Dangerous Goods from China: IMDG 42-24, IATA DGR 67 and the Documents Carriers Ask For

Two rulebooks, one effective date

Dangerous goods rules move on a two-year cycle, and 2026 happened to put the sea and air editions on the same date.

On the sea side, IMO's Maritime Safety Committee adopted Amendment 42-24 to the IMDG Code at its 108th session through resolution MSC.556(108). Administrations could apply it voluntarily from 1 January 2025. It became mandatory on 1 January 2026. The UK Maritime and Coastguard Agency's notice MIN 715 puts it plainly: Amendment 42-24 "can be used on a voluntary early adoption basis from 1 January 2025 and becomes mandatory internationally and in the UK on 1 January 2026."

Chinese reporting on the resolution adds the detail that matters most to a shipper: the mandatory date is 1 January 2026 with no transitional period (无过渡期). There was no grace window in which 41-22 remained acceptable. If a booking made in 2026 still carried a 41-22 classification, it was already wrong.

On the air side, the 67th edition of the IATA Dangerous Goods Regulations took effect on 1 January 2026. IATA's own lithium battery guidance document states the headline change: "From 1 January 2026, lithium-ion batteries that are packed with equipment and vehicles powered by lithium ion or sodium ion batteries must be offered for air transport with the battery at a reduced state of charge, unless otherwise approved by the relevant States."

The UN number that changed underneath you

This is the change with the most practical damage in it, because nothing about the cargo changed. Only the number did.

Before 42-24, an electric vehicle shipped from China went out as UN3171, battery-powered vehicle. Under 42-24 that entry no longer covers a lithium-ion vehicle. The code now has four separate vehicle entries, and UN3171 was narrowed to what is left.

China Customs confirmed the new entry in a policy session published in April 2026, answering a shipper asking how to declare UN 3556:

42-24 also added entries that did not exist before — fire suppressant dispensing devices (UN 0514 and UN 3559), disilane (UN 3553), gallium contained in manufactured articles (UN 3554) — and revised transport conditions elsewhere, including a requirement that UN 3536 lithium batteries be stowed on deck only.

State of charge: where 30% is mandatory and where it is only advice

The 30% figure gets repeated as if it applied to everything with a cell in it. It does not. It splits four ways, and two of the four are not mandatory.

Shipping above 30% is not automatically impossible. IATA's wording is that cells and batteries above the limit "may only be shipped with the approval of the State of Origin and the State of the Operator under the written conditions established by those authorities." That approval takes time. It is not something to discover at the acceptance desk.

The distinction that trips people up is packed with versus contained in. A laptop with its battery installed is contained in. A power tool shipped with a spare battery loose in the same case is packed with. The classification follows how the battery is physically presented, not how the product is sold.

UN3480 and UN3090 do not go on passenger aircraft

The ICAO Technical Instructions list both UN3480 lithium ion batteries and UN3090 lithium metal batteries as FORBIDDEN for passenger aircraft. The cargo aircraft column points to packing instruction 965.

UN3481 and UN3091 — batteries packed with or contained in equipment — are permitted on passenger aircraft within quantity limits.

For anyone booking air freight out of China this translates into something concrete: a standalone battery consignment needs freighter capacity. It cannot be priced or planned as belly-hold space on a passenger rotation, and it will be refused if tendered that way.

危包证 is two certificates, not one

Everyone in Chinese export uses the word 危包证. China Customs has said publicly that the word covers two separate documents issued at two different points in the chain.

To apply for the use-inspection certificate, Customs lists five documents: the packaging inspection application form, the packaging performance certificate, the factory's own inspection record or a product conformity declaration, the dangerous characteristics classification and identification report, and the export sales contract.

Two further things worth knowing. The maritime authority checks the use-inspection certificate — in Customs' own words, "海事部门会验核出口危险货物包装使用鉴定结果单." And the certificate carries a validity period; Customs' advice is simply that it must be used within it, so check the date on your own copy rather than assuming last year's is still good.

When you do not need one

Three exemptions come straight from Customs:

• Special provision 188. "符合相应运输方式危险货物规则188条款内容的，可不向海关申请包装使用鉴定，但需要在每个包装件上粘贴或者悬挂相应的锂电池组标记." Lithium batteries meeting SP188 skip the use inspection, but every package still needs the lithium battery mark.
• Battery installed on the vehicle. If the lithium battery ships assembled on the vehicle it powers, no use inspection. If it is removed from the frame, use inspection is required.
• Limited and excepted quantities. Customs' own example is 53% baijiu, UN3065, packed six bottles of no more than one litre per carton, which meets the IMDG limited quantity conditions and needs no use inspection.

