IMSML Web Article 8/2026: RESOLUTION MSC.556(108) AMENDMENTS TO THE INTERNATIONAL MARITIME DANGEROUS GOODS (IMDG) CODE
As usual, due to the large number of dangerous chemicals created by industry, this amendment is huge. There are two appendices, ie Appendix 1 (Parts 1-2 and Parts 4-7) and Appendix 2 (Part 3, appendices A and B, and index). The document is a whopping 939 pages in PDF form. All the provisions cannot be dealt with in a single article as the resulting write up would be unwieldy. The author intends to divide the explanation on the various issues into multiple articles. Today’s article starts with PART 1, Chapter 1.1 to Chapter 1.5.
What ships are subject to the amendments?
All ships subjected to International Convention for the Safety of Life at Sea, 1974 (SOLAS), as amended, see Paragraph 1.1.1.1. In particular, passenger ships and to cargo ships constructed on or after 1 July 2002, see Paragraph 1.1.1.2. For cargo ships of less than 500 gross tons constructed on or after 1 September 1984 and before 1 February 1992, it is recommended that Contracting Governments extend such application to these cargo ships as far as possible, see Paragraph 1.1.1.2.
Are there any parts of the amended Code which are not mandatory?
The following parts of the Code remain recommendatory, for example:
[1] Paragraph 1.1.1.8 (Notification of infringements);
[2] Paragraphs 1.3.1.4 to 1.3.1.7 (Training);
[3] Chapter 1.4 (Security provisions) except 1.4.1.1, which is mandatory;
[4] Section 2.1.0 of chapter 2.1 (Class 1 – Explosives, Introductory notes);
[5] Section 2.3.3 of chapter 2.3 (Determination of flashpoint);
[6[ Columns 15 and 17 of the Dangerous Goods List in chapter 3.2;
[7] The segregation flow chart and example in the Annex to Chapter 7.2;
[8] Section 5.4.5 of Chapter 5.4 (Multimodal Dangerous Goods Form), insofar as the layout of the form is concerned.
[9] Chapter 7.8 (Special requirements in the event of an incident and fire precautions involving dangerous goods);
[10] Section 7.9.3 (Contact information for the main designated national competent authorities); AND …
[11] Appendix B.
Are the standards provided for in the amended Code mandatory?
Yes. The Code takes precedence. Standards which do not conflict with the Code remain applicable, see Paragraph 1.1.1.6.
Are the standards in the Code also applicable to dangerous goods used in cargo transport units for cooling or conditioning purposes?
These are only subject to the provisions of Section 5.5.3. However, when carried on board as ship’s stores or equipment, these coolants and conditioners are not subject to the provisions of this Code, see Paragraph 1.1.1.7.
What can IMO do if it learns of infringements of the Code?
For transport of dangerous goods that are subject to serious or repeated infringements,, it can notify the Regulatory Authority of the relevant Member State of such infringements, see Paragraph 1.1.1.8.
How are Lithium Batteries Regulated under the new provisions?
This article will focus on the regulation of lithium cells / batteries as this is now widely used in industry as well as having the possibility of catching fire that is very difficult to put out.
By virtue of Paragraph 2.0.6.2, the following categories of lithium batteries are regulated:
[1] Lithium cells that are integral to the article. This shall meet the testing requirement of PART III, Manual Tests and Criteria, sub-section 38.3;
[2] Articles containing pre-production prototype lithium cells transported for testing;
[3] Articles containing lithium cells manufactured in production runs of not more than 100 cells.
Paragraph 2.0.6.2 makes it expressly clear that where a lithium cell is installed in an article, and such article is damaged or defective, the lithium battery shall be removed.
Shall a lithium cell incorporate a safety vesting device?
Yes. It is designed to preclude a violent rupture under conditions normally incident to transport, see Paragraph 2.9.4.2.
Shall each lithium cell incorporate an effective means of preventing external short circuits?
Yes, see Paragraph 2.9.4.3.
Shall battery containing cells or a series of cells connected in parallel be equipped with effective means necessary to prevent dangerous reverse current flow?
Yes. This includes diodes, fuses etc, see Paragraph 2.9.4.4.
What is the content of quality management under which lithium cells are manufactured?
