This page sits under the Mulia Charcoal Logistics pillar and tracks what changed in 2026. For the timeless classification — what UN 1361 and Class 4.2 are — see the UN 1361 page; here we cover the new rules. Logistics overview
What changed, at a glance
The IMDG Amendment 42-24 changes that govern coconut charcoal from 1 January 2026.
- Mandatory from
- 1 January 2026
- Withdrawn
- Special Provisions 925 and 223
- Introduced
- Special Provision 978
- Lawful basis
- Declared dangerous goods only
- Packing temperature
- ≤ 40 °C
- Container headspace
- ≥ 30 cm
What changed in 2026
IMDG Amendment 42-24 became mandatory on 1 January 2026. For UN 1361 it withdrew Special Provisions 925 and 223 and introduced Special Provision 978. The practical effect: the self-heating test no longer exempts charcoal from dangerous-goods rules. The cargo must be declared and carried as IMDG Code UN 1361 Class 4.2 (spontaneous combustion), Packing Group III.
What SP 978 requires
Special Provision 978 is not just paperwork — its controls exist because contained self-heating fires have happened. Complying means the cargo is managed for that risk at source. Self-heating fire is inherent vice and is not insurable, so these prevention controls, not a policy, are the safeguard.
SP 978 requires:
- Weathering
- 14 days under cover in open air, or inert gas after pyrolysis plus 24 hours of storage
- Packing temperature
- ≤ 40 °C on the day of packing, recorded and declared
- Container headspace
- ≥ 30 cm in the container (CTU)
- Packaging
- P002 — UN-approved, sift-proof
- Declaration data
- date of production, date of packing, temperature on the day of packing
- Bulk
- Containerized bulk without packaging is not allowed
- Stowage
- Stack height no more than 1.5 m, or a maximum block of 16 m³ with at least 15 cm between blocks.
How prevention and insurance fit together The DGD data fields in the document pack
Can charcoal still ship non-DG?
No. Since 1 January 2026 there is no compliant non-DG route for UN 1361 charcoal. Any supplier quoting non-DG freight is offering a misdeclaration — and the exposure lands on the importer: carrier blacklisting, port-state detention, and liability if the cargo self-heats. We ship declared, every time.
A View from the Other Side: Is a Clean Self-Heating Test Enough to Skip Declared DG?
The honest counterargument runs like this: coconut shell charcoal, properly weathered, is a low-energy fuel that has shipped for decades, and a passing UN N.4 self-heating test demonstrates the specific cargo does not self-heat under the test regime. From that view, full Class 4.2 carriage — with its DG premium, IMO surcharge, DG handling fee, and the payload lost to ≥ 30 cm of headspace and stowage limits — looks like blanket regulation penalizing well-made charcoal for the failures of badly weathered, badly stowed product. A cost-focused importer can reasonably ask why a clean N.4 result no longer buys an exemption.
Where the objection genuinely holds: the test result is real evidence, and the cost is real — a compliant container does carry less than a brim-full one, and the surcharges are not trivial. We do not dispute either.
Where it fails, on the facts: since IMDG Amendment 42-24 became mandatory on 1 January 2026, a passing N.4 test is no longer an exemption — it is supporting evidence only. The amendment withdrew Special Provisions 925 and 223 precisely because the test-out had not stopped the fires; the controls exist because contained self-heating fires have happened, with ignition often days after loading, long after any pre-shipment test. The exposure from quoting non-DG does not sit with the supplier who quotes it — it lands on the importer, as carrier blacklisting, port-state detention, and liability if the cargo self-heats. And self-heating fire is inherent vice, which is not insurable, so a cheaper non-DG booking is not a cheaper risk — it is the same risk with the safeguard removed. The headspace and stowage payload the buyer “loses” is the margin that keeps the cargo from igniting. That is why we ship declared, every time.
What it costs, and why payload drops
Declared dangerous goods carries surcharges — a DG premium, IMO surcharge, and DG container handling — quoted by the carrier at booking. The 30 cm headspace and stowage limits also reduce how much cargo fits, so a compliant container carries less than a brim-full one. That trade-off is the price of a cargo that arrives.
Booking and the surcharge structure Worked landed-cost example (US) Headspace and box specs