Dangerous Goods Ocean Shipping Documents: A Checklist Under the IMDG Code and 49 CFR


By GDZ Computer Services · Updated 2026-10-21 · 7 min read · Blog › U.S. Customs and compliance

Dangerous goods moving by sea to or from the United States are governed by two rulebooks: the IMO's International Maritime Dangerous Goods (IMDG) Code and the U.S. Hazardous Materials Regulations in 49 CFR. U.S. rules allow shipments with a vessel leg to move under the IMDG Code, but several U.S. requirements still apply. This checklist covers the documents a shipper, NVOCC and carrier each need to get right.

Key takeaways
  • The IMDG Code is mandatory under SOLAS chapter VII, and 49 CFR 171.22 and 171.25 let U.S. shipments with a vessel leg move under it, subject to added U.S. conditions.
  • The shipping description needs the UN number, proper shipping name, hazard class, packing group and total quantity.
  • Hazmat cannot be carried by vessel without a shipper's certification, and a signed container packing certificate goes to the vessel operator.
  • The carrier prepares a dangerous cargo manifest and keeps a copy for at least one year; shippers keep shipping papers for two years.
  • A 24-hour emergency response telephone number must appear on the shipping paper, and answering services do not qualify.

Two rulebooks: the IMDG Code and 49 CFR

IMO describes the IMDG Code as an extension of SOLAS chapter VII and notes that it became mandatory under the SOLAS umbrella from 1 January 2004, with some parts remaining recommendatory. It is amended on a two-year cycle, so documentation templates need checking whenever a new amendment takes effect.

On the U.S. side, 49 CFR 171.22 authorizes shipping hazardous materials in accordance with the IMDG Code, and 171.25 allows IMDG shipments to, from or within the United States by vessel, and by truck or rail, provided all or part of the movement is by vessel. The catch is in the conditions. Under 171.22(g), IMDG shipments must still meet U.S. requirements for emergency response information, training, security plans, incident reporting and PHMSA registration, as applicable.

The shipping description: five elements in order

Under 49 CFR 172.202, the shipping description of a hazardous material on the shipping paper must include:

  1. The identification number (for example, a UN number) from the Hazardous Materials Table.
  2. The proper shipping name.
  3. The hazard class or division, with any required subsidiary hazard in parentheses.
  4. The packing group in Roman numerals, where one is assigned.
  5. The total quantity, by mass or volume, with the unit of measure.

Section 172.201 adds format rules: when hazardous and non-hazardous materials appear on the same shipping paper, the hazardous entries must be listed first, printed in a contrasting color, or marked with an "X" in an "HM" column. The description must be legible and in English, and it may not contain codes or abbreviations unless the rules authorize them. Under 171.22(f), shipping paper information for imports must also be in English; a bilingual paper is permitted.

Certifications: shipper, packing and emergency contact

Three statements travel with every dangerous goods shipment by sea:

Document or statementWho provides itWhat the rule says
Shipper's certificationThe shipper (offeror)49 CFR 172.204 sets the certification wording; 176.27 says a carrier may not transport hazmat by vessel without it. For import or export shipments not moving by rail, highway or air, the shipper may certify on the bill of lading under IMDG or 49 CFR.
Container packing certificateWhoever packs or loads the containerUnder 176.27(c), a signed certificate goes to the vessel operator stating the container is serviceable, holds no incompatible goods, and the packages were inspected, undamaged, properly marked and secured.
Emergency response telephone numberThe shipperUnder 172.604, a number monitored at all times while the material is in transportation, answered by someone knowledgeable about the material. Numbers that require a call back do not meet the rule.
Sources: 49 CFR 172.204, 172.604 and 176.27 (eCFR, current as of October 2026).

For imports, 171.22(f) adds that the shipper, directly or through the forwarding agent at the place of entry, must provide the initial U.S. carrier with the shipper's certification, and a carrier may not accept the hazardous material without it.

