In the September issue of the Assagenti Newsletter, Avv. Enrico Ottonello comments on the proposal submitted by the World Shipping Council (WSC) to the International Maritime Organization (IMO). The proposal aims at revising Special Provision 188 of the IMDG Code, which currently provides simplified requirements for small lithium batteries but does not limit the total quantity that can be loaded into a single container.
The global deployment of these batteries in 2025 was six times higher than in 2020, and demand is expected to double by 2030. Furthermore, a battery-related fire reportedly occurs on a container ship every 17 days.
For instance, a single container carrying around 4,200 laptops can contain batteries with a combined capacity of 416 kWh—equivalent to the energy storage of three or four electric vehicles—without being declared as dangerous goods. To address this loophole, the WSC proposes a maximum threshold above which full declaration and marking requirements would apply. The proposal will be examined by the IMO’s Sub-Committee on Carriage of Cargoes and Containers (CCC).
