Declaration requirements for lithium batteries shipped by sea may be tightened further. CINS, a safety organization for the container shipping industry, recently recommended that all shipments containing lithium-ion batteries be declared, including those currently eligible for relief under Special Provision 188 (SP188) of the IMDG Code. CINS also proposed limiting the total gross mass of lithium-ion batteries transported under SP188 to 20 kg per cargo transport unit (CTU). These remain industry recommendations and have not taken effect as new international regulations. However, some carriers have already tightened their declaration and approval requirements for lithium battery shipments.

Key Highlights 

• Declaration of all shipments: CINS recommends declaring all shipments containing lithium-ion batteries, including those covered by SP188. 

• Proposed 20 kg/CTU threshold: Shipments exceeding the proposed threshold would need to be declared and handled as dangerous goods under the IMDG Code. 

• Tighter carrier requirements: Some carriers have already tightened their booking and declaration requirements for lithium battery shipments.

Why Is CINS Recommending the Declaration of All Lithium Battery Shipments?

SP188 was introduced to provide transport relief for qualifying lithium batteries that present a relatively limited risk when shipped in individual packages. However, as lithium batteries become increasingly common in consumer electronics, energy storage systems, and electric equipment, CINS believes that compliance with SP188 at the individual package level does not necessarily mean the risk remains low when large quantities of batteries are consolidated in a single container.

One of CINS’s main concerns is that SP188 currently sets requirements for individual packages but does not impose a corresponding limit on the cumulative quantity of lithium-ion batteries loaded in a CTU. Carriers may know that each package meets the applicable requirements but have no accurate information about the total quantity of batteries inside the container. In the event of a fire, crew members, terminal personnel, and emergency responders may have difficulty quickly identifying the cargo and assessing the risks. CINS has therefore called for greater transparency and traceability for lithium battery shipments throughout the transport chain.

The 2020 fire aboard X-Press Godavari has also drawn industry attention to this issue. The investigation found that the container involved carried more than 7,000 kg of lithium-ion batteries. Although the individual packages complied with SP188, consolidating such a large quantity in one container increased the overall risk. The incident is one of the key factors behind CINS’s proposal for a CTU-level weight limit.

△CINS

What Does 20 kg/CTU Mean, and Will SP188 Be Withdrawn?

The most closely watched element of the proposal is the 20 kg/CTU threshold. The 20 kg limit refers to the total gross mass of lithium-ion batteries in a single CTU, not the weight limit for an individual battery package. Under the CINS proposal, SP188 would remain in place. If the total gross mass of lithium-ion batteries in a CTU does not exceed 20 kg, the shipment could still qualify for transport relief, provided that all applicable conditions are met, but it would still need to be declared. If the total gross mass exceeds 20 kg, the shipment would need to be declared and handled in accordance with the relevant dangerous goods requirements of the IMDG Code.

CINS is therefore not proposing that SP188 be withdrawn. Instead, it is seeking to make the provision subject to stricter conditions. The proposed 20 kg/CTU threshold should not be treated as a mandatory international standard currently in force. Any formal incorporation into the IMDG Code would still need to go through the relevant amendment process.

This distinction is particularly important for companies arranging lithium battery shipments in the near term. The proposal does not mean that shipments exceeding 20 kg are prohibited, nor does it mean that all SP188 shipments have already been reclassified as dangerous goods. Whether a booking will be accepted, what documentation must be submitted, and whether additional approval is required will continue to depend on the latest requirements of the individual carrier.

Carrier Requirements Are Already Tightening—What Is Needed for Booking?

Although the CINS recommendations have not become formal international regulations, some carriers have already tightened their requirements. CMA CGM, for example, requires cargo containing lithium-ion batteries to be declared, including dangerous goods, non-dangerous goods, and shipments covered by SP188. Depending on the cargo, the carrier may also require supporting battery documentation. Emirates Shipping Line has previously imposed a temporary suspension on lithium battery shipments, including those covered by SP188.

Whether a shipment qualifies for SP188 is therefore no longer the only consideration. Shippers and freight forwarders must also determine whether the carrier requires a declaration, what battery documentation must be submitted, and whether additional approval or route restrictions apply. When booking lithium battery shipments, freight forwarders and cargo owners should confirm the carrier’s latest policy in advance and prepare any required documents, such as an MSDS, a UN 38.3 test report, and evidence of SP188 compliance. This can help avoid situations in which cargo cannot move as planned after shipping arrangements have already been made.

For now, there has been no immediate, industry-wide change to lithium battery shipping rules. However, the industry is placing greater emphasis on shipment transparency and container-level risk controls. The proposed 20 kg/CTU threshold should therefore be viewed as an important indicator of possible future changes. Current shipments should continue to be handled in accordance with the existing IMDG Code and the latest requirements of the individual carrier.

Sources and Disclaimer 

Sources include CINS, CMA CGM, Emirates Shipping Line, the Marine Safety Investigation Unit of Malta, and publicly available shipping industry information. This article is provided solely for reference by the international logistics and freight forwarding industry. Specific requirements remain subject to the latest notices issued by the relevant authorities and carriers.