With the mandatory implementation of the IMDG Code 42-24 Amendment just around the corner on January 1, 2026, a pivotal adjustment to the classification of battery-powered vehicles in international maritime dangerous goods transportation is set to take effect. The long-standing UN3171 classification, which previously covered all battery-powered vehicles and equipment uniformly, will be drastically restricted, and lithium-ion battery-powered vehicles must now be declared under the newly added UN3556 classification. As the countdown to the deadline enters its final month, are exporters fully prepared for this regulatory shift?
The amendment, officially adopted through Resolution MSC.556(108) by the International Maritime Organization (IMO) Maritime Safety Committee at its 108th session, marks a significant move toward "refined classification and precise risk control" . Prior to this revision, the UN3171 classification was a one-size-fits-all label for various battery-powered vehicles, failing to address the distinct risks posed by different battery types. Under the new rules, UN3171 will be limited exclusively to vehicles and equipment powered by wet-cell batteries, sodium-metal batteries, or sodium-alloy batteries when transported with installed batteries . In contrast, three new UN numbers have been introduced to cover other battery-powered vehicles: UN3556 for lithium-ion battery-powered vehicles, UN3557 for lithium-metal battery-powered vehicles, and UN3558 for organic sodium-ion battery-powered vehicles.
This classification refinement is accompanied by stringent new requirements for packaging, marking, and stowage, which directly impact operational practices. For vehicles falling under UN3556, UN3557, and UN3558, the newly added Packaging Instruction P912 mandates that vehicles must be secured in robust, rigid outer packagings made of suitable materials. These packagings must have sufficient strength to prevent accidental movement or activation of the vehicle during transit . Notably, while the packaging design type does not require inspection certification, specific securing measures are mandatory to protect the batteries from damage. For vehicles with a net weight of 30 kg or more, options include crating, securing to pallets, or unpackaged transport if the vehicle can remain upright independently and protect its battery.
Marking and labeling requirements have also been updated to enhance visibility throughout the transportation chain. Packages containing UN3556 vehicles must display the 9A label (minimum size 100mm×100mm), while transport units must bear corresponding placards (minimum size 250mm×250mm) . This replaces the previous general Class 9 label used for UN3171, ensuring clearer identification of the dangerous goods nature. Additionally, the stowage category for UN3536 (lithium batteries installed in transport units) has been revised to Category D with stowage codes "SW1" and "SW2", requiring such shipments to be stowed on deck only, away from heat sources and living quarters .
The transition period, during which both UN3171 and UN3556 could be used concurrently, is set to end on December 31, 2025 . Industry reports indicate that some shipping companies have already begun refusing bookings under UN3171 for lithium-ion battery-powered vehicles, urging exporters to complete the switch early . Key preparation tasks for enterprises include reviewing their shipping lists to confirm the correct new UN numbers for their products, updating material safety data sheets (MSDS) – particularly Section 14 on transportation information – and obtaining revised shipping appraisal reports . Staff training for declarants and packers is also critical to avoid compliance errors due to operational inertia.
Authorities, including China MSA, have issued warnings about potential clearance delays or cargo detentions for non-compliance . The amendment is part of a global regulatory alignment, with the International Air Transport Association (IATA) also adopting the new UN numbers in the 66th edition of its Dangerous Goods Regulations (DGR), which enforced the switch from UN3171 to UN3556 for air transport on March 31, 2025.
As the mandatory implementation date approaches, industry experts emphasize the importance of proactive communication with freight forwarders and shipping companies to navigate potential system inconsistencies during the transition . For exporters of new energy vehicles, electric scooters, handling robots, and other battery-powered equipment, timely adaptation to the new regulations will be crucial to maintaining smooth international trade operations in 2026 and beyond.
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