IMDG Code Special Provisions 961 and 962

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In response to numerous inquiries, COSTHA, NAAHAC and IVODGA has prepared this briefing document for industry. Should you have any questions feel free to contact us.

Give guidance to shippers and vessel operators how to move fuel cell-powered vehicles.

In 2010 the International Maritime Organization (IMO) voted to re-regulate vehicles with IMDG Code Special Provisions SP961 and SP962 applicable.  The Special Provisions were introduced as a way to limit the amount of dangerous goods contained within vehicles when hazard communication is not provided.  Further, the provisions identified exceptions to hazard communication when dangerous goods are present in certain quantities.

Regulation(s) Title:
International Maritime Dangerous Goods Code (IMDG), Amendment 36-12

Regulation Status: 
Implementation Date(s) or Timeline of Regulation:
Authorized January 2013, mandatory January 2014 

Regulatory Summary:
When shipping vehicles or equipment under the IMDG Code, UN3166 and UN3171 apply.

UN3166 includes:

  • engine, internal combustion or vehicle, flammable gas powered or

  • engine, internal combustion or vehicle flammable liquid powered or

  • vehicle, fuel cell, flammable gas powered or

  • vehicle, fuel cell, flammable liquid powered.

Special Provisions (SP) applicable to UN3166: 312, 356, 961, 962

SP312 identifies which entry should be used if the vehicle is powered by a fuel cell or plant internal combustion engine

SP 356 states metal hydride storage systems installed in vehicles, vessels or aircrafts or in completed components or intended to be installed in vehicles, vessels or aircrafts shall be approved by the competent authority before acceptance for transport.



Lithium Ion Batteries

Liquid Fuel


Shipping Papers


961 RO/RO not subject to the regs if conditions met

pass 38.3

No qty limit, no leakage

No qty limit, closed shut off valve



961 CONTAINER not subject to the regs if – fuel tank is empty of flammable liquids or gas, positive pressure

pass 38.3


< 2 Bar, closed shut off valve

962 Class 9 fuel shut-off valve is securely closed

pass 38.3
and protected

the lesser of 1/4 full or <250L

No qty limit, closed shut off valve





SP961 applies to vehicles which are being transported on a vessel in an area specifically designed to contain vehicles such as Roll on, Roll off vessels and other vessels which have approved designed areas. These areas do not include storage areas for containers.

Such vehicles are not subject to any conditions of the IMDG code provide there are no signs of leakage from the battery, engine, fuel cell, compressed gas cylinder or accumulator, or fuel tank when applicable.

In addition when transported by vessel, vehicles and equipment when transported in cargo transport units which comply with the following are also not subject to the conditions of the code:

  • do not contain dangerous goods,

  • flammable liquid or flammable gas fuel tanks are empty, the positive pressure in the tank does not exceed 2 bar, the fuel shut-off or isolation valve is closed and secured

  • have batteries installed which are protected from short-circuit

 (Note: these exceptions are not applicable for lithium batteries installed in vehicles or equipment)


SP962 applies if the conditions of SP961 are not met. Vehicles and equipment are assigned to Class 9 and must meet the following conditions:

Vehicles and equipment shall not show any signs of leakage from:

  • Batteries

  • Engine

  • fuel cells

  • compressed gas cylinders accumulators, or

  • fuel tanks

If the vehicle or equipment is powered by a flammable liquid, the fuel tank may:

  • be up to ¼ full or,

  • up to 250 L whichever is less

For a flammable gas powered vehicle or equipment, the fuel shutoff valve must be securely closed.  (Note: There is no limitation on the amount of flammable gas contained in the fuel tank).

All installed lithium batteries must be of a design type which successfully passed the United National Manual of Tests and Criteria, part III, subsection 38.3 or be approved by a competent authority and must be protected from damage, short circuit and accidental activation.

Additional dangerous goods such as fire extinguishers gas, compressed accumulators and airbag inflators are permitted as long as they are securely mounted in the vehicle or equipment.

If all of these conditions are met, then the marking, labeling and placarding provisions of the IMDG do not apply. The documentation requirements apply.


UN3171 includes:

·         battery  powered vehicle, or

·         battery powered equipment

Special Provisions applicable to UN3171:  240, 961, 962

SP240 specifies this entry only applies to vehicles powered by wet batteries, sodium batteries, lithium metal batteries or lithium ion batteries when installed.   Equipment containing lithium batteries must be consigned as UN3091 or UN3481. For the purpose of this special provision, vehicles are self-propelled apparatus designed to carry one or more persons or goods. Examples of such vehicles are electrically-powered cars, motorcycles, scooters, three- and four-wheeled vehicles or motorcycles, e-bikes, wheel-chairs, lawn tractors, boats and aircraft


Penalties/Fines:  Delayed shipments may occur. The penalty structure for the country of loading or unloading applies.

Note: Additional editorial changes to clarify SP961 and SP962 are expected with the next edition of the IMDG Code, Amendment 37. The Amendment will be published in 2014, authorized for use in 2015 and mandatory in 2016.


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