covering lithium, sodium-ion and hybrid battery technologies. Two particularly important additions to the Dangerous Goods List are UN 3563, LITHIUM METAL BATTERIES INSTALLED IN CARGO TRANSPORT UNIT, and UN 3564, SODIUM ION BATTERIES INSTALLED IN CARGO TRANSPORT UNIT. These entries are relevant to the growing market for containerised energy systems and other installations in which batteries form an integral part of a cargo transport unit.
Terminology will also be simplified. The marking currently generally referred to as the lithium or sodium-ion battery mark will become the more general battery mark. This reflects the development of battery technologies beyond the traditional distinction between lithium metal and lithium-ion batteries and makes the regulatory terminology more adaptable to future battery chemistries.
For manufacturers, consignors, freight forwarders, container packers and shipping lines, these changes mean that battery classification must receive even greater attention. It will no longer be sufficient to treat every modern battery system as if it were simply another variation of a conventional lithium-ion battery. Correct identification of the battery chemistry, configuration and method of installation will increasingly determine the applicable UN number, special provisions, packaging requirements and transport conditions.
Major changes for the transport of vehicles
The transport of vehicles is another area in which Amendment 43-26 introduces significant changes. This is particularly important because the global vehicle fleet is changing rapidly. Ships and containers now routinely carry conventional petrol and diesel vehicles, battery electric vehicles, plug-in hybrids, vehicles powered by gases and vehicles using combinations of different energy sources.
A major new element is Special Provision 980. The provision introduces a clearer requirement for the safety condition of vehicles to be assessed before they are offered for maritime transport. Consignors will therefore have a more explicit responsibility to determine whether a vehicle is safe for shipment. Vehicles showing significant damage, leakage or the effects of events such as flooding or other severe conditions cannot simply be presented for shipment without an appropriate assessment and corrective measures. Where a vehicle contains a damaged lithium battery falling under the relevant damaged-battery provisions, removal of that battery may be required before transport.
Existing Special Provisions 961 and 962 are also being revised. These provisions determine whether vehicles can benefit from certain exemptions or must comply with the normal dangerous goods requirements. The revised approach takes greater account of the type of propulsion system and fuel carried by the vehicle. This is particularly relevant to hybrid vehicles and vehicles containing both flammable liquid and gaseous fuels.
Another important practical issue concerns cargo transport units containing vehicles. Under the new provisions, placarding requirements for CTUs carrying vehicles are clarified and strengthened. This may have a direct impact on container depots, vehicle logistics companies, freight forwarders and terminals because a container carrying vehicles may require dangerous goods placards even though the vehicles themselves are being transported unpackaged. BIMCO has identified the vehicle provisions as one of the most significant operational elements being introduced through Amendment 43-26.
The broader message is clear: companies involved in shipping vehicles will need better information about the condition, propulsion technology, fuel and battery systems of the vehicles they accept for transport. A simple description such as “vehicles” will increasingly be inadequate as the basis for a dangerous goods assessment.
Changes to the Dangerous Goods List
Amendment 43-26 will also update the Dangerous Goods List in Chapter 3.2. Apart from the new battery-related entries, additions and amendments include entries associated with chlorophenols, butyl acrylates and vanadium pentoxide. These changes reflect developments in the UN Recommendations on the Transport of Dangerous Goods, which form an important basis for harmonisation between maritime, road, rail and air transport regulations.
An interesting development concerns Column 17 of the Dangerous Goods List. Column 17 contains properties and observations relating to dangerous goods entries. IMO has been working to make this information more accurate, consistent and useful. The revised approach considers information such as physical state, form, boiling point, flashpoint, toxicity and corrosivity.
This may appear to be a relatively technical change, but better information in Column 17 can be extremely valuable during cargo acceptance, stowage planning and emergency response. Knowing whether a substance is highly volatile, corrosive, toxic or likely to behave in a particular way during a fire can influence decisions made by both shoreside personnel and ships’ crews.
Technical and emergency response provisions
Amendment 43-26 also contains several more specialised technical changes. These include revised provisions relating to portable tanks and fibre-reinforced plastic service equipment. Requirements concerning design, construction, inspection and testing are being developed further as the use of composite materials in dangerous goods equipment increases.
Temperature-controlled dangerous goods are another area receiving attention. Revised provisions specify more precisely how temperature should be measured in cargo transport units, including the use of independently powered measuring devices in relevant circumstances. Such provisions are important for substances capable of dangerous self-accelerating reactions when temperature control is lost.
Changes also affect Class 6.2 infectious substances, with clarification of classification principles including the distinction between Category A and Category B. This is particularly relevant where emerging pathogens or unusual infectious materials have to be assessed for transport.
The Emergency Response Procedures for Ships Carrying Dangerous Goods, better known as the EmS Guide, are also being updated to reflect new UN numbers and revised dangerous goods provisions. MSC approved a revised EmS circular alongside Amendment 43-26. This ensures that emergency response information available to ships remains aligned with the substances and articles appearing in the revised IMDG Code.
Companies should prepare during 2027
For many organisations, the most important consequence of Amendment 43-26 will not be a completely new way of transporting dangerous goods. Instead, it will be the accumulation of many changes affecting classification, vehicle acceptance, batteries, documentation, markings, placards, packaging and operational procedures.
The transition year of 2027 therefore provides an important opportunity. Dangerous goods procedures should be reviewed against the new Code, transport management systems should be updated and employees whose duties fall within IMDG Code Chapter 1.3 should receive training appropriate to their responsibilities. Particular attention should be given to personnel accepting vehicles, batteries and containerised energy systems for maritime transport.
Amendment 43-26 demonstrates how quickly the dangerous goods environment is changing. Electric mobility, alternative energy storage technologies and increasingly complex global supply chains are creating risks that did not exist in the same form only a few years ago. Companies that wait until 1 January 2028 to study the new requirements may find themselves having to change procedures under considerable time pressure. Organisations that use 2027 as a genuine transition year will be much better prepared when Amendment 43-26 becomes the only applicable edition of the IMDG Code.
