What does it take to introduce a new cargo schedule into the IMSBC Code? Drawing on our experience with three cargo schedule applications, we outline the formal process and share practical insights into the technical and regulatory challenges involved.
The International Maritime Solid Bulk Cargoes (IMSBC) Code establishes internationally recognised requirements for the safe carriage of solid bulk cargoes by sea. But what happens when a proposed cargo is not listed in this Code?
The Code provides a pathway for developing new individual cargo schedules, from determining the material's characteristics and hazards through to consideration and adoption by the International Maritime Organization (IMO).
While the process is well defined, successfully navigating it requires careful planning, thorough preparation, and rigorous testing.
At Davoren Environmental, we've contributed to the development of three new IMSBC cargo schedules:
PHOSPHATE ROCK FINES (uncalcined) — Group A
IRON ORE BRIQUETTES — Group C
DIRECT SHIPPING ORE SPODUMENE — proposed Group C schedule
The first two were adopted under IMSBC Amendment 08-25 and will become mandatory on 1 January 2027. More recently, the IMO's Sub-Committee on Carriage of Cargoes and Containers (CCC 12) agreed in principle to a new individual schedule for Direct Shipping Ore Spodumene and referred it to the Editorial and Technical Group (E&T 45) for consideration and potential incorporation into draft amendment 09-27 to the IMSBC Code.
In Australia, the Australian Maritime Safety Authority (AMSA) is the relevant competent authority. We have worked with shippers to develop the technical evidence and proposed schedules for consideration through the IMO process.
Drawing on these projects, we outline the key steps for developing a new cargo schedule and some practical lessons learned along the way.
Step 1. Test and characterise the cargo to determine whether a new schedule is required
IMSBC references: Sections 1.2.1 and 4; Sections 7–9 as applicable.
The starting point is to establish the cargo's physical and chemical characteristics and identify its potential hazards during maritime transport.
This involves reviewing available information and undertaking appropriate representative sampling and testing, which may include particle size distribution, moisture-related behaviour, chemical hazards and other relevant properties.
The findings are assessed against the existing individual cargo schedules in Appendix 1 to determine whether an established Bulk Cargo Shipping Name (BCSN) exists and whether the schedule appropriately covers the material.
Where no existing schedule applies, the material is considered an unlisted cargo under Section 1.3. Importantly, an unlisted cargo can still be assessed as Group A, B, C or as a combined A and B.
An existing IMSBC schedule classified uncalcined phosphate rock as Group C, indicating no Group A or B hazards. However, comprehensive testing demonstrated that this schedule was unsuitable for PHOSPHATE ROCK FINES (uncalcined).
Laboratory analysis identified a fine-grained material (D50 of 0.30–0.35 mm) with a measurable Transportable Moisture Limit (TML), establishing the need to address potential liquefaction hazards. Consequently, a new Group A schedule was developed to provide appropriate requirements for safe carriage.
Step 2. Compile the technical evidence and establish the proposed hazard classification
IMSBC references: Sections 1.7 and 4; Sections 7–9 as applicable. IMO guidance: MSC.1/Circ.1453/Rev.2.
Once the need for a new schedule is established, the technical evidence must be sufficient to substantiate the cargo's properties, potential hazards and appropriate conditions of carriage.
The IMO guidelines address the supporting information expected, including composition, production processes, physical characteristics, variability, representative sampling and relevant test results.
The objective is to establish a technically defensible Group A, B, C or combined A and B classification, together with sufficient evidence to justify the proposed carriage requirements.
Importantly, the testing and supporting data need to be representative of the cargo as it will be shipped, including relevant variations in its properties.
For IRON ORE BRIQUETTES, the primary technical challenge was demonstrating that a coarse, free-draining cargo (10–40 mm), for which standard TML testing was not applicable, would not degrade into a material susceptible to liquefaction during transport. To address this evidence gap, the testing program incorporated ISO 3271 tumbler and abrasion indices to assess the briquettes' resistance to physical degradation and the generation of fines.
PRACTICAL TAKEAWAYAnticipate material behaviour and test the limits. Standard liquefaction testing may not be applicable to coarse, free-draining materials such as iron ore briquettes. Where degradation could generate finer particles, supplementary physical testing, such as tumbler and abrasion indices, can provide important evidence of material stability during handling and transport.
Step 3. Engage with the competent authority and establish the regulatory pathway
IMSBC references: Sections 1.3.1–1.3.2.
Where a cargo is not listed in Appendix 1, the shipper must provide the competent authority with information on its characteristics and properties to establish the appropriate regulatory pathway.
Early engagement helps clarify the requirements for developing a new individual cargo schedule, identify any gaps in the technical evidence and prepare for submission to the IMO.
The Code also provides for provisional carriage of unlisted cargoes, subject to competent-authority assessment and certification of suitable carriage conditions. This temporary mechanism enables shipment before an internationally recognised schedule is adopted.
The provisional carriage arrangements are distinct from the development of a new schedule.
