Shipping Lines Urge IMO to Close Lithium Battery Declaration Loophole
Major container shipping lines are urging the International Maritime Organization to close a regulatory loophole under the International Maritime Dangerous Goods Code that exempts small lithium-ion batteries from mandatory cargo declarations, warning that invisible battery shipments escalate fire risks aboard vessels.
The joint regulatory push follows growing alarm across global supply chains. According to a submission backed by Germany, the Marshall Islands, the Netherlands, Singapore, Thailand, and the International Bureau of Containers, current rules under Special Provision 188 allow thousands of small batteries to enter maritime transit without carriers knowing they are on board. The World Shipping Council, BIMCO, the International Chamber of Shipping, the International Cargo Handling Coordination Association, the ITF, and various P&I clubs co-authored the proposal to the IMO Sub-Committee on Carriage of Cargoes and Containers.
The Regulatory Blindspot Driving Maritime Risk
Special Provision 188 was introduced in the 1990s to facilitate trade in small electronics while limiting transport risks. Battery demand has surged exponentially since then. The International Energy Agency estimated that global lithium-ion battery deployment in 2025 was six times higher than in 2020, with demand projected to double again by 2030.
Under the existing framework, batteries that fall below specified watt-hour thresholds and meet standard testing and packaging requirements bypass IMDG declaration requirements entirely. The submission highlights a hypothetical scenario involving a 40-foot container loaded with 4,200 laptops, each housing a 99 watt-hour battery. While every individual laptop qualifies for the SP188 exemption, the collective container carries battery capacity equivalent to three or four electric vehicles. Carriers receive no official manifest notification of this hidden energy load.
BIMCO regulatory manager Katerina Elikonida Maroudi stated that the lack of declaration leaves crews without the information needed to assess cumulative fire risk, choose appropriate stowage, or prepare an effective emergency response.
World Shipping Council president and chief executive Joe Kramek noted the hazards of invisible cargo. Batteries shipped under the exemption have caused serious container fires, putting people, ports, ships, and the marine environment at risk, according to Kramek. As battery shipments continue to grow, the industry requires a better solution that makes these cargoes visible and allows risks to be properly managed.
Historical Precedents and Real-World Casualties
The danger is not theoretical. In September 2020, the Malta-flagged X-Press Godavari experienced a container fire while anchored in the Bay of Bengal after spotting smoke from a deck container. The container continued burning for days after discharge. An investigation revealed it held 500 cartons containing more than seven tonnes of lithium-ion batteries shipped under the SP188 exemption. The crew remained unaware of the lithium-ion nature of the fire for approximately 90 minutes until charterers confirmed the contents by email.
Recent maritime casualties aboard the Wan Hai 503 and the Maersk Frankfurt, both resulting in fatalities, underscore the severe consequences of thermal runaway events. ICS senior marine adviser for cargo Lional Roy Sharon explained that lithium-ion battery fires escalate rapidly. By the time smoke becomes visible, thermal runaway is often already well advanced, leaving little opportunity for intervention.
Managing this regulatory and operational shift requires rigorous cargo oversight.
As the IMO weighs the joint submission, container lines face mounting pressure to bridge safety gaps before the next reporting cycle.