THE World Shipping Council (WSC) is urging governments to close a critical maritime loophole in the International Maritime Dangerous Goods Code that allows large shipments of lithium batteries to bypass hazardous cargo declarations.
Special Provision 188 (SP188) exempts small batteries meeting specific capacity and testing criteria from full dangerous goods rules. However, because the rule lacks a consolidation limit, a container holding 4,200 laptops — equivalent to 416 kWh of energy or roughly four electric vehicles — can travel without hazardous documentation or placarding.
“Right now, a container can be packed with thousands of lithium batteries and still travel without being declared as dangerous goods,” stated Joe Kramek, president and CEO of the WSC. “The SP188 exemption was intended to simplify the transport of individual devices with small batteries, not to make entire container loads invisible.”
This regulatory gap creates severe risks as global trade grows. According to International Energy Agency data, lithium-ion battery deployment in 2025 was six times higher than in 2020, while insurer Allianz reports that container ship fires occur every 17 days on average.
When these hazards remain hidden, carriers, port operators, and emergency responders cannot accurately assess risk, select appropriate shipboard stowage, separate containers from other sensitive cargo, or coordinate an effective response to thermal runaway fires.
“The current rules are not working as intended,” Kramek emphasized. Supported by five governments and industry partners, the WSC has submitted a proposal to the IMO Sub-Committee on Carriage of Cargoes and Containers, meeting in London from Sept. 14-18, 2026, to establish maximum container-level thresholds for battery declarations.