危险化学品 and 危险货物 are two different lists

These two terms get used interchangeably in export conversations and they are not the same test. Customs describes them as "源自不同法律规章的两个概念" — two concepts from different legal instruments. One is about chemical safety, the other about transport safety.

The overlap is partial in both directions. Lithium batteries are dangerous goods without being hazardous chemicals. Boric acid is a hazardous chemical without being a dangerous good. UN3077, Class 9 environmentally hazardous substance, is not in the hazardous chemicals catalogue, so the PRC Law on the Safety of Hazardous Chemicals does not apply to it — but it is still Class 9 for transport.

Where they collide, both regimes apply. Customs: "如果您出口的危化品同时属于危险货物，还需要满足危险货物运输的包装要求."

For documentation, the safety data sheet follows GB/T 16483 on content and section order together with GB/T 17519 on compilation. Sixteen sections, and Customs is explicit: "不得随意变更顺序，不得空项" — the order may not be changed and no section may be left blank. Labels for the domestic market follow GB 13690, GB 15258 and the GB 30000.2–29 series; for export, GAC Announcement 2020 No.129 requires the label to meet international rules or the destination country's technical requirements.

Magnetised cargo: the 2.1 metre and 4.6 metre test

Magnetised material is UN2807, Class 9, handled under IATA packing instruction 953. The test is done on the finished, packed shipping unit — not on a sample component — because packaging, quantity and orientation all change the reading.

The reference value is a compass deflection of 2 degrees, which equals 0.418 A/m or 0.00525 gauss. China's national standard revision for 危险货物 磁性试验方法 restates the same numbers: "罗盘指针产生2度偏转时的磁场强度为0.418 A/m（0.00525高斯）."

One caveat worth stating plainly: these thresholds are air thresholds from the IATA and ICAO rules. Sea carriage does not use the compass test. If you are moving magnetic assemblies by ocean, confirm the carrier's own position before you book rather than assuming the air rule transfers.

Six reasons a dangerous goods booking gets refused

1. The UN number came from the previous amendment. A lithium-ion vehicle still declared UN3171 is mis-declared under 42-24.
2. State of charge above 30% under PI 965 or PI 966 with no written approval from the State of Origin and the State of the Operator.
3. UN3480 or UN3090 tendered for a passenger flight. Both are forbidden there.
4. No use-inspection certificate, or one that has expired. Customs inspects and issues batch by batch, so last shipment's copy is not this shipment's copy.
5. No UN38.3 test summary for the cell or battery type. The eight tests are T1 through T8.
6. A hazardous chemical declared as ordinary goods. Goods in the catalogue are statutory inspection commodities. Under the implementing regulations of the commodity inspection law, statutory export goods that have not been inspected, or that fail inspection, may not be exported, and Article 45 provides for administrative penalty.

Documents checklist for a dangerous goods export from China

Classification is the shipper's legal responsibility, and final acceptance of a dangerous goods booking always rests with the carrier and the vessel or aircraft operator. This page describes the rules, not a commitment that any given booking will be accepted.

Frequently asked questions

References

• IATA, Lithium Battery Guidance Document — state of charge requirements by packing instruction, effective 1 January 2026. iata.org
• UK Maritime and Coastguard Agency, MIN 715 (M) — adoption of IMDG Amendment 42-24, mandatory 1 January 2026. gov.uk
• IMO Maritime Knowledge Centre, CAB 334 — IMDG Code 2024 (Amendment 42-24) publication note. imo.org
• ICAO Dangerous Goods Panel, DGP/26 working paper — UN3480 and UN3090 shown as forbidden for passenger aircraft in Table S-3-1. icao.int
• 中华人民共和国海关总署, 转危为安（海关政策直通车㉔）, 2026-04-12 — 危包证 composition, SP188 exemption, UN 3556, 危险化学品 vs 危险货物, SDS requirements. customs.gov.cn
• 《中国海关》, 从爆炸式铆钉合规出境看危险货物海关监管, 2025-07 — the five-step dangerous goods export inspection flow. chinacustoms.gmcmonline.com
• 全国标准信息公共服务平台, 《危险货物 磁性试验方法》国家标准修订项目 20231814-T-469 — 0.418 A/m and 0.00525 gauss thresholds. std.samr.gov.cn

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