Shipborne Cargo Hazard Assessment Standard Guide
From international rules to shipper practice

"Is it dangerous goods, and which class?" has long been the most error-prone step in shipborne cargo regulation and shipper practice. A commodity name can be disguised, but its inherent dangerous properties do not disappear — as shown by several concealment cases uncovered by maritime authorities in 2026. This Standard is exactly about pulling "assessment" back from experience and grey zones onto a unified, evidence-based scale.

1. What happened: an announcement that solves the "assessment" problem

1.1 Basic information of the announcement and the Standard

1.2 Why every shipper should take this seriously

The Ningde MSA's implementation briefing of 27 October highlighted the regulatory pain point with several highly deceptive concealment cases:

• Two containers declared as ordinary feed "sprayed corn husk" turned out to contain defatted rice bran on inspection — its oil and moisture parameters meet the seed cake (UN 1386) criteria, a Class 4.2 spontaneously combustible substance;
• A consignment declared as household goods "plastic storage boxes" actually contained 1,200 high-risk compressed gas cylinders;
• Shipborne lithium batteries concealed among ordinary daily goods.

The common thread: a "down-to-earth" commodity name does not justify casual declaration. Shippers, forwarders and container packers who treat these as "ordinary cargo" plant the seeds of spontaneous combustion, leakage and explosion. The value of this Standard is to provide a unified yardstick for assessment.

2. The essence: two assessment paths × three transport states

2.1 Cargo is first divided into three transport states

Article 3 of the Standard divides shipborne cargo by transport state into two categories and three sub-categories:

2.2 Path 1: listed cargo → directly determined

Article 3 provides that listed dangerous goods and their dangerous properties are determined directly under the following rules, without re-assessment:

1. Packaged dangerous goods listed in Part 3 of the IMDG Code (Dangerous Goods List);
2. Solid bulk cargo in Group B, or both Groups A and B, listed in Appendix 1 of the IMSBC Code;
3. Bulk oils listed in Appendix I of MARPOL Annex I;
4. Bulk liquid chemicals listed in Chapter 17 of the IBC Code;
5. Bulk liquefied gases listed in Chapter 19 of the IGC Code;
6. Packaged dangerous goods suitable for water transport listed in the mandatory national standard GB 12268 (List of dangerous goods);
7. Solid bulk dangerous goods listed in Appendix B of the mandatory national standard GB 40558 (Safety technical requirements for solid bulk cargo carriage by sea).

2.3 Path 2: unlisted ≠ ordinary cargo → must be assessed

This is the Standard's key safety net: not appearing in the list does not mean there is no dangerous property. Article 3, paragraph 2 provides that cargo not listed but possessing dangerous properties in the international rules and national lists shall have its specific dangerous properties determined under Chapters 2 to 4.

3. Deep comparison: differences and common ground with international rules

This is the core of understanding the Standard. It is neither a brand-new classification system nor a simple copy of international rules, but a combination of "fully anchoring to international rules + localized implementation and safety net".

3.1 Common ground: anchoring to IMO rules class by class

The Standard's technical assessment core almost entirely cites the IMO rules verbatim, and the two are highly consistent in classification systems and assessment thresholds:

Taking solid bulk cargo as an example, the IMSBC Code groups cargo into Group A (liable to liquefaction), Group B (chemical hazards) and Group C (neither), with Group B further divided into "dangerous goods (DG)" and "materials hazardous only in bulk (MHB)". Article 19 of the Standard quotes exactly the six MHB categories of IMSBC section 9.2.3:

3.2 Differences: three layers of localized "implementation + safety net"

The common ground is "citation"; the differences lie in force, safety net and scope:

4. Shipper perspective: export vs import — very different risks

The same Standard means very different things to a "country-of-origin shipper" and a "country-of-destination consignee". Understanding this difference is key to understanding why the import link needs cargo information held even more tightly.

