From 1st Jan 2012 Vehicles with internal combustion engines are regulated by IMDG Code (35-10) for sea transport. Depending on certain factors vehicles may become hazardous or non-hazardous consignment. Special Provisions 961 & 962 assigned to UN 3166 specifies this.

Vehicle on flatrack - Photo by shashi kallada

Special Provisions 961 and 962 are shown below in tabular format so we can compare the differences easily

Special Provision 961 ( Non Hazardous Vehicles )

Special Provision 962 ( Hazardous Vehicles )

The fuel tank(s) of the vehicle or equipment powered by a flammable liquid fuel is empty and installed batteries are protected from short circuit; Vehicles and equipment shall not show signs of leakage from batteries, engines, fuel cells, compressed gas cylinders or accumulators, or fuel tank(s) when applicable;
The fuel tank(s) of the vehicle or equipment powered by a flammable gas is emptied of liquefied or compressed gas, the positive pressure in the tank does not exceed 2 bar, the fuel shut-off or isolation valve is closed and secured, and installed batteries are protected from short circuit; or  for flammable liquid powered vehicles and equipment, the fuel tank(s) containing the flammable liquid shall not be more than one-fourth full and in any case the flammable liquid shall not exceed 250 l;
The vehicle or equipment is solely powered by a wet or dry electric storage battery or a sodium battery, and the battery is protected from short circuit. for flammable gas powered vehicles and equipment, the fuel shut-off valve of the fuel tank(s) shall be securely closed;
installed batteries shall be protected from damage, short circuit, and accidental activation during transport. Lithium ion or lithium metal batteries shall meet the requirements of the United Nations Manual of Tests and Criteria, Part III,subsection 38.3, unless otherwise approved by the competent authority; and
dangerous goods required for the operation of the vehicle or equipment such as fire extinguishers, compressed gas accumulators, airbag inflators, etc., shall be securely mounted in the vehicle or equipment.
The marking, labelling and placarding provisions of IMDG Code shall not apply.

For non-hazardous consignments Shipping Lines may ask shipper to give a statement in writing stating his/her consignment meets the requirement of SP 961.

Sample Statement:

“We confirm that the vehicle meets the requirements of IMDG code Special Provision 961, the fuel tank is empty and batteries are protected from short circuit”

Lines should proactively educate the shippers  that to make vehicles as non-hazardous consignment must meet conditions laid down in SP 961 (see above).

Just writing a letter won’t make haz into non-haz!


  1. i am currently involved in a seafreight shipment of a KTTA 19 Cummins engine. it has been packed and labelled and collected for departure.
    i supplied an MSDS for engine lubricating oil and the diesel fuel ( you can smell it ) the engine has been drained but not the sump.
    according to the shipping agent, the MSDS should be for UN 3166.
    exports is not the core business of this company. were a mining and civil earthworks company.
    where on this beautiful green planet can i get my hands on an MSDS for UN3166Please assist or advise if possible.
    thank you and kind regards, Rita Woodward

    1. Dear Rita,

      Now all shipping lines have switched over to IMDG Code 37th amendment.
      Under IMDG Code 37th amendment vehicles loading on vessels other than RO-RO vessels may be hazardous or may not be hazardous.

      Conditions for Hazardous Vehicles (under UN Number 3166 ) is listed under Special Provisions 962.
      Conditions for non-hazardous vehicles are listed under Special Provisions 961.
      You may refer to my article http://shashikallada.com/2015/07/29/planes-trains-and-automobiles-imdg-code-37-14/ to understand the difference between hazardous and non –hazardous vehicles.
      If your vehicle meets the conditions of non-hazardous vehicles as laid out in special provisions 961 you may visit http://shashikallada.com/2015/07/26/shippers-loi-for-vehicles-imdg-code-37-14/ for a sample of LOI to give to the shipping line.

      If your vehicle is hazardous you may download sample LOI for hazardous vehicles at http://shashikallada.com/2015/07/26/shippers-loi-for-vehicles-imdg-code-37-14/

      I do not know which shipping line will ask for MSDS for a vehicle 


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