IMDG 42-24 vs 43-26: What Changes and How Should Companies Prepare?
Companies involved in the transport of dangerous goods by sea are currently working under an important transition in the International Maritime Dangerous Goods Code. IMDG Code Amendment 42-24 became mandatory on 1 January 2026, but the next edition, Amendment 43-26, has already been adopted and published. From 1 January 2027, administrations may allow the new amendment to be used voluntarily, before it becomes mandatory on 1 January 2028.
For shippers, freight forwarders, packers, loaders, shipping lines and dangerous goods professionals, this creates an important question: what is actually changing between IMDG 42-24 and 43-26, and when should companies start preparing?
The answer is that 43-26 should not be viewed simply as another routine update. While the basic structure and principles of the IMDG Code remain familiar, the new amendment continues the adaptation of dangerous goods regulation to developments in battery technology, electric mobility and modern logistics. Organisations dealing with batteries, battery-powered equipment and vehicles should pay particular attention.
IMDG 42-24: the current regulatory baseline
Amendment 42-24 is contained in the 2024 Edition of the IMDG Code. It could already be applied voluntarily from 1 January 2025 and became mandatory on 1 January 2026.
The amendment introduced numerous changes throughout the Code, including harmonisation with developments in the UN Model Regulations. Among the important subjects were revised provisions for marine pollutants, new and amended dangerous goods entries, updated definitions and developments concerning batteries and battery-powered vehicles.
One particularly significant development was the further incorporation of sodium-ion battery technology into the dangerous goods regulatory system. This reflected a broader trend within transport legislation. Lithium batteries are no longer the only battery technology that dangerous goods professionals need to understand.
For companies operating during 2026, Amendment 42-24 therefore remains the applicable baseline. Classification procedures, packaging instructions, documentation, marking, labelling, segregation and operational procedures should currently be based on this edition unless a competent authority specifically provides otherwise.
That position begins to change in 2027.
What is different about IMDG Amendment 43-26?
Amendment 43-26 was adopted by the IMO Maritime Safety Committee in May 2026. It may be applied voluntarily from 1 January 2027 and becomes mandatory from 1 January 2028.
The change from 42-24 to 43-26 is especially relevant because several developments concern areas that are expanding rapidly in international transport: batteries, battery systems and vehicles.
The IMO identifies updated provisions for the carriage of batteries as one of the principal elements of Amendment 43-26. The amendment also introduces clearer criteria relating to the transport of vehicles, including electric vehicles.
This is important because vehicle transport has become increasingly complicated. A vehicle may contain lithium-ion or other battery technology, while damaged or defective vehicles can present very different risks from vehicles in normal operational condition. Determining the correct transport conditions therefore requires more than simply establishing that an item is a vehicle.
Amendment 43-26 introduces Special Provision 980 concerning vehicle safety assessment and revises existing Special Provisions 961 and 962. These developments make the assessment of vehicles before maritime transport increasingly important.
Companies transporting electric vehicles, used vehicles, damaged vehicles or vehicles following accidents should therefore examine their procedures well before the mandatory 2028 implementation date.
Batteries become even more important
Battery regulation has developed considerably across successive editions of the dangerous goods regulations, and Amendment 43-26 continues this process.
The new edition includes new UN entries relating to lithium and sodium-ion battery systems. This development is significant because batteries increasingly appear not only as individual cells or batteries, but as components of larger energy storage systems, industrial installations and transportable equipment.
For dangerous goods professionals, the practical question is always whether an existing classification remains correct.
A product shipped correctly under Amendment 42-24 should not automatically be assumed to require exactly the same treatment under 43-26. Companies should compare their product database against the new Dangerous Goods List, applicable special provisions and packing requirements.
This is particularly important for manufacturers, battery distributors, freight forwarders and consignors handling newer battery technologies.
A useful transition project is therefore to identify every product in the organisation that contains lithium or sodium-ion batteries. These products can then be checked systematically against Amendment 43-26 before the new requirements become mandatory.
Electric vehicles require closer attention
One of the clearest themes of 43-26 is the treatment of vehicles.
The distinction between a vehicle that can safely be offered for transport and one that requires additional assessment can have major operational consequences. Damage to batteries, electrical systems or other components may create risks that are not immediately visible during normal booking or acceptance procedures.