4.1 Export: origin-country jurisdiction, clear chain, relatively easy to comply

When China is the country of origin, the shipper is a domestic consignor directly under the MSA's jurisdiction. The cargo is declared at the loading port and inspected at the loading port, with a unified assessment standard and a clear responsible party. For businesses familiar with the rules, the whole process is evidence-based and relatively controllable as long as classification, cataloguing and declaration are done under this Standard and the IMDG/IMSBC rules.

4.2 Import: risk originates abroad, consequences fall on the domestic consignee

When China is the country of destination, the situation is different. The Chinese importing enterprise (consignee)'s assessment of the cargo's dangerous properties depends to a large extent on the truthful declaration of the overseas shipper — when the cargo is loaded at the loading port, the Chinese maritime administration cannot verify it directly as it would at the origin port. This gives rise to two risks that deserve particular attention:

• First, different countries and regions differ in their dangerous goods management standards or update pace. Some countries or regions do not fully identify the dangerous properties of certain cargo, such as the self-heating risk of agricultural bulk cargo (fishmeal, seed cake) or the gas hazard of small gas cartridges; in some places of origin these are not treated as dangerous goods. If such cargo is shipped to China as ordinary cargo, the problem often surfaces only at container inspection.
• Second, even in countries and regions with well-developed regulatory systems, shippers may under-appreciate the destination country's mandatory domestic standards. Although the international rules (IMDG, IMSBC, etc.) are globally uniform, some shippers may, out of the inertia that "our own rules are already sufficient", overlook the destination country's — that is, China's — separately enacted mandatory assessment basis, resulting in incomplete declaration or failure to supplement assessment under Chinese standards.

4.3 Three "counter-intuitive" high-risk categories to watch especially in imports

The Ningde MSA briefing already flagged several categories that "look harmless but are dangerous". The following three are particularly frequent in import scenarios and deserve close attention from cargo owners, forwarders and customs brokers:

① Fishmeal — the feed ingredient that can "burn the ship"

Fishmeal is the core protein ingredient of aquafeed, and China is one of the world's largest fishmeal importers, importing large volumes from South America and other origins year-round. But fishmeal is rich in oil and highly prone to self-heating and spontaneous combustion: unstabilized fishmeal is UN 1374 (Class 4.2, spontaneously combustible), antioxidant-stabilized fishmeal is UN 2216 (Class 9), and in bulk it is IMSBC Group B. Historically, in 1984 the "Liulinhai" vessel loaded 18,300 tonnes of fishmeal in Peru and self-ignition occurred on the homebound voyage — the lessons of such incidents fall precisely on the import leg. Under the IMDG special provisions, fishmeal loaded at a temperature above 35°C or 5°C above ambient must not be transported.

② Seed cake — the self-heating family behind "sprayed corn husk"

Seed cake is the residue left after extracting oil from oil-bearing seeds, including soybean meal, rapeseed meal, peanut cake and defatted rice bran, with over 350 million tonnes shipped by sea worldwide each year. Containing moisture and unsaturated fats, it oxidizes slowly with heat release and can self-ignite, falling under UN 1386 / UN 2217 (Class 4.2). The Ningde MSA case of "sprayed corn husk actually being defatted rice bran" is exactly this category. Only solvent-extracted soybean meal with oil ≤1.5%, moisture ≤11% and free of flammable solvent (special provision SP 142) may be shipped as ordinary cargo. As a major importer of feed meals, consignees must verify the oil-and-moisture test reports provided by overseas shippers.

③ Small gas cartridges (whipped cream chargers etc.) — the smaller, the easier to overlook

Whipped cream "chargers", CO₂ cartridges for soda makers and similar items are often only a few centimetres long and look like ordinary food tools, making them extremely easy to treat as harmless small items. But inside they hold high-pressure gas — commonly nitrous oxide (N₂O, known as "laughing gas", UN 1070, an oxidizing gas) or carbon dioxide — and when shipped as small cylinders/cartridges they are managed as Class 2 gases (aerosols UN 1950, gas receptacles/small cylinders UN 2037, etc.). Nitrous oxide has been listed in the Catalogue of Hazardous Chemicals. These "too small to notice" items are exactly the counter-intuitive dangerous goods most easily overlooked — and most likely to cause problems — in import inspection.

