Cargo ship

New CINS Operational Guidelines for Lithium-Ion Batteries Shipped Under SP188

The Cargo Incident Network System (CINS) has now released Operational Guidelines for Lithium-Ion Batteries Shipped Under SP188 (Special Provision 188 of the IMDG Code).

Written by

Image of Mark Russell

Mark Russell

Vice President, Global Claims Lead, Safer with Gard

Published 04 November 2026

These operational guidelines bring together practical experience and observations from CINS Member carriers involved in lithium-ion battery container fire incidents, together with input from shore-based firefighting specialists and terminal operators involved in incident response.

The guidance translates these real-world experiences into practical considerations for CINS Members and the wider maritime community.

It focuses on strengthening cargo visibility, risk-informed stowage planning, firefighting preparedness, and emergency response throughout the maritime transport chain.

At the heart of the guidance is a practical approach to managing risk: maintaining visibility of SP188 lithium-ion battery cargo before an incident occurs, while ensuring that firefighting capability, equipment, and trained personnel are sufficient to sustain prolonged firefighting and cooling operations if an incident develops.

The operational guidelines follow CINS’ publication of a Recommendation Paper on IMDG SP188 Lithium-Ion Batteries highlighting operational invisibility concerns brought about by the regulatory relief provided for in SP188. As highlighted in this Gard insight article, SP 188 exempts certain lithium batteries from the IMDG code’s Dangerous Goods (DG) declaration and other requirements. This is amid growing concerns, borne out by Gard claim experience described in that article, that battery-related fire incidents are becoming more frequent and severe.

The IMO Sub-Committee on Carriage of Cargoes and Containers (CCC) held its twelfth session in September 2026 (CCC 12) and considered several proposals for amendments to the IMDG Code. Notably, this included a Word Shipping Council submission that was co-sponsored by numerous industry bodies, including the International Group of P&I Clubs. Proposed amendments at CCC12 were referred to the IMO Editorial and Technical Group for further development, including the improvement of hazard communication for large quantities of batteries transported under special provision 188. E&T 46 will convene in Spring 2027 and will submit a report to CCC13. The WSC has filed a parallel UN submission with the United Nations Dangerous Goods Committee in view of multi-modal transportation considerations.

In collaboration with the International Group of P&I Clubs, the TT Club and IUMI, CINS has also previously published Guidelines for the Shipping of Lithium-ion Cells and Batteries that are declared under UN N Nos. 3480 and 3481 in Cargo Transport Units (CTUs).

Download the new operational guidelines here

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