The introduction of Special Provision 980 should therefore be considered not merely as a regulatory change, but as a reason for companies to review their vehicle acceptance process.
Freight forwarders and shipping companies may need more information from customers. Shippers may need better internal procedures for assessing vehicles before offering them for transport. Terminals and vessel operators may need to know whether documentation accurately reflects the condition of the cargo.
This is especially relevant to companies involved in transporting second-hand electric vehicles, damaged vehicles, salvage vehicles and vehicles following collisions, flooding or fire exposure.
The practical lesson from 43-26 is that classification and acceptance decisions increasingly depend on understanding the actual condition of the vehicle rather than merely identifying its propulsion system.
Other changes should not be overlooked
Although batteries and vehicles are among the most visible developments, Amendment 43-26 is broader than these subjects.
The amendment includes changes affecting radioactive cargo, including updated segregation distances. Consequential changes are also being made to the Emergency Response Procedures for Ships Carrying Dangerous Goods, generally known as the EmS Guide.
Companies should therefore avoid approaching 43-26 as if it were exclusively a lithium battery amendment.
Dangerous goods compliance requires examining the entire chain. A regulatory amendment can affect classification, packing, marking, labelling, documentation, container packing, segregation, stowage and emergency response.
Even a relatively small change to a Dangerous Goods List entry or special provision can have practical consequences for an individual shipment.
2027 will be the transition year
The most important date for many organisations will be 1 January 2027.
According to the IMO amendment cycle, 2027 is the transition year between Amendments 42-24 and 43-26. Amendment 43-26 may be applied voluntarily from that date, while 42-24 remains valid during the transition period. From 1 January 2028, Amendment 43-26 becomes mandatory.
This transition period provides companies with valuable preparation time, but it can also create confusion.
Staff should know which edition is being used. Internal procedures should clearly identify the applicable amendment, and organisations should avoid having uncontrolled mixtures of old and new instructions circulating between departments.
A company that updates its dangerous goods database to 43-26 while warehouse instructions, documentation templates and employee training remain based entirely on 42-24 could inadvertently create inconsistencies.
The transition should therefore be managed as a controlled compliance project.
Training is an essential part of the change
The IMDG Code requires shore-based personnel involved in dangerous goods transport to receive training appropriate to their responsibilities. Regulatory changes are therefore also a training issue.
Employees do not all need exactly the same level of knowledge. Someone performing administrative activities requires a different depth of training from an employee classifying dangerous goods, packing cargo transport units, preparing dangerous goods documentation or performing ship loading activities.
However, everyone whose work can affect dangerous goods compliance should understand the changes relevant to their function.
For general personnel, an IMDG Awareness course provides an important foundation in the structure of the Code, dangerous goods classes, packing groups and basic maritime dangerous goods requirements.
Employees performing specific dangerous goods functions should receive training corresponding to those responsibilities.
Prepare your personnel for changing IMDG requirements
Companies should not wait until 1 January 2028 before preparing employees for Amendment 43-26. The 2027 transition period provides an opportunity to review training records, identify affected functions and update dangerous goods knowledge in a controlled manner.
The E-learning IMDG Awareness Training (English) available through IMDG-course.com provides employees with practical knowledge of the IMDG Code and maritime dangerous goods requirements and can be completed online.
View the E-learning IMDG Awareness Training (English)
From 42-24 to 43-26: start preparing now
For most organisations, the move from IMDG 42-24 to 43-26 should not require rebuilding the entire dangerous goods management system. It does, however, require a structured review.
Companies should identify which substances, articles, batteries and vehicles they ship, compare relevant UN entries and special provisions, review packaging and documentation procedures, examine vehicle acceptance procedures and determine which employees require updated training.
Particular attention should be given to lithium and sodium-ion batteries, battery systems and electric vehicles because these are prominent areas of development within Amendment 43-26.
Amendment 42-24 remains the mandatory IMDG Code during 2026. From 1 January 2027, however, the industry enters the transition towards 43-26. Companies that use that transition period effectively will be in a much stronger position when Amendment 43-26 becomes mandatory on 1 January 2028.
The objective should not simply be to replace one edition of the IMDG Code with another. The real objective is to ensure that classification, packaging, documentation, operational procedures and employee knowledge continue to reflect the dangerous goods actually being transported.
