Notice Regarding the Implementation of the International Maritime Dangerous Goods (IMDG) Code, Amendment 41-22

IMDG Code Amendment 41-22 - China MSA Implementation Notice cover

1. Effective Date and Authority

Pursuant to the notification from the Maritime Safety Administration of the People's Republic of China (China MSA), Amendment 41-22 to the International Maritime Dangerous Goods (IMDG) Code, which was adopted by the International Maritime Organization's Maritime Safety Committee at its 105th session (Resolution MSC.501(105)), entered into force in China on January 1, 2024.

2. Summary of Major Amendments

2.1 Dangerous Goods List (DGL) and Specific Transport Conditions

New Entry: Addition of UN 3550 Cobalt hydroxide powder, containing not less than 10% respirable particles.
Revised Entries: Revisions to the special provisions, packing instructions, and stowage and segregation codes for 44 existing entries, including UN 1002 Air, compressed.
Critical Hazard Reclassification: The hazard classification for UN 1891 Ethyl bromide has been changed. Its primary hazard is now Class 3 (Flammable liquids) with a subsidiary risk of Class 6.1 (Toxic substances). Corresponding transport conditions have been adjusted.
Entry Consolidation and Renaming: The entry for UN 1169 Extracts, aromatic, liquid has been deleted. Such goods must now be transported under UN 1197, whose Proper Shipping Name (PSN) has been revised to "Extracts, liquid, for flavouring or aromatics."
Simplified Segregation: The segregation group code for strong acids in Column 16b of the DGL has been changed from "SGG1a" to "SGG1", eliminating the distinction for strong acids within segregation requirements.

2.2 Packaging and Documentation Requirements

Increased Mass Allowance for Large Packagings: A note has been added to 15 packing instructions (including P003), specifying that packagings approved under these instructions may have a net mass exceeding 400 kg.
Revised Lithium Battery Packaging Instructions: Packaging Instructions P903, P911, and LP906, which pertain to lithium batteries, have been amended. The revisions clarify the scope of P903(2), stipulate requirements for transporting multiple battery assemblies and equipment containing batteries under P911, and specify documentation requirements for shippers using LP906.
New Standards for Portable Tanks: A new Chapter 6.10 has been added, specifying the design, construction, inspection, and testing requirements for fibre-reinforced plastics (FRP) tank portable tanks.
Clarified Documentation for Specific Substances: A new paragraph added to Section 5.4.1.4.3 clarifies the PSN requirements on transport documents for "Molten substances" and "Stabilized and temperature-controlled substances."

3. Administrative and Enforcement Directives from China MSA

Unified Enforcement: Effective January 1, 2024, all China MSA authorities and other local departments responsible for waterborne traffic safety are mandated to process Dangerous Goods Declarations, Safety of Transport Approvals, and conduct on-site inspections in accordance with this amendment. Particular attention will be paid to goods with significant regulatory changes, such as lithium batteries, to ensure full compliance.
Industry Outreach and Compliance Oversight: The MSA will conduct outreach to shippers, carriers, port operators, and relevant personnel to communicate updates to the dangerous goods safety supervision framework. The aim is to ensure industry parties possess the current IMDG Code text and adhere to all regulatory requirements for the safe transport of dangerous goods.

Key Compliance Implications for Shippers

All dangerous goods declarations submitted to China MSA authorities must reflect the updated classifications, UN numbers, and PSNs as per Amendment 41-22.
Lithium battery shippers must review and update their packaging and documentation procedures to comply with revised P903, P911, and LP906 instructions.
Shippers of ethyl bromide (UN 1891) must update SDS, transport documents, and labeling to reflect the new primary hazard (Class 3) and subsidiary risk (Class 6.1).
UN 1169 is no longer valid – affected goods must be shipped under UN 1197 with the revised PSN.
New FRP portable tank requirements under Chapter 6.10 apply for relevant shipments.

Recommended Actions for Supply Chain Stakeholders
Verify Classification: Check if your products are affected by new entries, reclassifications, or consolidated entries.
Update Documentation: Ensure all shipping documents, including DGD, SDS, and packing certificates, reflect Amendment 41-22 requirements.
Review Lithium Battery Procedures: Confirm that packaging and documentation for lithium batteries comply with revised P903/P911/LP906.
Partner with Experts: Work with a freight forwarder experienced in IMDG Code compliance to navigate these changes.

Disclaimer: This guide provides general information based on China MSA implementation of IMDG Code Amendment 41-22 (Resolution MSC.501(105)) effective January 1, 2024. Always consult certified dangerous goods personnel, your freight forwarder, and the latest official IMDG Code text for specific cargo compliance requirements.