Ports plays a central role in Sea Transport of Dangerous Goods in Kenya. The Port of Mombasa is not only the country’s principal seaport but also an important gateway for cargo moving to and from neighbouring landlocked countries such as Uganda, Rwanda, South Sudan and parts of the Democratic Republic of Congo. Among the millions of tonnes of cargo handled through maritime supply chains are chemicals, fuels, aerosols, batteries, paints, pesticides and many other products that can be classified as dangerous goods. When these products are transported by sea, ordinary cargo procedures are not sufficient. Dangerous goods must be classified, packaged, marked, labelled, documented, packed into cargo transport units and handled according to specific safety requirements. The principal international standard governing these activities is the International Maritime Dangerous Goods Code, better known as the IMDG Code.
For Kenyan manufacturers, freight forwarders, exporters, importers, logistics companies and port operators, understanding the IMDG Code is particularly important because Kenya’s Merchant Shipping Act expressly connects the national regulation of dangerous goods carried by ship with the IMDG Code.
Sea Transport of Dangerous Goods in Kenya
The International Maritime Organization developed the IMDG Code to provide a consistent international system for transporting dangerous goods in packaged form by sea. It forms part of the international maritime safety system established under the SOLAS Convention and contains detailed requirements covering classification, packaging, marking, labelling, documentation, container packing, segregation, stowage and emergency response.
Kenya has incorporated this international approach into its own merchant shipping framework. Section 297 of the Kenyan Merchant Shipping Act provides for regulations defining dangerous goods in accordance with the Safety Convention and specifically states that those regulations are to incorporate the International Maritime Dangerous Goods Code of the International Maritime Organization by reference. The legislation also provides for requirements relating to packing, stowage, quantities, the places aboard a ship where dangerous goods may be carried, marking of packages and containers and inspection.
This makes the IMDG Code considerably more than a voluntary international guideline for Kenyan maritime operations. Businesses involved in dangerous goods shipments through Kenya need to understand both the international Code and the applicable Kenyan maritime requirements.
The Kenya Maritime Authority (KMA) is the national maritime regulator responsible for regulating, coordinating and overseeing maritime affairs in Kenya. Kenya’s modern merchant shipping framework is centred around the Merchant Shipping Act and associated regulations, with KMA responsible for a wide range of maritime safety and regulatory functions.
Which IMDG Code applies in Kenya?
The IMDG Code is normally amended every two years. This is important because classification rules, special provisions, packaging requirements and entries in the Dangerous Goods List can change between editions.
As of 2026, the applicable edition is the IMDG Code 2024 Edition incorporating Amendment 42-24. Amendment 42-24 became mandatory internationally on 1 January 2026. The International Maritime Organization confirms that the revised Code applies to ships carrying dangerous goods in packaged form and that the previous 2022 edition has been superseded.
The next edition, Amendment 43-26, has already been published by the IMO in September 2026. The normal IMDG amendment cycle provides for a transition period before a new amendment becomes the sole applicable version. Companies operating in Kenya should therefore maintain procedures for monitoring IMDG amendments rather than assuming that a training course, dangerous goods database or shipping procedure remains current indefinitely.
This is especially relevant for companies involved in lithium batteries, sodium-ion batteries, chemicals and new technologies, because these areas regularly generate amendments to dangerous goods transport requirements.
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Classification comes before shipment
Every compliant dangerous goods shipment begins with classification. Before a product can be offered for maritime transport, the shipper needs to determine whether it meets the criteria for one or more dangerous goods classes.
The IMDG Code recognises nine principal classes, including explosives, gases, flammable liquids, flammable solids, oxidising substances and organic peroxides, toxic and infectious substances, radioactive materials, corrosive substances and miscellaneous dangerous substances and articles.
Once classified, the product is generally assigned an appropriate UN number, Proper Shipping Name, class and, where applicable, packing group and subsidiary hazard. It may also be classified as a marine pollutant.
