WSC calls on governments to close battery cargo safety gap

The World Shipping Council (WSC) has called on governments to address a gap in international dangerous goods regulations that allows containers carrying thousands of lithium batteries to be transported without carriers being informed of the associated fire hazard.

The WSC issued the call on September 10, 2026, as the use and transport of batteries continues to expand while cargo fires remain a persistent safety risk for container shipping. According to the International Energy Agency (IEA), global lithium-ion battery deployment in 2025 was six times higher than in 2020, while battery demand is expected to double by 2030. Meanwhile, Allianz statistics indicate that a container ship fire occurs approximately every 17 days.

Lithium-ion batteries can undergo thermal runaway, a rapid self-heating reaction that can cause intense fires, explosions and the release of hazardous gases. Such fires can be difficult to extinguish and may reignite hours or even days later, while early detection and firefighting at sea can be particularly challenging.

Concerns over SP188 exemption

At the center of the WSC’s concerns is Special Provision 188 (SP188) of the International Maritime Dangerous Goods (IMDG) Code. The provision exempts certain smaller lithium batteries from some dangerous goods requirements when they meet specified testing, packaging and capacity criteria.

However, the WSC said the rules do not currently set a limit on the number of batteries qualifying for the exemption that can be consolidated into a single container.

As a result, a container carrying around 4,200 laptops could contain approximately 416 kWh of stored energy, equivalent to the energy contained in three or four electric vehicles, without requiring dangerous goods documentation or container placarding.

Right now, a container can be packed with thousands of lithium batteries and still travel without being declared as dangerous goods 

… said Joe Kramek, President and CEO of the WSC.

He argued that SP188 was intended to simplify the transport of individual devices containing small batteries, rather than allow entire container loads of batteries to be transported without their hazards being declared.

Lack of visibility creates safety risks

The WSC emphasized that batteries are transported safely every day when they are properly declared and their associated risks are appropriately managed.

The concern, it said, arises when carriers, crews, ports and emergency responders are unaware that significant quantities of battery-powered cargo are present.

Without information about the hazard, carriers may be unable to properly assess the risks associated with a container, select appropriate stowage arrangements or separate it from other cargo. The lack of information can also limit the ability of crews, ports and emergency responders to prepare an appropriate response if a fire occurs.

We know what can happen when hazards are invisible 

… Kramek said, adding that batteries transported under the exemption have been involved in serious container fires, creating risks for people, ships, ports and the marine environment.

Why are batteries an issue?

Undeclared lithium batteries pose a particular risk because carriers and crews may be unaware that a container contains hazardous cargo, potentially preventing appropriate stowage and limiting the effectiveness of firefighting efforts.

According to Allianz’ Safety and Shipping Review 2026, mis-declared cargo, such as batteries or chemicals, remains a major contributor to container ship fires – a quarter of cargo-related incidents. Failure to properly declare, document and pack such hazardous cargo can result in containers stowed inappropriately, or hamper firefighting efforts. 

The risk is therefore not simply that an undeclared battery may catch fire, but that the crew may not know what is burning, where the batteries are located or how much battery cargo is present, hampering an effective emergency response.

However, industry initiatives and organizations have been trying to mitigate the risks. For instance, the International Safe Containerised Cargo Organisation (CINS) has issued guidelines for shipping lithium-ion cells in containers.

WSC proposes container-level threshold

To address the issue, the WSC, backed by five governments and a wider coalition of industry organizations, has submitted a paper to the International Maritime Organization (IMO) for consideration.

The submission highlights the following points:

• Close the existing safety gap: The current lack of visibility for containerized battery cargo transported under SP188 should be addressed as a matter of urgency.
• Improve transport safety: Greater visibility of significant battery hazards could improve safety for shippers, ports, ships and crews, coastal states and other parties involved in or affected by the transport.
• Reduce pressure on carriers: Better hazard visibility could help ease the pressure currently placed on carriers through increased scrutiny of bookings and cargo acceptance restrictions.
• Use an existing IMDG model: The WSC proposes drawing on Special Provision 963 (SP963), which applies to UN 3496 and establishes a maximum cargo transport unit (CTU)-level threshold above which hazard communication requirements are triggered.
• Set a container-level threshold: SP188 could be adapted to establish a maximum total threshold for batteries within a CTU, expressed either in watt-hours (Wh) or gross mass.
• Trigger hazard communication: Once the proposed threshold is exceeded, the requirements under sections 5.4.1 and 5.4.3 of the IMDG Code for dangerous goods documentation and information could apply.
• Consider placarding requirements: The proposal also considers triggering the placarding requirements under section 5.3 once the container-level threshold is exceeded.
• Choose a practical measurement: The submission notes that a gross-mass threshold could be easier to measure in practice, while a Wh-based threshold could provide greater precision.
• Build on existing limits: The proposed approach could mirror the existing 30 kg gross-mass package-level limitation in SP188, while introducing a separate threshold applicable to the total contents of a container.
• Already tabled internationally: A possible pathway was presented to the UN Sub-Committee of Experts on the Transport of Dangerous Goods (SCETDG) at its 68th session, held from June 30 to July 8, 2026, for consideration under the Model Regulations where feasible. The proposal was also shared with the IMO Sub-Committee on Carriage of Cargoes and Containers (CCC 12) for parallel awareness.

The proposal sets out a potential maximum threshold at the container level, above which shipments of batteries would have to be declared and potentially placarded.

The WSC said such a threshold would help ensure that large quantities of battery cargo become visible to those responsible for transporting, handling and responding to incidents involving the cargo, while retaining simplified requirements for smaller battery shipments that fall within the intended scope of SP188.

As battery shipments continue to grow, we need a better solution that makes these cargoes visible and allows the risks to be properly managed 

… Kramek highlighted, pointing out that the current rules are not working as intended

IMO to consider the issue

Governments will consider the issue at the IMO Sub-Committee on Carriage of Cargoes and Containers (CCC), which is scheduled to meet in London from September 14 to 18, 2026.

The discussions will take place as battery use and related cargo volumes continue to increase, raising concerns over whether existing dangerous goods requirements provide sufficient visibility of the potential hazards associated with large quantities of lithium batteries transported in containers.

source : safety4sea