Step 4. Develop the proposed individual cargo schedule and supporting submission
IMSBC reference: Section 1.3.3. IMO guidance: MSC.1/Circ.1453/Rev.2.
The proposed schedule must follow the prescribed IMSBC format, including the tentative BCSN, cargo description, characteristics, hazards and requirements for loading, carriage and discharge.
The accompanying submission must provide sufficient technical evidence to support the proposed classification and conditions of carriage, in accordance with the IMO guidance.
The competent authority is responsible for putting forward the formal proposal to the IMO. Developing a robust application requires collaboration among the cargo producer, technical specialists, and the competent authority to ensure the proposed schedule is supported by representative testing, sound hazard assessment, and clearly justified carriage provisions.
The challenge is not simply completing the required format. The supporting evidence must be sufficiently robust to withstand international technical scrutiny.
Early engagement with competent authorities (CAs) is essential for developing technically defensible schedule proposals. Because CAs understand the rigorous evaluation applied at the IMO level, early feedback helps identify critical technical gaps. Ultimately, this collaboration ensures that testing and subsequent hazard justifications are robust enough to withstand international scrutiny long before formal submission.
Step 5. Submit the proposal to IMO and navigate CCC and E&T review
IMSBC reference: Section 1.3.2. Supporting process: IMO Sub-Committee on Carriage of Cargoes and Containers (CCC) and Editorial and Technical (E&T) Group.
Under Section 1.3.2, the competent authority at the port of loading is required to submit an application to IMO to incorporate an unlisted cargo into Appendix 1. The Code links this requirement to the provisional-carriage certificate, specifying submission within one year of its issuance.
The proposed schedule is then considered through CCC and the supporting E&T Group.
These reviews examine the technical basis for the proposed schedule, including the cargo's hazard classification, supporting evidence and proposed carriage requirements.
While some proposals progress relatively smoothly, others encounter technical questions, objections or requests for additional information that must be resolved before progressing.
Unresolved issues may result in further consideration at subsequent meetings, potentially delaying inclusion in the intended IMSBC amendment cycle.
This is where the quality of the original submission can become particularly important. Anticipating foreseeable technical questions, clearly substantiating the proposed classification and addressing potential concerns early can help minimise avoidable delays.
Applications can encounter delays during CCC or E&T consideration when supporting evidence is incomplete or hazard classifications lack sufficient justification.
Across our phosphate rock fines, iron ore briquettes and spodumene applications, robust testing and early engagement with competent authorities helped identify and address evidence gaps before committee consideration.
For iron ore briquettes, targeted physical degradation data helped strengthen the technical justification.
PRACTICAL ADVICE FOR SHIPPERS- Ensure hazard classifications are supported by representative testing.
- Engage the competent authority early to identify evidence gaps.
- Where appropriate, participate as a technical expert in the competent authority's CCC delegation.
Step 6. MSC adoption and entry into force
Reference: IMO Maritime Safety Committee (MSC) and SOLAS amendment procedures.
Following technical review and finalisation, proposed new cargo schedules are incorporated into draft amendments to the IMSBC Code for consideration and adoption by the Maritime Safety Committee.
Adopted amendments then follow the specified arrangements for voluntary application and mandatory entry into force.
Two schedules that Davoren Environmental contributed to, PHOSPHATE ROCK FINES (uncalcined) and IRON ORE BRIQUETTES, were adopted under amendment 08-25 in June 2025. The amendment may be applied voluntarily from 1 January 2026 and becomes mandatory on 1 January 2027.
More recently, the proposed DIRECT SHIPPING ORE SPODUMENE schedule secured agreement in principle at CCC 12 in September 2026 and was referred to E&T 45 for consideration within draft amendment 09-27, with adoption targeted for 2027.
These examples highlight both the milestones and the time required to progress new schedules through international regulatory processes.
For mineral producers and exporters, understanding the IMO amendment timetable matters when planning new products, export arrangements, and longer-term shipping requirements.
Getting the process right
While the IMSBC Code establishes the regulatory framework for introducing new cargo schedules, successfully navigating the process requires more than preparing the prescribed documentation.
Our experience across three different cargoes reinforces the importance of sound scientific characterisation, representative testing, constructive regulatory engagement and preparing technical evidence that can withstand international scrutiny.
The strongest applications anticipate and resolve potential technical concerns before they become reasons for delay.
For mineral producers and exporters, investing in the right technical preparation and regulatory engagement from the outset can help minimise avoidable delays and establish internationally recognised requirements for safe and reliable shipment.
Davoren Environmental provides specialist support for mineral cargo hazard classification, testing strategies, regulatory submissions and the development of new IMSBC cargo schedules.
Unsure which IMSBC schedule applies to your cargo?
Whether you're shipping a new mineral product or uncertain if an existing schedule is appropriate, Davoren Environmental can help assess your cargo's classification and identify the appropriate pathway for safe, compliant shipment.
Contact us to discuss your cargo.