Recently, CINS (Cargo Incident Notification System), composed of 14 leading container shipping companies, released a proposal recommending amendments to the SP188 exemption clause under the IMDG Code, proposing a comprehensive new control scheme for all lithium battery marine transport.
Two Core Reform Proposals
(1) Mandatory Declaration of Lithium Battery Cargo
Even lithium batteries and products with built-in batteries that meet the current SP188 exemption conditions and could previously be shipped as general cargo, will be required to undergo mandatory declaration, no longer enjoying the convenience of exemption from dangerous goods declaration.
(2) 20kg Gross Weight Limit Per Container for Lithium Batteries
Lithium batteries shipped under the SP188 exemption channel must not exceed a total gross weight of 20kg per container. If the total lithium battery weight in a container exceeds this threshold, the exemption will not apply, and the cargo must be fully booked and shipped as a Class 9 dangerous good.
Important Reminder: This is currently an industry proposal, not an officially effective IMO regulation. The proposal will be reviewed at the IMO CCC-12 meeting on September 14–18. It has not yet come into effect, but some shipping companies have already begun tightening their carrying standards in advance.
Persistently High Risk of Lithium Battery Fires at Sea
According to CINS statistics, lithium battery-related fire incidents on container ships occur approximately every 17 days. A large number of power banks, small appliances, consumer electronics, and other products are shipped as general cargo under the SP188 exemption.
The large volume of batteries in containers, without dangerous goods labeling, leaves crew unable to identify potential risks. Once thermal runaway occurs, the difficulty of shipboard firefighting and rescue is extremely high, making it one of the main causes of container ship fires at sea.
Current SP188 Exemption Conditions: Single cells ≤20Wh, battery packs ≤100Wh, having passed drop tests, meeting the conditions allows exemption from full DG dangerous goods declaration and shipment as general cargo.
Shipping Lines Preemptively Tightening Controls
Shipping lines such as CMA CGM have already implemented control measures in advance on multiple routes including Vietnam, India, UAE, and Lebanon:
1. Regardless of whether the cargo meets SP188 exemption conditions, the booking process must actively declare the presence of lithium batteries in the container;
2. Submission of complete documentation including UN38.3 reports, MSDS, and actual battery photos for verification is required;
3. Misdeclaration of lithium batteries will face severe penalties, with fines up to USD 15,000 per container, accompanied by container detention, return shipment, and high demurrage and detention charges, with all losses borne by the shipper.
Which Importing and exporting Enterprises Will Be Affected?
Importers and exporters of mobile phones, laptops, power tools, small appliances, power banks, various battery-equipped consumer electronics, lithium battery components, and other product categories will be impacted. A large number of cross-border e-commerce, machinery and electronics manufacturers, and foreign trade enterprises need to pay close attention to the regulatory changes.
Click here to check our story about handling shipments of goods containing power banks for our client.
Marine safety regulation continues to tighten. Compliance in lithium battery exports has become an unavoidable topic. Even though the proposal has not yet officially taken effect, importing and exporting enterprises are advised to abandon the old practice of "passing off goods as general cargo" and prioritize compliance to avoid subsequent heavy fines, container detention, and return shipment losses.
If you have any questions about shipping from China, please contact our logistics expert, Icey.
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