These details determine many of the requirements that follow.
For example, UN 1263 PAINT may be subject to Class 3 requirements, while certain lithium-ion batteries are transported under UN 3480 or UN 3481 depending on the circumstances. Corrosive chemicals can fall within Class 8, while aerosols generally fall within Class 2.
Incorrect classification at the beginning of the process can consequently lead to incorrect packaging, labels, documentation and stowage decisions later in the supply chain.
This is why companies should not rely solely on a commercial product description. A Safety Data Sheet can provide important information, particularly Section 14, but the shipper remains responsible for ensuring that the transport classification is correct.
Packaging, marking and labelling
Dangerous goods shipped from or through Kenya must be prepared in packaging permitted by the applicable IMDG provisions. Depending on the substance and quantity, this may involve drums, boxes, jerricans, intermediate bulk containers or other approved forms of containment.
UN specification packaging is required for many dangerous goods. Such packaging has undergone prescribed testing and carries markings that identify the type and performance level of the packaging.
The outer package must normally show the UN number and Proper Shipping Name where required, together with the applicable hazard labels. Additional markings may be necessary for environmentally hazardous substances, lithium batteries, limited quantities, elevated-temperature substances or other specific cargoes.
These requirements are not merely administrative. Packages can spend weeks moving through terminals, container yards, vessels and inland logistics networks. Clear markings and labels allow stevedores, vessel operators, emergency responders and other employees to recognise the hazards involved.
Kenyan law reinforces the importance of this information. Section 298 of the Merchant Shipping Act prohibits the carriage of dangerous goods on a Kenyan ship unless the applicable requirements are met. It also requires the nature of dangerous goods to be distinctly marked on the outside of the outermost package and written notice to be provided to the master or owner of the ship.
Dangerous Goods Declaration and container packing
Documentation is another critical part of IMDG compliance.
The shipper must provide dangerous goods information containing the prescribed transport description. Typically, this begins with the UN number followed by the Proper Shipping Name, hazard class and packing group where applicable. Other information may need to be added depending on the shipment.
In containerised transport, the Container/Vehicle Packing Certificate is also important. The person responsible for packing the cargo transport unit certifies that the container has been properly packed, that packages have been inspected, incompatible goods have been segregated where necessary and the cargo has been properly secured.
In practice, the Dangerous Goods Declaration and Container Packing Certificate are often combined into a multimodal dangerous goods form.
For exports through Mombasa, mistakes at this stage can lead to rejected containers, delays, additional costs or refusal by a shipping line. A technically correct product can still become a non-compliant shipment if its documentation is incomplete or inconsistent with package labels and container placards.
Container placarding, segregation and stowage
Dangerous goods inside a freight container must be communicated externally as well. Cargo transport units carrying dangerous goods generally require placards corresponding to the hazards of the substances inside. Additional marks, including the marine pollutant mark, may also be required.
Segregation is particularly important at sea because incompatible dangerous goods can create severe consequences if they interact during a fire, leakage or container failure.
The IMDG Dangerous Goods List provides segregation information, while the Code contains general and specific segregation provisions. Some substances must be separated from acids, alkalis, explosives or other classes. Correct segregation has to be considered not only aboard the vessel but also when different dangerous goods are packed into the same cargo transport unit.
Stowage requirements determine where cargo can be placed aboard a vessel. Certain dangerous goods may be permitted below deck, while others require specific positions or restrictions.
These decisions are ultimately part of the ship’s cargo planning process, but the quality of the information provided by the shipper is essential. A shipping line cannot make correct stowage and segregation decisions when a dangerous cargo has been incorrectly declared.
Dangerous goods at the Port of Mombasa
Mombasa is a major international container port and an important gateway for East African dangerous goods traffic. Dangerous cargo arriving in Kenya may be destined for the domestic market or continue inland as transit cargo.
