The shipping industry is raising alarms about a regulatory loophole that permits thousands of lithium-ion batteries to be shipped in a single container without being declared to the carrier. This exemption, known as Special Provision 188 (SP188) under the International Maritime Dangerous Goods Code, was initially designed in the 1990s for small battery shipments. However, with global lithium-ion battery deployment projected to double again by 2030 after a six-fold increase between 2020 and 2025, containers now routinely carry hundreds or thousands of these batteries, often equivalent in capacity to multiple electric vehicles, unbeknownst to vessel crews. This lack of visibility prevents proper risk assessment, stowage, and emergency response planning, making these shipments a significant safety hazard for people, ports, ships, and the marine environment.
Several governments and major shipping organizations, including Germany, Singapore, the World Shipping Council, BIMCO, and the International Chamber of Shipping, have jointly proposed to the International Maritime Organization (IMO) that this loophole be addressed. They suggest adapting a similar regulation, SP936, which imposes weight limits on other battery types, to introduce a threshold for lithium-ion batteries. This would require shipments exceeding a certain weight to be declared as dangerous goods, even if individual batteries fall under the SP188 exemption. Joe Kramek, president and chief executive of the World Shipping Council, emphasized that the current rules are not functioning as intended, highlighting that undeclared battery shipments have already caused serious container fires.
The danger is not merely theoretical, as evidenced by past incidents. For instance, the Malta-flagged X-Press Godavari suffered a container fire in 2020, which was later discovered to contain over seven tonnes of undeclared lithium-ion batteries. The crew was unaware of the cargo's nature for about 90 minutes, complicating firefighting efforts. Recent fatalities on vessels like Wan Hai 503 and Maersk Frankfurt underscore the severe consequences of such fires, which can escalate rapidly due to thermal runaway, releasing toxic gases and making intervention extremely difficult. The proposal aims to initiate a formal discussion at the IMO's Sub-Committee on Carriage of Cargoes and Containers (CCC 12) in September 2026 to find a practical and proportionate solution to this growing safety gap.