Paragraph 2.9.4.5 requires the following to be included, ranging from: First, a description of the organisational structure and responsibilities or personnel with regard to the design and product quality, see Paragraph 2.9.4.5.1, all the way to procedures to ensure that there is no damage to the final product, see Paragraph 2.9.4.5.9.
Paragraph 2.9.4.5 also recognises the acceptability of in-house quality management programmes, and third party certification if not required.
For lithium cells that are not designed to be externally charged, Paragraph 2.9.4.6 requires the following precautionary measures to be taken: First, the lithium cells are only to be charged from the primary lithium metal cells, see Paragraph 2.9.4.6.1. Second, overcharge of the rechargeable lithium ion cell is precluded by design, see Paragraph 2.9.4.6.2. Third, the battery has been tested as a lithium primary battery, see Paragraph 2.9.4.6.3. Fourth, component cells of the battery shall be type approved to meet the respective testing requirements of the Manual of Tests and Criteria, PART III, sub-section 38.3, see Paragraph 2.9.4.6.4.
What sort of marks should there be lithium batteries (ie equally applicable to sodium batteries)?
All packages should be prepared in accordance with special provision 188, see Paragraph 5.3.2.10.1.
Under Paragraph 5.2.1.10.2, the mark shall indicate a UN number, preceded by the letters ‘UN’, for example:
[1] UN3090 for lithium metal cells;
[2] UN3480 for lithium ion cells;
[3] UN3091 for cells packed with equipment;
Note:
[a] Where a package contains cells or batteries assigned to different UN numbers, all applicable UN numbers shall be indicated on one or more marks.
[b] The mark shall be indicated the form of a rectangle or square with hatched edging.
Is there any information which supplements the proper shipping name for lithium in the dangerous goods description ?
The supplementary information is found in Paragraph 5.4.1.4.3. In addition to lithium, it is also applicable to other dangerous goods.
The technical names, other generic descriptions and proper assigned shipping names shall be supplemented with the technical or chemical names, see Paragraph 5.4.1.4.3.1.
Empty uncleaned means of containment (including packaging, IBCs, bulk containers, portable tanks, road tank vehicles) shall have the word ‘EMPTY UNCLEANED’ or ‘RESIDUE LAST CONTAINED’ before and after the dangerous goods, see Paragraph 5.4.1.4.3.2.
Other than radioactive waste, dangerous goods waste being transported for disposal shall be preceded by the word ‘WASTE’ (unless it is already part of the proper shipping name), see Paragraph 5.4.1.4.3.3.
As lithium can also be shipped in molten form, the qualifying word ‘MOLTEN’ shall be added as part of the shipping name (unless it is already a part of the shipping name), see Paragraph 5.4.1.4.3.4.
As lithium has ecological toxicity, it is a marine pollutant. If transported, it should be identified as a ‘MARINE POLLUTANT” and supplement with its recognised chemical names, together with the phrase ‘ENVIRONMENTALLY HAZARDOUS’, see Paragraph 5.4.1.4.3.6.
Shipping of ‘damaged / defective lithium cells’ should be labelled ‘DAMAGED / DEFECTIVE’, ‘LITHIUM BATTERIES FOR DISPOSAL’ or ‘LITHIUM BATTERIES FOR RECYCLING’, see Paragraph 5.4.1.4.3.8.
Could dangerous goods such as lithium be used or intended for use during transport?
Yes. This is recognised in Paragraph 5.5.4.1. In particular the device needs to be able to withstand shocks and loadings normally encountered during transport. It shall also be safe for use in dangerous environments, to which it may be exposed to.
Thank you for reading IMSML Web Article 8/2026
Stay tuned for the next IMSML Web Article 9/2026: MSC.557(108) - Amendments to the Performance Standard for Protective Coatings for Dedicated Seawater Ballast Tanks in all Type of Ships and Double-Skin Spaces of Bulk Carriers (Resolution MSC.215(82) as Amended)
Signing-off for today,
Dr Irwin Ooi Ui Joo, LL.B(Hons.)(Glamorgan); LL.M (Cardiff); Ph.D (Cardiff); CMILT
Professor of Maritime and Transport Law
Faculty of Law
Universiti Teknologi MARA Shah Alam
Selangor, Malaysia
Tuesday, 24 February 2026
Note that I am the corresponding author for the IMSML Website Articles. My official email address is: uijoo310@uitm.edu.my