The Cargo Incident Notification System (CINS) has published a new recommendation paper examining the growing challenges associated with lithium-ion batteries shipped under Special Provision 188 (SP188) of the IMDG Code. The paper highlights how the significant increase in lithium-ion battery production, use and shipment volumes has changed the risk landscape since SP188 was first introduced.
SP188 was originally introduced to facilitate the transport of smaller lithium cells and batteries that present a lower level of risk when certain conditions are met. For lithium-ion batteries, the exemption generally applies to cells not exceeding 20Wh and batteries not exceeding 100Wh, provided they comply with requirements relating to testing, packaging, marking and protection against short circuits.
Where these conditions are satisfied, qualifying shipments are exempt from many of the IMDG Code requirements that would otherwise apply to fully regulated Class 9 dangerous goods. However, as CINS observed, this exemption does not remove the inherent hazards associated with lithium-ion batteries.
A central theme of the paper is the issue of visibility. As SP188 shipments are generally not accompanied by a dangerous goods declaration or cargo transport unit (CTU) placarding, carriers may have limited awareness of the presence and quantity of lithium-ion batteries loaded within a container. This may create challenges for cargo acceptance, stowage planning, emergency preparedness and incident response.
The concerns raised by CINS also mirror those highlighted in a recent submission to the IMO’s 12th Session of the Sub-Committee on Carriage of Cargoes and Containers (CCC-12), co-sponsored by several Member States and industry organisations, including the International Group of P&I Clubs. The submission notes that, whilst SP188 contains package-level limits and safeguards, there is currently no equivalent limit on the total quantity of batteries that may be loaded within a single freight container.
As a result, a container may be packed with large quantities of batteries that individually qualify for SP188 relief, yet remain effectively invisible to carriers from a dangerous goods declaration perspective. The submission describes this as a significant safety gap with implications for risk assessment, stowage planning, emergency response and shore-side support during incidents.
Drawing on industry incident data and experience, the CINS paper identifies recurring concerns including misdeclaration, packaging deficiencies, battery quality issues and the accumulation of large quantities of batteries within a single container. It also advocates greater transparency and traceability throughout the transport chain.
These concerns echo themes discussed in the Club’s previous article, Tackling the Evolving Challenge of Cargo Fires at Sea, which highlighted the increasing risks associated with lithium-ion batteries and the importance of accurate cargo information to support effective risk assessment and fire prevention measures.
Whilst the CINS paper does not alter existing regulatory requirements, it provides a useful snapshot of current industry thinking and the direction of ongoing regulatory discussions. For Members involved in the carriage of containerised cargo, the message is clear: accurate cargo information and visibility of cargo hazards remain fundamental components of maritime safety.
