The World Shipping Council (WSC) is calling on governments to close a loophole in international dangerous goods regulations concerning the transport of batteries in containers. According to the umbrella organisation for container shipping companies, thousands of lithium batteries are being transported in containers without carriers being aware of the danger, reports the Belgian trade publication Flows.
The urgency stems from the growth in demand. According to the International Energy Agency, the use of lithium-ion batteries in 2025 was six times higher than in 2020, and demand is expected to double by 2030. At the same time, fire poses a constant risk at sea: insurer Allianz previously stated that, on average, a fire breaks out on board a ship every seventeen days.
The loophole in the regulations: Special Provision 188
The crux of the problem lies in the so-called Special Provision 188 (SP188) of the International Maritime Dangerous Goods Code, the international set of regulations governing dangerous goods at sea. This provision exempts smaller batteries from certain requirements, provided they meet specific testing, packaging and capacity criteria. However, there is no limit on the number of exempted batteries that may be consolidated in a single container.
The result is easy to imagine. A container holding 4,200 laptops can contain approximately 416 kWh of stored energy — the equivalent of three to four electric cars — without requiring any dangerous goods documentation or warning signs on the container.
Full container load remains undetected
WSC Chairman and CEO Joe Kramek points out that, today, a container can be loaded with thousands of lithium batteries without being declared as dangerous goods. According to him, the SP188 provision was intended to simplify the transport of individual items containing small batteries — not to make an entire container load invisible. According to Kramek, batteries transported under SP188 have already caused significant container fires, thereby endangering people, ports, ships and the marine environment.
Ignorance is the real risk
The WSC emphasises that batteries are transported safely every day when they are correctly labelled and the risk is managed appropriately. The problem arises when carriers, crews, ports and emergency services do not know what is inside the container. Without that information, shipping companies cannot arrange for appropriate loading, keep the containers separate from other cargo, or prepare an emergency plan in case things go wrong.
Proposal submitted to the IMO
The WSC, with the support of five governments and a broad coalition of industry organisations, has submitted a proposal to the International Maritime Organisation (IMO). The proposal calls for a maximum limit per container: anyone transporting batteries in excess of this limit must declare this and may also be required to affix warning signs to the container. According to Kramek, the current rules are not working as intended and, with the growth in battery transport, a solution is needed to make this cargo visible. The issue is on the agenda of the IMO subcommittee on the carriage of cargo and containers, which is due to meet in London from 14 to 18 September 2026.
Implications for importers and exporters
Shippers should take this news seriously, even though no new regulation has yet come into force. Anyone shipping products containing lithium batteries — from electronics to tools — would be well advised to classify and declare the cargo correctly as of now. This is not just a matter of safety: in the event of an incident involving undeclared battery cargo, transport insurance cover may also be called into question. On the page about dangerous goods, you can read about what is involved in the transport of dangerous goods.
If the IMO proposal is adopted, there may be significant changes to the documentation and labelling requirements for consignments containing batteries. TOP is monitoring the decision-making process in London and will inform customers as soon as there is clarity. If you’re unsure whether your products are subject to dangerous goods regulations or how to prepare for stricter requirements, please request tailored advice.
a single container holding 4,200 laptops can contain approximately 416 kWh of stored energy? That is comparable to three to four electric cars — and under current regulations, such a container is permitted on board without dangerous goods documentation or warning signs.
