Warning! Lithium Battery Cargo Proposed to Be Fully Included in Dangerous Goods Declaration!

Recently, the Container Inspection and Safety Organization (CINS) released an industry advisory document calling for mandatory declaration of all lithium-ion battery cargoes, including those eligible for dangerous goods declaration exemptions under Special Provision 188 (SP188) of the current International Maritime Dangerous Goods (IMDG) Code. This has attracted widespread attention in the foreign trade and logistics industries.
Proposed Container Total Quantity Control for Lithium Batteries Under SP188
In its advisory, CINS proposes a total gross weight control standard at the container freight unit level for lithium-ion batteries under SP188: when the total gross weight of SP188 lithium-ion batteries in a container does not exceed 20 kg, the cargo is still subject to the mandatory declaration obligation; when the total gross weight exceeds 20 kg, the IMDG dangerous goods regulations must be fully complied with, and mandatory declaration and transport as dangerous goods is required.
It should be clarified that this advisory is currently only an industry organization initiative and has not yet been incorporated into the official revised text of the IMDG Code; it still needs to undergo review through international maritime regulatory procedures. However, in practical terms, some liner operators have already tightened their booking declaration standards for lithium battery cargoes ahead of any formal regulatory change.
Existing Risk Gaps in SP188 Draw Attention
The original purpose of SP188 was to provide maritime transport facilitation for eligible, lower-risk small lithium-ion batteries and accompanying products, allowing qualifying cargoes to be exempted from the full Category 9 dangerous goods declaration process.
CINS points out that with the rapid growth of global lithium battery freight volumes, the fact that an individual package meets SP188 conditions does not mean the risk is controllable after concentrated loading in a container. There is a clear regulatory gap in the existing rules: carriers can confirm that individual packages are compliant, but cannot know the cumulative total quantity of lithium batteries loaded in a single container. Once thermal runaway and fire occur inside the container, crew members and shore-based emergency responders cannot accurately assess the cargo risk level at the first opportunity, which impedes ship emergency response.
Historical Incidents Confirm the Reality of the Risk
This risk has been corroborated by real incidents. In September 2020, a container fire occurred on the container ship "X-Press Godavari." A subsequent report by Malta's maritime safety investigation authority showed that the container involved was loaded with a cumulative total of more than 7,000 kg of lithium-ion batteries, and all individual packages complied with the SP188 requirements in force at the time. However, the old rules had no cumulative weight limit at the container level, and the concentrated stowage of large quantities of lithium batteries directly amplified the fire risk. This also serves as important background for CINS's proposed CTU weight limit.
Liner Operators Have Already Tightened Carriage Standards Ahead of Regulation
Even before CINS issued its advisory, some shipping companies had already introduced carriage requirements stricter than existing rules. CMA CGM issued a customer notice on July 17, 2026, requiring that all cargoes containing lithium-ion batteries, whether dangerous goods or non-dangerous goods (including cargoes under SP188), must complete declaration at the booking stage and submit supporting compliance documents such as MSDS and UN38.3 test reports, and the cargo must be marked with the corresponding SMDG code "LIO." Emirates Shipping Line had previously also announced a temporary suspension of lithium battery carriage business, including SP188 cargoes. Overall industry practices are shifting toward enhancing the transparency and traceability of lithium battery cargoes.
The container fire that occurred on the "CMA CGM Petra" in late August 2026, with industry speculation also pointing to lithium battery cargoes as the cause, has further prompted the industry to re-examine the safety blind spots brought about by the SP188 exemption.
Direction of SP188: Conditional Exemption May Become the Trend
According to the direction of the CINS advisory, the intention is not to directly abolish SP188, but to adjust it into a conditional exemption model. Cargoes meeting SP188 technical conditions may still enjoy partial transport facilitation, provided that the entire supply chain achieves cargo visibility, traceability, and controllable risk.
The core of subsequent changes lies in the fact that even if cargo meets the technical conditions for SP188 exemption, it will be difficult to continue shipping in a completely "invisible" ordinary cargo mode, and booking declaration and document submission requirements will be significantly raised. Whether this advisory can be incorporated into the official revised text of the IMDG Code still depends on the advancement of subsequent international regulatory procedures.
Industry Observations and Operational Recommendations
From the current trend, regulatory revision takes time, but shipping companies' independent tightening of carriage standards has become an established direction. Shippers and freight forwarders should no longer continue to rely solely on the SP188 exemption to book cargo as ordinary goods by default.
It is recommended that export enterprises review in advance the cargo attributes of products containing lithium batteries, distinguishing between cell capacity and total battery weight; proactively disclose lithium battery-related information at the booking stage; and prepare in advance documents such as UN38.3 test reports, MSDS, and SP188 compliance certificates to avoid booking rejection or shipment delays. Going forward, they should continuously track the progress of the CINS advisory and customer notices from various shipping companies, and adjust export operating procedures in a timely manner to ensure compliant shipment.

Source: Shipping Information WeChat Official Account