IMDG 42-24 and containers lost at sea: reporting duties and cargo insurance in 2026

IMDG Amendment 42-24 has been mandatory since 1 January 2026. New duties to report containers lost at sea also took effect on that date. These are separate changes: the IMDG Code addresses dangerous goods carried by sea in packaged form, while SOLAS and MARPOL govern reporting the loss. Neither automatically entitles a claimant to an insurance payment.

For importers, exporters and operators in Spain and across Europe, the practical task is to check what is being shipped, how it is declared and which policy protects each exposure. This guide connects compliance with cargo insurance and P&I; it is not a substance-specific shipping instruction.

What is IMDG 42-24, and when did it become mandatory?

The International Maritime Dangerous Goods Code sets requirements for classification, packaging, marking, documentation, stowage and segregation of dangerous goods carried by sea in packaged form. Its 2024 edition incorporates Amendment 42-24. The IMO confirms that it became mandatory in January 2026; Administrations could apply it voluntarily during 2025.

Updating a date on a template is not enough. Businesses should review the applicable goods entry, special provisions and procedures used by each person in the logistics chain. Commercial acceptance of a booking does not itself establish regulatory compliance or insurance cover.

Two related changes with different purposes

Instrument	Subject	Parties directly affected
IMDG Amendment 42-24	Preparation and carriage of packaged dangerous goods	Participants according to their functions, including consignors, packers and documentation and transport staff
SOLAS V/31 and V/32	Reporting containers lost or observed drifting at sea	Master, company in specified circumstances and flag State
MARPOL Protocol I	Coordination of lost-container reporting with SOLAS	Parties subject to the applicable reporting regime

The IMO’s official overview of rules effective in 2026 covers both changes. Lost-container reporting is not restricted to containers carrying dangerous goods. Ordinary cargo can also end up adrift and endanger other ships.

IMDG changes businesses should review

Batteries and new technologies

The amendment introduces entries for goods such as sodium-ion batteries and battery-powered vehicles, alongside changes to packing instructions and special provisions. TT Club’s technical review describes these areas of change.

For a battery shipment, copying the classification from a previous consignment is unreliable: chemistry, configuration, whether batteries travel alone or with equipment, and their condition all matter. Competent personnel should determine the actual classification using the current Code and the manufacturer’s technical information.

Charcoal

Charcoal deserves attention because it can self-heat. TT Club and CINS explain that 42-24 removes the IMDG exemption used for certain earlier shipments. Their guidance on safe charcoal carriage provides further context.

For an importer, the practical consequence is to check the supplier, classification, paperwork and carrier acceptance before booking. A history of shipping the product as general cargo does not justify continuing that practice.

Documentation, training and container preparation

Internal checks should establish that the booking, dangerous goods declaration, applicable certificates and packing instructions describe the same consignment. A safety data sheet can provide supporting information, but it does not automatically replace the required transport document.

The IMO/ILO/UNECE CTU Code provides guidance on packing and securing cargo. It is a code of practice that is not mandatory in itself, without prejudice to incorporation into contracts or legislation. Verified gross mass, or VGM, should not be described as a new 42-24 requirement either: the relevant SOLAS requirement dates from 2016.

Containers lost at sea: who must report?

Under SOLAS V/31, the master of the ship losing containers must notify nearby ships, the nearest coastal State and the flag State without delay. The flag State reports to the IMO. Where the ship is abandoned or its report is unobtainable or incomplete, the company assumes the prescribed obligations to the fullest extent possible.

A master observing containers drifting at sea, even if they did not come from that ship, must notify nearby ships and the nearest coastal State. The recipients differ from those for a loss from the reporting ship. The provisions appear on pages 22–23 of the January 2026 SOLAS supplement.

The initial report should not wait until all details are known. Further information follows at the earliest opportunity; after a safe and practicable inspection, the number lost is verified and the required final message is sent.

For the cargo owner, maritime reporting does not replace notification to insurers. The owner should provide reliable contents, identification and hazard information to the carrier, retain evidence and open the insurance claim.

