The World Shipping Council asked governments on 10–11 September 2026 to close a gap in the International Maritime Dangerous Goods Code that can let a container packed with thousands of lithium batteries move without the carrier being told the hazard is on board. The exemption is Special Provision 188. SP188 was written to simplify the carriage of individual devices with small batteries that meet testing, packaging and capacity limits. It does not set a cap on how many of those qualifying batteries may be stuffed into one cargo transport unit. WSC says a container of about 4,200 laptops can hold roughly 416 kWh of stored energy — comparable to three or four electric vehicles — without dangerous-goods documentation or placarding.
Joe Kramek, WSC president and chief executive, put the problem in operator language: the exemption was meant for small devices, “not to make entire container loads invisible.” Batteries move safely every day when they are declared and the risk is understood. The failure mode is invisibility. Without a declaration, the carrier cannot make an informed stowage or segregation decision, the crew cannot plan a fire party for a battery cargo they do not know is there, and port and shore responders meet a box that looks like general cargo. WSC says batteries shipped under the exemption have already been involved in serious container fires.
The volume argument is no longer theoretical. The International Energy Agency says global lithium-ion battery deployment in 2025 was six times the 2020 figure, and demand is expected to double by 2030. Allianz statistics cited by WSC put a container-ship fire at about one every 17 days. Allianz’s Safety and Shipping Review 2026 still lists mis-declared cargo — batteries and chemicals among it — as a major contributor to container-ship fires, about a quarter of cargo-related incidents. The International Safe Containerised Cargo Organisation has already issued guidance on lithium-ion cells in containers. Guidance does not substitute for a Code line that tells the master what is in the box.
WSC, backed by five governments and a wider industry group, has submitted a paper that borrows an existing IMDG model. Special Provision 963, which applies to UN 3496, already uses a cargo-transport-unit threshold above which hazard communication is triggered. The proposal would give SP188 a similar container-level threshold, expressed in watt-hours or gross mass. Once the threshold is exceeded, IMDG sections 5.4.1 and 5.4.3 on dangerous-goods documentation and information would apply, and placarding under section 5.3 could be triggered. A gross-mass threshold would be easier to measure on the terminal; a watt-hour threshold would be more precise. The package-level 30 kg gross-mass limit already in SP188 would stay. A possible pathway was tabled at the UN Sub-Committee of Experts on the Transport of Dangerous Goods at its 68th session, 30 June to 8 July 2026. Governments will take the maritime piece at the IMO Sub-Committee on Carriage of Cargoes and Containers, CCC 12, in London from 14 to 18 September 2026.
Operational implications sit with booking offices and cargo planners this week, not only with whoever attends CCC 12. A box that is legal under SP188 today can still be a fire the crew cannot identify. Carriers that have already tightened lithium-battery acceptance will stay under commercial pressure to take undeclared or loosely described “electronics” cargo while the Code still permits a full container to move as if it were general cargo. Shippers who consolidate thousands of small cells into one cargo transport unit are using the letter of SP188. Masters and designated persons who treat that letter as a safety case are the ones who will fight the fire. Until a threshold is in the Code, the safety management system has to impose one.
Port State Control will not wait for a later IMDG amendment to ask why a burned bay had no dangerous-goods list. Insurers will ask whether the carrier’s acceptance policy, the verified gross mass file and the stowage plan treated a high-count battery consolidation as general cargo because SP188 allowed it. Charterers of container ships, and operators of feeder and con-ro tonnage that lift the same boxes, need a written rule for when a booking that cites SP188 is refused, held for declaration, or accepted only with a location, segregation and fire-plan note. CCC 12 is 14–18 September. A paper can fail, be deferred, or come out as a draft that does not enter into force for years. The fire risk does not follow the amendment calendar.
What Operators Should Note
- Treat SP188 as a small-device exemption, not as permission for an undeclared battery container. WSC’s worked example is about 4,200 laptops and 416 kWh in one box with no dangerous-goods documents and no placard. If the booking description is “electronics,” “parts” or “SP188 batteries” at container scale, ask for a count, a watt-hour or gross-mass total, and a declaration before the box is planned.
- Put a company cargo-transport-unit threshold in the safety management system before CCC 12, not after it. Mirror the SP963 idea: above a watt-hour or gross-mass limit, require IMDG 5.4 documentation and consider 5.3 placarding even if the Code does not yet compel it. Do not wait for a mandatory amendment that may be years away.
- Give cargo planners a stowage rule they can apply at 0200. Known or suspected high-count battery boxes should not sit against accommodation, over other dangerous goods, or in a position the crew cannot reach with the fire party. If the contents are unknown, treat the box as a battery risk until the shipper proves otherwise.
- Brief the master and the fire party on invisibility, not only on thermal runaway. The Allianz problem is mis-declaration. The crew may not know what is burning, where the batteries are, or how many boxes are involved. The drill should include “undeclared battery cargo in a general-cargo bay,” not only a labelled Class 9 container.
- Keep the booking office and the designated person ashore on the same rejection list. A commercial hold on SP188 consolidations is a safety control. Record refusals, queries and late declarations. That file is what P&I and the hull underwriter will ask for after the next container fire.
- Watch CCC 12 (14–18 September, London) for a threshold, not for a finished Code change. Five governments are already behind the paper. A UN Model Regulations path was shown at the 68th session of the Sub-Committee of Experts in June–July. Whatever CCC does this week, IMDG amendment timing will lag the cargo. Do not write the voyage memo as if the loophole closes on 18 September.
- Align feeder, con-ro and terminal partners to the same threshold. The box does not become visible because it crossed a berth. If the deep-sea line requires a declaration above a container-level limit, the feeder and the container yard have to apply the same question or the hazard re-enters the stow as general cargo.
Regulas Shipping will keep lining the WSC SP188 paper, CCC 12 discussions and container-fire statistics against booking and stowage practice so operators can treat a high-count battery box as a declared hazard, not as invisible general cargo.
