International sea transport requirements for charcoal changed significantly on 1 January 2026, when Amendment 42-24 of the International Maritime Dangerous Goods Code became mandatory.
For charcoal producers, exporters, importers and logistics companies, the change is important because conventional wood charcoal shipped by sea must now be handled under the dangerous-goods requirements for UN 1361 – CARBON, animal or vegetable origin, Class 4.2.
For Paraguayan hardwood charcoal and White Quebracho charcoal, the new rules affect not only the documents provided to the shipping line, but also how the charcoal is produced, cooled, stored, packaged and loaded into the container.
Why is charcoal classified as dangerous goods?
Charcoal is produced through pyrolysis, where wood or other organic material is heated with limited oxygen. Although properly manufactured charcoal appears stable, it can continue to oxidize slowly when exposed to air.
This oxidation generates heat. Because charcoal is also a good thermal insulator, heat inside a large quantity of charcoal may not dissipate quickly enough. Under certain conditions the temperature can continue rising until spontaneous combustion occurs.
This is why charcoal is classified under Class 4.2 – substances liable to spontaneous combustion.
The risk is not merely theoretical. The Cargo Incident Notification System, known as CINS, has recorded numerous shipboard fires involving charcoal, including cases where the cargo had been incorrectly declared and the carrier was not aware of the actual hazard being transported.
The new rules are intended to make the preparation, declaration and carriage of charcoal more consistent throughout the international shipping industry.
What changed in 2026?
Charcoal was already listed under UN 1361 before 2026. The major change is that an important route previously used to ship qualifying charcoal outside the full dangerous-goods requirements has been removed.
Under previous editions of the IMDG Code, certain charcoal consignments could qualify for exemptions when testing demonstrated that the material did not meet the relevant self-heating criteria.
One test commonly used for this purpose was the UN N.4 self-heating test.
Under IMDG Amendment 42-24, this test can no longer be used as a basis to exempt conventional charcoal falling under UN 1361 from the IMDG dangerous-goods requirements.
The new framework introduced Special Provision 978, which establishes specific requirements for the preparation and transport of charcoal.
The amendment could already be applied voluntarily during 2025, but became mandatory internationally on 1 January 2026. Several major shipping lines began applying the new requirements even earlier.
Special Provision 978
Special Provision 978 is one of the most important parts of the new regulation because it establishes requirements that begin directly at the charcoal production facility.
Under the standard weathering method, after production the unpacked charcoal must normally be stored under cover but exposed to open air for at least 14 days before being packaged for transport.
This period begins after the pyrolysis process has been completed.
The charcoal therefore should not simply be removed from production, placed immediately into bags and loaded into an export container.
The regulation also requires the charcoal to be 40°C or below on the day it is packed into its packaging.
An alternative preparation method involving steam treatment, cooling and packaging under an inert atmosphere is also provided for, but for conventional lump hardwood charcoal production the 14-day weathering method is generally the most relevant.
For professional charcoal producers, production dates, weathering records and packing temperatures therefore become an increasingly important part of export logistics.
New container loading requirements
The regulation also establishes specific requirements for how packaged charcoal is loaded inside the container.
A minimum 30 cm headspace must be maintained at the top of the cargo transport unit.
Special Provision 978 also provides requirements concerning the arrangement of packages inside the container.
Packages may be stowed to a limited height, or alternatively arranged in separated blocks with space between them.
These requirements are intended to help manage heat accumulation and improve the safety of the cargo during transport.
This means that container loading plans for charcoal may need to be reconsidered rather than simply filling every available cubic metre of the container.
Packaging, markings and labels
UN 1361 charcoal is now handled as packaged dangerous goods for international sea transport.
The correct Proper Shipping Name is:
UN 1361 – CARBON, animal or vegetable origin – Class 4.2
Commercial descriptions such as “Wood Charcoal,” “BBQ Charcoal” or “Quebracho Charcoal” may still appear on invoices, packing lists or product packaging, but they do not replace the Proper Shipping Name required for dangerous-goods transport documentation.
Packages must carry the applicable dangerous-goods markings and Class 4.2 label.
Containers must also carry the required Class 4.2 placards.
Where individual bags are placed on pallets and their dangerous-goods labels or UN markings are no longer visible, the applicable OVERPACK marking and labelling requirements also need to be taken into account.
Shipping lines may impose additional operational requirements, so exporters should always confirm the carrier’s instructions before loading the container.
The Dangerous Goods Declaration now contains production information
Another important change concerns the Dangerous Goods Declaration, or DGD.
For UN 1361 shipments under Special Provision 978, the transport documentation must include additional information about the production and packaging of the charcoal.
This includes:
- The date of production;
- The date the charcoal was packed into its packaging;
- The temperature of the charcoal on the day it was packed.
This creates a direct connection between the factory’s production records and the maritime shipping documents.
For example, an exporter needs to be able to document when a batch completed production, when it was packaged and what its temperature was at that time.
Depending on the shipping line, additional supporting documentation may also be requested, such as weathering records, packing records, photographs or container-loading information.
Accurate factory records therefore become an integral part of the export shipment.
What does this mean for White Quebracho charcoal?
For producers of Paraguayan White Quebracho charcoal, the new regulation does not change the physical qualities that make dense hardwood charcoal suitable for professional grilling, restaurants and industrial applications.
It does, however, change how export shipments need to be prepared.
Production scheduling now has to allow sufficient weathering time.
Charcoal temperature needs to be controlled before packaging.
Packages, pallet markings and container placarding have to comply with the dangerous-goods requirements.
The Dangerous Goods Declaration must also correspond with the actual production and packing records.
Importers should expect their ocean freight bookings to be processed as dangerous-goods cargo.
This may affect booking procedures, documentation deadlines, available vessel space, freight costs and dangerous-goods surcharges depending on the shipping line and route.
What should importers consider?
Importers should discuss the dangerous-goods requirements with their supplier before the container is packed.
Trying to correct the loading arrangement or documentation once a container has already reached the port can result in delays, additional costs or rejection of the shipment.
Before shipment, the importer and exporter should confirm:
- The shipping line accepts UN 1361 charcoal on the selected route;
- The charcoal has completed the required weathering period;
- Packing temperature has been recorded;
- Packaging and pallet markings are correct;
- The container is loaded according to Special Provision 978;
- The Class 4.2 placards are correctly installed;
- The Dangerous Goods Declaration contains the required information.
Good coordination between the producer, freight forwarder, shipping line and importer is therefore increasingly important.
Safety and transparency throughout the supply chain
The purpose of the new requirements is to reduce the risk of undeclared or improperly prepared charcoal entering the international container shipping system.
For professional suppliers, compliance therefore means much more than simply adding a dangerous-goods label to the container.
It begins with the production process and continues through cooling, weathering, temperature control, packaging, traceability, documentation and container loading.
At CALIPAR, we recognize the importance of adapting charcoal export operations to these new requirements and providing customers and logistics partners with the information required for properly declared shipments.
From 2026 onward, international maritime transport of conventional wood charcoal should be planned around UN 1361, Class 4.2 and IMDG Special Provision 978.
For importers, understanding these requirements before placing an order can help avoid documentation problems, rejected bookings and unnecessary delays at ports.
For producers and exporters, the new regulations make one point particularly clear:
Safe production, correct documentation and proper dangerous-goods preparation are now essential parts of international charcoal trade.
This article relates specifically to international maritime transport under the IMDG Code. Domestic road, rail or other transport modes may be subject to separate national and international dangerous-goods regulations.
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