Dangerous goods are treated differently from ordinary containerised cargo at ports because prolonged storage increases operational risks. Kenya Ports Authority’s tariff structure reflects this distinction. Its published tariff provides specific storage charges for dangerous cargo beginning from the second day after landing, illustrating the operational importance of moving dangerous goods efficiently through the port environment.
Companies importing dangerous goods should therefore coordinate maritime and inland transport arrangements in advance. It is poor practice to allow a dangerous goods container to arrive while permits, customs formalities, storage arrangements or onward transport are still unresolved.
The maritime leg and the road leg should be considered as one continuous logistics process.
A shipment arriving correctly under the IMDG Code does not automatically mean that it is ready for unrestricted transport by road in Kenya. Separate Kenyan requirements relating to hazardous chemicals, road transport, petroleum products or other regulated commodities may apply once the container leaves the port.
IMDG training for employees in Kenya
One of the most important and sometimes underestimated IMDG requirements concerns personnel training.
The Code requires shore-based personnel whose duties concern the transport of dangerous goods by sea to receive training appropriate to their responsibilities. This can include employees who classify dangerous goods, pack packages, mark or label cargo, load or unload cargo transport units, prepare transport documents, offer dangerous goods for transport or otherwise perform regulated dangerous goods functions.
Training should be function-specific. An employee preparing an IMDG Dangerous Goods Declaration needs different detailed knowledge from an employee packing cartons into a freight container, although both require general dangerous goods awareness.
Security awareness is also part of the training framework, and employees dealing with high-consequence dangerous goods may require more detailed security-related instruction.
Companies operating in Kenya should therefore avoid viewing IMDG training solely as something required for ship crews. A considerable proportion of IMDG compliance takes place ashore, before the container ever reaches the vessel.
Responsibilities of Kenyan shippers and logistics companies
A reliable IMDG compliance system should clearly allocate responsibilities throughout the organisation.
The shipper needs to ensure that dangerous goods are correctly identified and classified. Packaging needs to be suitable and compliant. Employees must apply the correct markings and hazard labels. Container packers must ensure that cargo is properly secured and that incompatible substances are not packed together. Documentation needs to match the physical consignment, and logistics personnel need to ensure that shipping lines receive dangerous goods information in time.
Freight forwarders should also recognise that acting as an intermediary does not make dangerous goods risks disappear. If information is transferred incorrectly between the manufacturer, exporter, forwarder, container packer, port and shipping line, the consequences can affect the entire transport chain.
Kenya’s Merchant Shipping Act provides enforcement powers in relation to dangerous goods. Contraventions can constitute an offence, and improperly marked, packed, stowed or quantified dangerous goods can result in a ship being considered unsafe because of improper loading. The Act also gives a ship’s master or owner powers to refuse suspicious packages and to take action when dangerous goods have been loaded without the required declaration or marking.
Safe maritime dangerous goods transport starts before the port
The most important lesson for dangerous goods transport in Kenya is that IMDG compliance begins long before a container reaches Mombasa.
A compliant shipment is built step by step: correct classification, suitable packaging, accurate markings and labels, competent employees, correct container packing, cargo securing, segregation, placarding and complete documentation.
Once these elements are properly managed, the shipping line and terminal can use that information to safely accept, handle, stow and transport the cargo.
For Kenyan businesses involved in international trade, the IMDG Code should therefore be seen as an operational standard rather than simply a shipping document requirement. The country’s Merchant Shipping Act makes the connection between Kenyan maritime law and the international dangerous goods framework clear, while the role of Mombasa as a gateway for East Africa makes competent dangerous goods management increasingly important.
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Companies exporting or importing chemicals, batteries, aerosols, fuels and other hazardous products should ensure that the people involved in those shipments understand not only what the IMDG Code requires, but also how those requirements apply to their own job functions. That combination of regulatory knowledge and practical competence is what ultimately prevents rejected shipments, cargo incidents, environmental damage and unnecessary risk at sea.