The dangerous cargo manifest (DCM)

Under 49 CFR 176.30, the carrier, its agents or a person they designate must prepare a dangerous cargo manifest, list or stowage plan. It may only list materials regulated by the Hazardous Materials Regulations or the IMDG Code, and must include:

  • Vessel name and official number (or radio call sign), and nationality.
  • Shipping name and identification number of each hazardous material, plus an emergency response telephone number.
  • Number and description of packages and the gross weight for each type of package.
  • Classification under the 49 CFR table or the IMDG Code, and any additional description required by 172.203.
  • Stowage location on board.

The information must match what the shipper provided on the shipping paper. The person supervising preparation signs and dates it, and the master or a designated licensed deck officer acknowledges it by signature. The carrier must keep a copy for at least one year. The document is kept on or near the bridge, or, when docked in a U.S. port, at a location the master designates with a sign at the bridge pointing to it.

Manifest data and record retention

Dangerous goods also show up in Customs filings. For U.S. imports, 19 CFR 4.7a lists the internationally recognized hazardous material code among the data elements the cargo declaration must state when such materials are shipped, so the hazmat data on the house bill feeds the ACE manifest as well. See what ACE AMS filing is for how that filing works.

Retention periods differ by document. Under 172.201(e), each person who provides a shipping paper keeps a copy, or an electronic image, accessible at its principal place of business for two years after the material is accepted by the initial carrier, or three years for hazardous waste. For vessel shipments, the date on the bill of lading may be used in place of the acceptance date. The carrier's DCM copy is kept for at least one year under 176.30(e).

Pre-sailing documentation checklist

  1. Shipping description complete: ID number, proper shipping name, class and subsidiary hazard, packing group, total quantity.
  2. Hazardous entries listed first, in contrasting color, or marked "X" in the HM column.
  3. Emergency response telephone number on the paper, monitored at all times, with the registrant or contract identified where required.
  4. Shipper's certification signed by a principal, officer, partner or employee of the shipper or its agent.
  5. Container packing certificate signed and delivered to the vessel operator.
  6. Booking, house bill and manifest show the same hazmat data as the shipping paper.
  7. Dangerous cargo manifest prepared, signed, acknowledged by the master and placed where the rule requires.
  8. Copies filed: shipping paper for two years (three for hazardous waste), DCM for at least one year.
Requirements change with each IMDG amendment and with PHMSA rulemakings. Check the current text and confirm specific cases with your dangerous goods adviser before relying on a template.

Building the DCM from the booking, not from scratch

The DCM is where retyping errors hurt most: the information must match the shipper's paperwork, and the master signs off on it. Building it from data already captured at booking keeps the two in agreement.

That is how GDZ-ISIS handles hazardous cargo: bookings can be entered for container, break bulk and hazardous cargo, and the dangerous cargo manifest is built from those entries. If your team still assembles the DCM by hand, schedule a demo to see the alternative.

Frequently asked questions

Can I ship hazmat from the U.S. under the IMDG Code instead of 49 CFR?

Yes, for shipments where all or part of the movement is by vessel, under 49 CFR 171.22 and 171.25. U.S. requirements for emergency response information, training, security, incident reporting and registration still apply, as applicable.

What must the hazmat shipping description include?

Under 49 CFR 172.202: the identification number, proper shipping name, hazard class or division (with subsidiary hazards where required), packing group, and the total quantity with its unit of measure.

Who prepares the dangerous cargo manifest?

The carrier, its agents or a person they designate, under 49 CFR 176.30. The person supervising it signs and dates it, the master or a designated licensed deck officer acknowledges it, and the carrier keeps a copy for at least one year.

How long must hazmat shipping papers be kept?

Two years after the material is accepted by the initial carrier, or three years for hazardous waste, under 49 CFR 172.201(e). For vessel shipments, the bill of lading date may be used in place of the acceptance date.

Is a container packing certificate required for ocean shipments?

Yes, for containers packed with hazardous materials for a manned vessel in ocean or coastwise service. Under 49 CFR 176.27(c), the person who packs or loads the container gives the vessel operator a signed certificate when the shipment is offered.

Sources

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