The Cargo Incident Notification System (CINS) has issued the new Operational Guidelines for Lithium-Ion Batteries addressing the fire risks associated with lithium-ion battery shipments that qualify for exemptions under the International Maritime Dangerous Goods (IMDG) Code.
Published in November 2026, the Operational Guidelines for Lithium-Ion Batteries Shipped Under SP188 highlight concerns that substantial quantities of lithium-ion batteries may be transported without being fully visible through conventional dangerous goods management systems. The publication outlines practical measures to strengthen cargo verification, stowage planning, firefighting preparedness and emergency response.
The new publication builds on earlier CINS initiatives to improve lithium-ion battery transport safety. In April, CINS published updated guidelines for shipping lithium-ion cells and batteries in containers, developed with the International Group of P&I Clubs, TT Club and the International Union of Marine Insurance (IUMI).
Regulatory exemptions raise cargo visibility concerns
According to CINS, Special Provision 188 (SP188) provides regulatory relief for eligible small lithium-ion cells and batteries that meet specific conditions, including capacity, testing, packaging and marking requirements.
Under SP188, lithium-ion cells rated at no more than 20 watt-hours (Wh) and batteries rated at no more than 100 Wh may qualify for exemptions from certain IMDG Code requirements. These include the standard dangerous goods declaration, provided all applicable conditions are satisfied.
However, CINS identifies a significant operational concern: the IMDG Code does not impose an aggregate SP188 battery quantity or energy limit at freight-container level. Consequently, containers may carry substantial quantities of qualifying lithium-ion batteries without their aggregate energy content being apparent from dangerous goods manifests.
CINS also notes that advances in battery technology since the introduction of SP188 in 1998 have expanded the capabilities of batteries eligible for the provision.
The guidelines emphasize that regulatory compliance alone does not eliminate operational risks, particularly where incomplete cargo information affects stowage decisions and emergency preparedness.
Key operational safety recommendations
Drawing on cargo incident reports, investigations and operational experience, CINS identifies several measures to improve the management of higher-risk SP188 shipments.
- Strengthen cargo acceptance and verification: Carriers should consider obtaining detailed information on battery type, quantity, applicable UN number, SP188 eligibility and testing compliance. Risk-based customer assessments, document verification and targeted inspections can help identify misdeclared or improperly packaged shipments.
- Improve cargo visibility: Information identifying higher-risk lithium-ion battery shipments should remain accessible throughout booking, terminal handling, stowage planning, vessel operations and emergency response. CINS encourages the use of standardized cargo attribute codes, including LIB and LIO, to support information exchange.
- Apply thermal-risk-based stowage planning: Carriers should consider heat exposure, proximity to machinery spaces, direct sunlight and the potential consequences of placing higher-risk battery cargo near other hazardous substances. Where operationally appropriate, on-deck stowage may improve accessibility for monitoring and firefighting.
- Enhance firefighting capabilities: Shipping companies should assess whether existing firefighting equipment can support prolonged container fire incidents, including sustained cooling and boundary protection. Equipment considerations include water mist lances, mobile water monitors, thermal imaging cameras and container penetration systems.
- Strengthen crew training and emergency preparedness: Exercises should address thermal runaway, toxic-gas exposure, explosions, jet flames, reignition and extended firefighting operations. CINS also encourages access to qualified shore-based emergency response specialists.
Thermal exposure and cargo concentration require attention
A significant part of the guidelines addresses the role of temperature and container positioning in managing lithium-ion battery risks.
CINS explains that containers may experience different thermal conditions depending on their location, exposure to sunlight, surrounding structures, cargo arrangements and weather conditions. The publication includes thermal images demonstrating variations in container surface temperatures at terminals and onboard ships. For identified higher-risk SP188 shipments, carriers and terminal operators are encouraged to consider these differences when planning storage and stowage arrangements. CINS also recommends avoiding excessive concentrations of higher-risk lithium-ion battery cargo in a single stowage area where operationally feasible, as such concentrations could increase the potential consequences of a fire and complicate emergency response.
Particular attention should be given to proximity to accommodation spaces, essential ship systems, heat sources and cargoes that could aggravate an incident, including flammable liquids, gases and oxidizers.
The guidelines do not introduce mandatory segregation distances or additional quantity limits. Instead, they encourage operators to incorporate these considerations into existing risk assessment processes.
Firefighting preparedness must account for prolonged incidents
CINS highlights the particular challenges associated with lithium-ion battery container fires, including thermal runaway propagation, explosions, jet flames, toxic-gas release and reignition.
At sea, firefighting operations may be further complicated by restricted access, limited resources and the potential absence of immediate external assistance. The guidelines distinguish between on-deck and under-deck fire scenarios.
For on-deck incidents, direct observation, thermal monitoring, water application and boundary cooling may be more accessible. Under-deck incidents may require additional consideration of smoke accumulation, fixed-fire-extinguishing arrangements, the limitations of CO systems during thermal runaway, and the stability implications of water application or flooding.
CINS also discusses the potential use of container penetration techniques and sustained water application to establish temporary protective barriers around burning containers, where appropriate and following vessel-specific assessment.
For container ships constructed before the enhanced IMO firefighting provisions took effect on January 1, 2016, the organization encourages operators to consider voluntarily upgrading their firefighting capabilities to levels comparable with newer vessels.
Crew competency is another central concern. CINS recommends scenario-based training and drills that address equipment operation, thermal monitoring, safe approaches, prolonged cooling operations and crew rotation.
Cargo information must remain available throughout transport Beyond shipboard operations, the guidelines emphasize that effective risk management depends on maintaining accurate cargo information throughout the transport chain.
CINS identifies transshipment operations, carrier handovers, terminal transfers and vessel-sharing arrangements as points where relevant cargo information may be lost or become less accessible.
It therefore encourages carriers and terminal operators to ensure that information identifying higher-risk lithium-ion battery shipments can be retained and communicated through operational systems, including BAPLIE stowage data exchanges.
This would help vessel planners, shipboard personnel and emergency response teams understand the distribution of relevant cargo risks, even where shipments are exempt from conventional dangerous goods declaration requirements.
Download the guidance at: