Battery Regulations Under Scrutiny Over Dangerous Goods ‘Blindspot’
A growing safety concern surrounding the international transport of lithium-ion batteries is putting a long-standing exemption within dangerous goods regulations firmly under the spotlight.
Under the International Maritime Dangerous Goods (IMDG) Code, smaller lithium batteries that meet specified testing, packaging and watt-hour requirements can be transported under Special Provision 188 (SP188), without requiring a Dangerous Goods Declaration.
The provision was originally introduced to facilitate the movement of smaller batteries, but the world has changed considerably since then. Global lithium-ion battery deployment in 2025 was more than six times the level recorded in 2020, according to the International Energy Agency.
Crucially, there is currently no overall limit on how many qualifying batteries can be consolidated into one container. This means a container can potentially hold hundreds or thousands of lithium-ion batteries while remaining undeclared as dangerous goods to the shipping line.
Industry bodies, including the World Shipping Council (WSC), are now calling for the regulations to be reconsidered, arguing that the growing volume of batteries being transported has created a significant safety gap.
The potential scale of the issue can be illustrated by a 40ft container carrying thousands of laptops. Individually, each laptop battery may fall within the SP188 exemption, yet collectively the container could carry an extremely substantial quantity of battery energy without the vessel’s crew being made aware of it as declared dangerous cargo.
The risks are far from theoretical.
In September 2020, the X-Press Godavari suffered a container fire while anchored in the Bay of Bengal. The affected container contained more than seven tonnes of lithium-ion batteries, but because the shipment qualified under SP188 it had not been declared as dangerous goods.
Investigators found that although individual packages were appropriately marked, the container itself did not have to carry the equivalent warning. Consequently, the crew were initially unaware that lithium-ion batteries were involved in the fire.
The issue is now expected to receive further attention at the IMO’s Sub-Committee on Carriage of Cargoes and Containers, which meets in September and is responsible for maintaining and developing provisions within the IMDG Code.
For shippers, the debate is another reminder that simply qualifying for an exemption does not remove the underlying risks associated with battery transport.
Evolution Forwarding specialises in dangerous goods logistics and supports customers with the classification, documentation, packaging and compliant international movement of hazardous cargo, including lithium batteries.
