Why Undeclared Dangerous Goods Are Back in the Spotlight
Undeclared dangerous goods are once again in the spotlight. To that point, an article from IAM member Andreas Christ Spedition and Mobeltransport recently pointed out that they have seen two cases of a US fifty-thousand-dollar fine due to undeclared dangerous goods in a sea container. More specifically, the article states that the Hamburg Water Police have enforced these fines due to automobiles not being completely empty of gas. In our blast from September of 2023, we pointed out that SP961can or should only be used for cars on “empty” and run to a stall, and this is exactly the case in this recent update. We also tried to explain that this may not have been enforced in the past, but we were going to book any non-empty auto as hazardous.
Recent $50,000 Fines Highlight Stricter Enforcement of Fuel Tank Regulations
IAM’s May 7, 2026, article alludes to this: “In an update from IAM Trusted member Andreas Christ Spedition and Mobeltransport, the company was alerted by their port agents that authorities are strictly adhering to regulations that demand a fuel tank is completely empty of fuel. The rule, which has historically been overlooked, has been enforced by Hamburg Water Police who inspected a container and levied the US$50,000 fine due to undeclared dangerous goods in a sea container. The import container will only be released in Germany after payment has been made.”
The Growing Importance of Shipping Vehicles with Empty Fuel Tanks
Let’s face it, there is so much information coming at us day to day it’s hard to stay up on things. It’s difficult to discuss rules that are not old but also are being newly applied. (Marad circa 2019) We also mentioned that although an empty fuel tank would allow us to use the special exemption to ship, based on customer feedback and our own experiences, we were NOT going to advocate that any agency demands an empty and run to a stall gas level for several reasons:
- Cars sometimes need to be moved at the port, in warehouses, etc., so having zero mobility is not recommended.
- Mechanical condition is not something we are easily able to ascertain on POVs, and we have concerns about modern autos being run to a stall and what that may cause for fuel injectors or engines.
- The 14FAM, which is one of the overarching documents in government shipping, says a “quarter” tank is allowed, so any demands for “empty“ would contradict this.
- A very large international shipping client said that they have seen “bad behavior” when they did ask for autos run to a stall, specifically an auto being “dragged” into a can by the front axle, or a car’s underside being damaged due to a large forklift being used to lift the car up (both of which cause a lot of damage).
The article also points out that this was in Hamburg but expected to be enforced in Bremerhaven as well. The full notice is also linked above.
*Notes – Acronym use – POV = privately owned vehicle, ICE auto = internal combustion engine, EV shipping = electric vehicle, SP961 = Special provision 961 IMDG Code Special Provisions 961 & 962 Explained, 14 FAM – current version of the Foreign Affairs Manual
** There are differing rules one might see on roll-on – roll-off vessels or ships.
To learn more about shipping EVs and Hybrid vehicles, read our article, Shipping Electric Vehicles in Global Mobility: Risks, Legal Implications, and Lessons from the Felicity Ace Case – Arpin International Movers.