Why accurate cargo information matters

The report may require UTC time, ship identity, position, container count and dangerous goods information, including the UN number where known. An inaccurate declaration can hamper the response even where nobody could have prevented the storm that triggered the loss.

A practical preparation measure is to keep the container and seal numbers, bill of lading, invoice, packing list, dangerous goods documents and responsible contact readily accessible. This document preparation does not replace the ship’s emergency procedures.

Does cargo insurance cover a container lost at sea?

The answer requires a distinction between the interests affected.

Exposure	Insurance to examine	What should not be assumed
Loss of or damage to the goods	Cargo insurance	Covered cause, transit, insured interest, limits and exclusions
Damage to the container itself	Equipment insurance or express inclusion	Goods insurance does not necessarily insure the container
Shipowner’s or operator’s liability	P&I, subject to entry and terms	There must be liability and applicable cover
Recovery or pollution costs	Relevant policies and legal regime	These are not automatically cargo or P&I expenses
Delay and commercial loss	Specific extension, if purchased	Lost sales and delay are not equivalent to insured physical damage

Cargo insurance: cause, terms and declaration

A loss overboard may be treated differently under broad cover and named-peril conditions. Cover should not be inferred from the labels ICC A, ICC B or ICC C alone. Packing, securing, cargo characteristics, the assured’s knowledge and endorsements also matter.

A manufacturer or importer should start with its marine cargo insurance. Correctly declaring dangerous goods to the carrier does not replace disclosure of material risk information to insurers. Equally, an IMDG breach does not justify claiming that all insurance automatically disappears without examining the contract, facts and applicable law.

P&I: the operator’s liability is a separate assessment

A casualty can generate cargo claims, third-party damage or removal measures. P&I insurance for shipowners and operators must be considered against the insured interest and liabilities. It does not replace the importer’s cargo insurance or guarantee recovery of the full invoice value from the carrier.

Example: a shipment from Spain loses a container

A business exports equipment containing batteries. The shipping line reports several containers lost overboard and is establishing which units are affected. This example is hypothetical.

The logistics manager collects the unit identification, transport documents and technical declaration, notifies the broker and insurer, and asks the carrier for written confirmation. The claim is assessed against the policy and the interest the business retained under its sale contract. Any operator liabilities are considered separately.

Maritime reporting assists safety and investigation; it does not by itself establish an insured cause or the recoverable amount. Our guide to the first 48 hours after a cargo loss or damage explains notifications, reservations of rights and preservation of evidence. It is an action guide, not a universal 48-hour legal deadline.

Checklist before the next shipment

• Confirm classification against IMDG 42-24 and current corrections.

• Review documents, packaging, marking, segregation and personnel competence for the goods and each function.

• Align information between supplier, consignor, forwarder and carrier.

• Preserve evidence of packing, securing, identification and VGM where applicable.

• Check insured interest, accepted goods, route, accumulations, deductibles and limits.

• Assign responsibility for notifying the broker and insurer and preserving rights against the carrier.

Frequently asked questions

Does IMDG 42-24 apply only to dangerous goods?

Its subject is packaged dangerous goods carried by sea. Lost-container reporting has a different scope and does not depend on hazardous contents.

Must the importer report the loss to the IMO?

The SOLAS reporting chain assigns duties to the master, the company in certain circumstances and the flag State. The importer must also handle its own commercial and insurance notifications.

Does IMDG compliance guarantee an insurance payment?

No. Compliance and cover are related but separate questions. Recovery depends on the facts and contract.

Should I review my policy before importing batteries or charcoal?

Review the change of risk before shipment, alongside classification and transport requirements. A policy covering general cargo should not be assumed to accept every dangerous product.

Review the shipment and insurance before loading

Nautilux can assess the goods, route, sale terms and insurance arrangements. Request a cargo risk review and insurance quotation to compare your actual operation with the proposed cover.

Information reviewed on 9 September 2026. This guide does not replace the current IMDG Code, classification by competent personnel or legal advice on a particular case. Cover depends on the policy and the casualty.