The Cargo Incident Notification System (CINS) Charcoal Work Group have updated their “Guidelines for the Safe Carriage of Charcoal in Containers”, reflecting the updated IMDG Code requirements, Britannia P&I Club highlights.
The 2024 edition of the International Maritime Dangerous Goods (IMDG) Code included changes in the requirements applying to charcoal. This edition, incorporating Amendment 42-24, became voluntary from 1 January 2025 and mandatory from 1 January 2026. According to Britannia Club, charcoal as a cargo presents unique stowage and handling requirements and requires strict safety protocols. In addition to the fire hazard, misdeclaration is known to result in the carrier being unaware of the risk.
Understanding the risk of charcoal transport
The primary hazard associated with charcoal is self-heating. If the heat cannot be dissipated quickly enough due to the thermal insulating properties of carbon, then the cargo temperature may rise further, possibly leading to self-ignition and spontaneous combustion.
The likelihood of spontaneous combustion in charcoal may be further affected by:
- Wetting of the cargo, generating additional heat in an exothermic process
- Presence of additives such as ignition accelerants or flammable solids – typical in certain charcoal products, for example charcoal in tablet form used for water pipes (Nargila, Shisha, Hookah). This may result in lower ignition temperature, contributing to a fire incident
- Chemically unstable condition caused by the presence of organic material which did not undergo complete pyrolysis.
Charcoal may also pose other hazards:
- Explosion: charcoal dust is combustible and can form a flammable or explosive atmosphere
- Toxicity: charcoal can release carbon monoxide (CO), particularly dangerous in enclosed spaces.
Charcoal and classification of carbon cargo
As a substance liable to spontaneous combustion, charcoal is designated as Class 4.2 in the IMDG Code. The forthcoming edition of the IMDG Code requires that charcoal should always be declared and carried as dangerous goods.
In the Dangerous Goods List of the IMDG Code, charcoal is listed under the proper shipping name (PSN) of CARBON. The correct declaration for charcoal is: UN 1361: CARBON, animal or vegetable origin.
The IMDG Code classifies carbon cargoes in three categories, which may result in confusion and lead to misdeclaration of the cargo:
Changes in the requirements of the IMDG code applicable to charcoal
The 2024 edition of the IMDG Code has removed two Special Provisions (SP), previously applicable to charcoal cargoes, and introduced a new SP 978. The removed SP’s enabled exemptions from the requirements for charcoal:
SP 925 stipulated that the provisions of the IMDG Code did not apply to a consignment of carbon if it passed certain tests for self-heating substances
SP 223 exempts shipments which, when tested, do not meet the “established defining criteria for the class or division listed in column 3, or any other class or division”, except in the case of a marine pollutant.
SP 978 introduces the following, specific requirements:
For the purpose of this Code, carbon of animal or vegetable origin means carbon, generated in a production or manufacturing process, not formed in a geological process and not obtained from mining. Carbon covered by this entry is produced by pyrolysis of an organic material such as bone, bamboo, coconut shell, jute or wood.
The UN N.4 test according to section 33.4.6 of the UN Manual of Tests and Criteria shall not be used to exempt carbon of animal or vegetable origin (UN 1361) from the provisions of this Code.
Without testing, the material shall be assigned to at least packing group III.
Unless otherwise approved by the competent authority, the following provisions apply:
After production, the unpacked material shall be subject to weathering (stored under cover, but in the open air) for a minimum period of 14 days before being packaged for transport;
or after pyrolysis, steam and cooling shall be applied to the unpacked material and the material shall be packed under an inert gas atmosphere (e.g. nitrogen); packages shall then be stored under loose cover or in the open air for a minimum of 24 hours before transport.
The material shall be packed into packagings only when the temperature of the material does not exceed 40°C on the day of packing.
When stowed in a cargo transport unit, minimum headspace in the CTU of 30 cm shall be maintained, and:
The stowage height of the package(s) in the unit should not exceed 1.5 m; or the maximum block size of the packages should be 16 m3 and a minimum of 15 cm of space between blocks should be maintained.
CINS recommended practices
Cargo practices recommended by CINS Guidelines include selected requirements of the IMDG Code, combined with additional precautions to ensure the safe carriage of charcoal.
CINS Guidelines recommend that all charcoal shipments should be classified as dangerous goods, even prior to the applicability of the IMDG Code Edition 2024 (Amendment 42-24).
Further recommendations set out by CINS address the following areas:
- Container selection
- Cargo weathering and packaging
- Container packing and vanning survey
- Ship loading, container stowage and segregation
- Documentation requirements.
Preventative measures against charcoal fire incidents
When considering preventative measures, regulatory requirements and industry guidance should be supplemented by a comprehensive risk assessment. This is necessary to ensure that the measures are applicable to the circumstances of the ship, operational situation, provisions of the Safety Management System (SMS) and the business environment including terminals and customers. If needed, a gap analysis should be carried out and cargo management procedures revised as appropriate.
The following objectives should be considered:
- Cargo management and booking process should ensure that cargo containing charcoal is correctly identified and declared
- Charcoal should be pro-actively treated as dangerous goods even before the 2024 edition of the IMDG Code is in force. In particular, the cargo management process should not enable the two existing Special Provisions (SP 925 and SP 223) and ensure that all charcoal cargo intended as fuel for burning is correctly classified and declared as dangerous goods. It is recommended to align cargo management process with the forthcoming SP 978 (including the requirements for container selection, packaging, stuffing, inspection, stowage and segregation set out in SP 978)
- Where charcoal is traded under names which may conceal its dangerous nature, carriers should implement effective cargo screening, together with the appropriate “Know Your Customer” (KYC) due diligence to ensure the cargo is correctly classified and properly declared
- Carbonised material intended for manufacturing of UN 1362: CARBON, ACTIVATED has been known to be misdeclared – the cargo management process should take it into account
- The weathering report, the vanning survey, as well as other surveys in place, should effectively identify additional risk factors, such as insufficient weathering of charcoal cargo, wetting of the cargo, or the effect of chemical additives present in the cargo on its stability and propensity to self-heat
- The KYC approach may be effective in reducing the risk by proactively assessing the cargo management prior to container packing and shipping
- Accessible stowage on deck (accessible from a fixed platform, deck or a lashing bridge), exceeding IMDG requirements is recommended. Accessibility is required to enable prompt extinguishing action.
