Mandatory reporting of containers lost at sea starts 1 January 2026

The primary objectives of these new requirements are to enhance maritime safety and safeguard the marine environment. According to the World Shipping Council’s latest Containers Lost at Sea Report 576 containers were lost in 2024. Whilst 2024’s reported losses represented an increase from the previous year, ships avoiding the Red Sea saw a 191% increase in transits around the Cape of Good Hope, exposing ships to more extreme and unpredictable weather and sea conditions. The South African Maritime Safety Authority reported nearly 200 containers lost in this region alone (35% of 2024’s total) something which has not been repeated in 2025, demonstrating the ability of the industry to learn from experience. Indeed, the vast majority of containers are transported without incident and with over 250 million containers transported in 2024, the number of losses remains very low.

Provisions have been introduced under SOLAS Chapter V (Safety of Navigation) through Resolution MSC.550(108) detailing the reporting requirements which apply to any ship carrying one or more freight containers or any ship that observes containers lost at sea. Masters must promptly report both the loss and any sightings of drifting containers. This ensures swift communication with nearby vessels, relevant coastal authorities, and the vessel’s flag State. The information required includes the ship’s identity, lost/drifting position, date & time and to the extent it is known, the number of containers lost/drifting, the container descriptions (size & type) and whether any Dangerous Goods are involved (with UN numbers).

IMO circular CCC.1/Circ.7 contains a reporting template and links to interim reporting forms that has developed for member states to use for reporting to the IMO.

It is recognized that at the time of the initial reporting, not all information may be available so there may be a need for more than one report. At the earliest, safe and practicable opportunity, a thorough inspection on a ship having lost containers is expected to verify the details. In the event of the ship being abandoned, or unable to report, the company, shall, to the fullest extent possible, assume the reporting obligations.

As the WSC say in their report, every container overboard is one too many. Consequences can be harmful for the environment, and Gard has experience of costly shore debris removal operations as well as significant claims in respect of lost and damaged cargo. The International Group (IG) is a member of the Maritime Research Institute of the Netherlands (MARIN) TopTier project, which was launched in 2021 to examine and assess the causes of container losses. The project brought together over 40 stakeholders including flag states, shipping companies, classification societies, and equipment manufacturers. Causal factors are numerous and complex. It should also be noted that many supply chain stakeholders, including shippers, forwarders, ship operators, terminals and stevedores have a role in supporting shipowners to prevent container losses.

The final TopTier Report was submitted to the IMO in September and Gard’s data analytics features on page 4. A workplan has identified 5 topics reflecting the main findings of TopTier Project and includes (i) operational guidance and limitations, (ii) conditions at sea, (iii)

loading, stowage, validation and planning (iv) strength properties and calculation issues (calculation technical standard and container securing gear) and (v) inspection programmes (container securing and lashing gear).

Vessel owners, operators, and masters should familiarise themselves with the amended SOLAS regulations and prepare to ensure timely compliance. This may include reviewing and updating the Safety Management Systems (SMS) so that bridge teams are sufficiently guided on the new reporting obligations and in keeping proper records.

In addition to making the required reports, we recommend that Members with ships having lost containers send a copy of their report to the Club to assist with survey arrangements and potential claim impacts.