Exporting lithium batteries may soon require an additional procedural step.
Recently, CINS (Cargo Incident Notification System), a safety organization within the container shipping industry, issued a set of recommendations regarding the maritime transport of lithium-ion batteries. The document proposes that even lithium-ion battery shipments currently exempt under the IMDG Code’s Special Provision 188 (SP188)—and thus not subject to full dangerous goods declaration procedures—should be included in the scope of mandatory declarations.
While this may appear to be merely a suggestion for an extra administrative step, the implications are far more complex for the lithium battery industry, which relies heavily on maritime exports.
01. Why impose stricter controls on lithium batteries?
Let us first examine the core of the CINS proposal. In short, it boils down to two points:
First, mandatory declaration for all shipments containing lithium batteries. Regardless of whether they meet the SP188 exemption criteria, all such shipments must be declared as dangerous goods. Even if the gross weight of a single container is 20 kg or less, a mandatory declaration is required.
Second, a 20 kg upper limit on the total weight of lithium batteries per container. Shipments exceeding this weight must comply with relevant IMDG regulations and be declared as dangerous goods.
It is important to emphasize that these are currently industry recommendations, not yet binding global regulations. So, why is CINS calling for mandatory declarations now?
To understand this, we must look at the rule itself. SP188 is a special provision within the *International Maritime Dangerous Goods (IMDG) Code*, originally designed to simplify transport for certain low-capacity, low-risk lithium battery products. Lithium-ion cells and battery packs that meet specific criteria—such as a rated energy of no more than 20 Wh per cell or 100 Wh per pack—and comply with requirements like UN38.3 testing, short-circuit prevention, and standardized packaging, are eligible for exemptions from standard dangerous goods transport regulations.
In layman's terms, items such as a single 18650 cell, a laptop battery, or a power bank do not require a dangerous goods declaration, provided they meet the regulations.
The issue is that the scale of lithium battery transport has changed dramatically. Lithium batteries have expanded far beyond consumer electronics like mobile phones and computers into sectors such as new energy vehicles, energy storage systems, and power tools, resulting in a significant increase in battery shipments by sea. Furthermore, if a lithium battery undergoes thermal runaway, it can trigger fires and explosions and poses a risk of re-ignition, making firefighting and emergency response on ocean-going vessels significantly more difficult. Shipping safety data suggests that these concerns are well-founded. The *Safety and Shipping Review 2026* published by Allianz Commercial reveals that there were 218 fire and explosion incidents involving ships globally in 2025—the second-highest figure in the past decade. Notably, misdeclared or undeclared cargo—including hazardous materials like batteries and chemicals—accounted for approximately one-quarter of all cargo-related incidents. The report also highlights a link between lithium-ion batteries and numerous major ship fires.
In other words, while the risk posed by a single, low-capacity battery may be limited, the increasing volume of lithium batteries entering the container shipping system as general cargo makes it difficult for shipping lines to accurately track exactly what—and how much—is inside the containers. In the event of an accident, a lack of transparency regarding cargo details not only complicates stowage planning but also hinders the crew's ability to assess the situation and execute firefighting measures.
Consequently, the recent recommendations from CINS serve to refocus attention on cargo declaration, quantity controls, and transparency across the transport chain. Industry trends indicate that this tightening of standards is already underway, with some shipping lines having proactively raised their declaration requirements for lithium battery shipments.
Put simply, the maritime transport of lithium batteries is shifting away from the previous "simplify wherever possible" approach toward a model that prioritizes clear risk disclosure.
02. The Economics of Exporting Energy Storage Products May Need Recalculation
If the CINS recommendations are implemented, the immediate pressure will fall on smaller-scale energy storage products—such as portable power stations, home backup power systems, and small-scale UPS units.
In recent years, these products have become a key component of China's energy storage exports. As individual units, they have relatively low capacities, and the lithium battery packs in some models meet the criteria for Special Provision 188 (SP188), allowing them to benefit from simplified transport regulations.
Should the scope of SP188 be restricted, these products would first face a change in transport classification: shifting from a simplified, exemption-eligible status to the full hazardous goods declaration process. This transition entails stricter requirements for packaging, labeling, documentation, booking, and port operations, inevitably driving up both logistics and compliance costs. For products like portable power stations—which rely heavily on price competitiveness—these additional transport costs are likely to be passed on to the final product price, potentially impacting competitiveness in overseas markets. However, the situation for large-scale energy storage containers differs; they are not the direct "victims" of these regulatory changes.
Currently, large-scale energy storage systems are typically shipped as Class 9 dangerous goods and do not fall into the category of cargo eligible for the SP188 exemption. Consequently, even if SP188 regulations are tightened in the future, the classification of these large containers as dangerous goods remains unchanged.
This does not mean, however, that large-scale energy storage equipment is entirely unaffected. A more realistic impact may stem from a general shift in risk appetite across the shipping industry regarding lithium-battery cargo.
As shipping lines, ports, and insurers raise the bar for vetting lithium-battery shipments, energy storage containers may face stricter scrutiny regarding booking, loading management, and transport conditions. For transoceanic energy storage projects, factors such as cargo space availability, schedule stability, and port handling capabilities could emerge as new variables influencing delivery timelines.
In fact, domestic ports have already begun supplementing regulations for the maritime transport of energy storage systems. In August, authorities including the Xiamen Maritime Safety Administration released the *Guidelines for the Safe Maritime Transport of Containerized Lithium-Ion Battery Energy Storage Systems at Xiamen Port (Version 2.0)*. These guidelines refine requirements for thermal runaway prevention, container inspection, state-of-charge (SOC) at shipment, and real-time monitoring and alerts. They also expand the scope to include sodium-ion and hybrid lithium-sodium batteries and cover additional transport scenarios, such as multi-purpose vessels and combined land-sea transport.
This underscores a key trend: the maritime transport phase of exporting energy storage systems is shifting from merely getting the goods shipped to ensuring they are shipped in compliance with increasingly rigorous standards.
More importantly, a complete energy storage project involves a host of components—such as BMS, EMS, thermal management systems, and connectors—alongside the main units. Some of these auxiliary devices contain small built-in lithium batteries and may likewise be subject to changing declaration and transport regulations.
In conclusion:
For the energy storage industry, the real issue may not be whether SP188 is amended, but rather whether transport safety and regulatory compliance will emerge as critical competitive factors—alongside cell prices and system costs—for products destined for overseas markets.
The answer is becoming increasingly clear.
In the next phase of energy storage globalization, success will depend not only on whether products can be sold, but also on whether they can be transported safely, efficiently, and in full compliance with regulations.