5. Shipper practice: assessment and preparation by transport state

5.1 Packaged cargo: check the list first, then the 9 classes

1. Step 1 — check the list: search the cargo's proper shipping name in the IMDG Code Part 3 Dangerous Goods List and GB 12268; if listed, determine the UN number, class and packing group directly;
2. Step 2 — match the 9 classes: if unlisted, assess class by class under Articles 8–16. Pay attention to the "easy to miss" items — whether perfume/alcohol/paint is Class 3 flammable liquid depends on flash point and boiling point; aerosol cans and compressed gas cylinders are Class 2; lithium batteries and seed cake meals are Class 4;
3. Step 3 — prepare documents: if dangerous goods, complete classification, cataloguing, packaging (DG packaging certificate), marking/labelling and declaration per the IMDG Code.

5.2 Solid bulk cargo: watch "liquefaction" and "MHB"

Solid bulk cargo is the most easily misjudged link, because many cargoes are "ordinary when packaged but dangerous when in bulk". Article 17 divides solid bulk dangerous goods into three situations:

• ① cargo that is packaged dangerous goods in packaged transport state;
• ② cargo that is not dangerous in packaged state but is dangerous in bulk transport;
• ③ cargo possessing both of the above characteristics.

In practice, hold two lines:

• Liquefaction (Group A): concentrates and certain ore powders can liquefy when the moisture content exceeds the Transportable Moisture Limit (TML), causing loss of ship stability. IMSBC section 7 requires "only cargo with actual moisture content below TML may be loaded" — the shipper must provide a TML certificate and moisture content certificate;
• MHB (bulk-specific hazards in Group B): under Article 19, check against IMSBC section 9.2.3 whether the cargo is MHB(CB)/MHB(SH)/MHB(WF)/MHB(WT)/MHB(TX)/MHB(CR). Typical examples include direct reduced iron (DRI) which reacts when wet/self-heats, and sulphur (formed sulphur in bulk vs UN 1350).

5.3 Bulk liquid cargo: three-way division + vapour pressure threshold

5.4 General statutory obligations every shipper must observe

1. Correct classification and cataloguing: for listed cargo, complete classification and cataloguing per international/national standards;
2. Assess unlisted cargo: for cargo suspected hazardous but not found in the lists, strictly assess its dangerous properties under the Standard, and submit professional appraisal documents if determined dangerous;
3. Truthful information delivery: before delivery for carriage, fully provide the carrier with the cargo's proper shipping name, hazardous properties, protective measures and emergency response, and report to the maritime administration;
4. No concealment or misdeclaration: never present dangerous goods as ordinary cargo.

6. A one-page checklist for shippers

1. ✅ Confirm the transport state: first distinguish packaged, solid bulk or bulk liquid — the three states follow different assessment paths;
2. ✅ Check the list first: cargo listed in IMDG, IMSBC, MARPOL, IBC, IGC, GB 12268 or GB 40558 is determined directly;
3. ✅ Assess when not found: for cargo with self-ignition, flammability, corrosion, thermal runaway or water-reactivity risk, assess item by item under Chapters 2–4 and obtain a transport condition appraisal report from a professional agency;
4. ✅ Watch bulk especially: for solid bulk, watch Group A liquefaction (TML) and Group B MHB; for bulk liquid, watch the 0.28 MPa vapour pressure threshold;
5. ✅ Screen high-risk categories: feed meals, lithium batteries, compressed gas cylinders and powders are concealment-prone — cargo owners, forwarders and packers should verify carefully;
6. ✅ Close the document loop: dangerous goods declaration + DG packaging certificate + appraisal documents + report to MSA — none may be missing.

Appendix: regulations referenced