CINS, the Cargo Incident Notification System, is urging regulators to overhaul the IMDG Code’s SP188 exemption for lithium-ion batteries, warning that gaps in declaration and packaging are creating an “out of sight, out of control” fire risk in container shipping.
In a recommendation paper published in August 2026, CINS, an independent industry organization founded in 2011 by major container lines including CMA CGM, Maersk Line, and MSC, said SP188, which was originally meant to cover lower-risk battery shipments, no longer matches the scale and complexity of today’s lithium-ion trade. The organization pointed to incident evidence including fires, thermal runaway events, and cargo mismatches, where batteries declared as ordinary consumer goods were later found to be undeclared dangerous goods only after carrier screening.
CINS proposed reforms including a mandatory dangerous goods declaration for all lithium-ion battery shipments regardless of size, and a cap of 20 kg gross battery mass per container transport unit (CTU) before mandatory dangerous goods provisions under IMDG Code Chapter 5.4 would apply. It’s worth noting that the paper reflects CINS’ own policy position rather than independently verified data, and the underlying incident dataset is only available to members on request from the CINS Secretariat.
CINS also flagged operational risks if the exemption isn’t tightened, including fire spread between containers, limited effectiveness of onboard suppression systems like hydropens when battery cargo is misdeclared or concealed, and extended salvage and disposal processes following incidents.
IAM Member Impact: Members handling lithium-ion battery shipments, including consumer electronics, e-bikes, and equipment with embedded batteries, should review shipper declarations closely and expect stricter documentation requirements if SP188 reform advances. Members should also attend the Lithium Battery session at the upcoming IAM Annual Meeting and get ahead of any regulatory change by proactively requiring full battery specifications and test reports from shippers, regardless of shipment size.