The bulk shipper's declaration: a short form, a detailed process
A bulk shipper's declaration can be signed in under a minute. Establishing what goes on it can take a laboratory, a battery of tests, and judgement across multiple separate regulatory codes. The declaration (in Australia, AMSA form 268) sits under the SOLAS Convention, and on a single page it draws together the International Maritime Solid Bulk Cargoes (IMSBC) Code classification, the chemical hazard from the International Maritime Dangerous Goods (IMDG) Code, and the classification relating to International Convention for the Prevention of Pollution from Ships (MARPOL Annex V ). Underpinning these regulations is the United Nations Globally Harmonized System of Classification and Labelling of Chemicals (GHS). The form is simple; the classification behind it is often not. Some cargoes are straightforward; others require an extensive testing and assessment process.
It starts with the schedule, and the schedule starts with testing
The first thing the cargo needs is its Bulk Cargo Shipping Name (BCSN). This points to the cargo's individual schedule in the IMSBC Code, which defines the group, physical characteristics, hazards, and carriage requirements. Get the schedule right, and the form has a foundation. Get it wrong, or apply an approximate match, and every entry that follows may be compromised.
The schedule itself is a conclusion, not a given. What determines the correct schedule is the characterisation of the material: its chemistry, mineralogy, physical properties, and chemical hazards. Characterisation comes first; the schedule follows from what the evidence establishes. Depending on the cargo, that characterisation may require chemical and mineralogical analysis, physical testing and specific hazard tests.
Sometimes the classification finds that no existing schedule is appropriate for the material, e.g. a novel material or a new processing stream. Where no schedule fits, the material must be characterised, provisionally classified, and a new schedule submitted to the IMO for inclusion in the Code (a process we'll cover in a future article).
The group follows from the schedule
The group classification (Group A, B or C) is stated in the cargo's schedule, and it determines which carriage requirements apply:
Group A cargoes present a hazard due to moisture that may result in liquefaction or dynamic separation if shipped above their Transportable Moisture Limit (TML).
Group B cargoes possess a chemical hazard.
Group C cargoes are neither Group A nor Group B.
Cargoes can also sit in both Group A and B simultaneously when they present dual hazards.
The hierarchy runs characterisation (including testing where required) → schedule → group.
Apply an approximate schedule without the characterisation to support it, and you inherit its group, its hazards and its carriage requirements, all potentially wrong. The group is only as reliable as the characterisation that determined the schedule, and because everything else on the form is shaped by the group, an error there carries through the entire declaration.
The physical characterisation and moisture control
Much of the work behind the form is physical characterisation: stowage factor, bulk density and angle of repose, which inform how the cargo stows, how it must be trimmed, and how it behaves for stability in the hold.
Moisture control is a critical subset of the testing that applies once a cargo is identified as Group A. The IMSBC Code requires that a Transportable Moisture Limit (TML) value for Group A materials be established using prescribed test methods.
For each shipment, the Moisture Content(MC) must be determined through representative sampling and testing and be demonstrated to be below the TML before loading. This control chain is documented in three steps:
Certificate of TML
Certificate of Moisture Content
The Competent Authority Approval for the sampling, testing, and moisture control procedures (under IMSBC Code Section 4.3.3)
The TML requirement is driven by the Group A classification, which is a consequence of the characterisation and the schedule.
The chemical hazard
Where a cargo carries a chemical hazard, the form asks for its class, UN number or MHB designation, and that single field draws on more than one regulation. Where the cargo is a dangerous good, its class and UN number are determined by the IMDG Code. Examples of cargo classifications include Class 4.2, UN 3190 for self-heating metal sulphide concentrates and Class 8, UN 1759 for corrosive metal sulphide concentrates. Other chemical hazards encountered include Class 9, UN 3077 for environmentally hazardous solids and Class 7, UN 2912 for certain low-specific-activity radioactive materials1.
An MHB (Materials Hazardous only in Bulk) hazard is the IMSBC Code's own category for materials that possess chemical hazards when transported in bulk. How a cargo becomes MHB carries a subtlety. It isn't only about bulk behaviour, for example, self-heating, or evolving flammable or toxic gas when wet, but also includes additional human health hazards not captured under the IMDG Code.
Marine Pollution: MARPOL Annex V
Whether the cargo is classified as harmful to the marine environment (HME) governs whether residues and hold washings from that cargo may be discharged at sea or must be retained on board for discharge to port reception facilities. Behind it are specific criteria, set out in MARPOL Annex V, again drawn from the GHS: a cargo is HME if it meets GHS Acute Aquatic Toxicity Category 1, or Chronic Aquatic Toxicity Category 1 or 2, or certain GHS human health hazards combined with persistence and bioaccumulation.
For many concentrates, the aquatic toxicity endpoints drive the HME classification, which strictly prohibits the overboard discharge of cargo residues2.
And then it all has to align on the declaration
The cargo identity and BCSN should be consistent across the documentary chain, including the shipper's declaration, approved moisture-control documentation, TML and moisture certificates, and relevant shipping documentation.
A discrepancy in the cargo name between the shipper’s declaration and a certificate can raise a query at the port. These discrepancies could surface at the worst possible moment, with the vessel alongside; a five-minute inconsistency at the desk becomes an expensive delay at the berth. The declaration doesn't just record the classification; it has to hold the whole documentary chain together.
The form is short, the stakes are high
The shipper's declaration is not a box-ticking exercise. It's the point where testing and classification across multiple regimes, all resting on the correct IMSBC schedule, converge into a single signed statement. Everything upstream exists so that the few entries on this page are right. Even the group, the entry that drives the carriage requirements, is a derived conclusion, only ever as sound as the characterisation beneath it. When the entries are correct, the cargo ships safely and in compliance.
That accuracy is exactly what the industry is asking for. INTERCARGO's Bulk Carrier Casualty Report 2026 identifies cargo liquefaction as the leading cause of loss of life in dry bulk shipping, and reinforces the need for robust cargo testing, declaration procedures and accurate shipper declarations of cargo properties.
An accurate declaration rests on sound classification, and when the classification is wrong, the consequences run from delayed cargo at best to the loss of life at worst.
1 UN3077 and UN2912 are examples of classifications for which special BCSN provisions apply under section 4.1.1.3 of the IMSBC Code also.
2 GHS Annex 10 Transformation/Dissolution (T/D) testing allows for a more refined hazard assessment by measuring the actual rate and extent of ion release from sparingly soluble substances in water. This data prevents conservative default classifications by determining if dissolved metal concentrations remain below aquatic Ecotoxicity Reference Values (ERVs).