The international shipping industry is calling for changes to the way large quantities of lithium batteries are declared when transported by sea.
The World Shipping Council (WSC) has raised concerns about a potential safety gap within the International Maritime Dangerous Goods (IMDG) Code, specifically involving Special Provision 188 (SP188).
For New Zealand businesses importing or exporting lithium batteries, electronics, power tools and other battery-powered equipment, this is an important development to watch.
What is Special Provision 188?
Under the IMDG Code, lithium batteries are generally classified as Class 9 dangerous goods under entries including UN3480, UN3481, UN3090 and UN3091.
However, SP188 provides relief from many of the normal dangerous goods requirements when smaller batteries meet specific conditions.
For lithium-ion batteries, this generally includes cells not exceeding 20 Wh and batteries not exceeding 100 Wh, provided all other requirements of SP188 are met.
This allows many everyday products containing smaller lithium batteries to be transported by sea without being treated in the same way as fully regulated Class 9 dangerous goods.
What is the concern?
The issue raised by the WSC is that while SP188 limits the size of individual batteries, there is currently no overall limit on the number of compliant batteries that can be consolidated into a shipping container.
The WSC gives the example of a container carrying approximately 4,200 laptops containing around 416 kWh of battery energy. Despite the significant amount of stored energy, the container could potentially move without dangerous goods documentation or placarding under the current SP188 framework.
This creates a visibility issue for shipping lines. When fully regulated lithium batteries are declared as dangerous goods, carriers know what is being transported and can consider this when making decisions around acceptance, stowage and emergency response.
What changes are being proposed?
The World Shipping Council is calling for the International Maritime Organization (IMO) to consider a container-level threshold.
Individual smaller batteries could continue to qualify for SP188, but once the total quantity or battery energy within a container exceeded a specified threshold, additional declaration or placarding requirements could potentially apply.
The issue is due to be considered by the IMO Sub-Committee on Carriage of Cargoes and Containers in September 2026.
Importantly, SP188 has not currently changed. Businesses should continue following the requirements of the applicable IMDG Code while monitoring future developments.
What could this mean for New Zealand importers and exporters?
Any future change could affect New Zealand businesses shipping large quantities of:
- Lithium-ion batteries
- Laptops, tablets and electronics
- Power tools and equipment
- Replacement batteries
- Other battery-powered products
A shipment that currently qualifies for relief under SP188 could potentially face additional requirements if a future container-level threshold is introduced.
It is also important to remember that SP188 is not a blanket exemption for lithium batteries. All conditions of the provision must be satisfied before the relief can be applied.
Shipping Lithium Batteries from New Zealand?
DG Solutions NZ assists businesses with the compliant transport of lithium batteries and other dangerous goods throughout New Zealand and internationally.
We can assist with lithium battery classification, IMDG and IATA dangerous goods declarations, UN packaging, repacking, marking and labelling, international dangerous goods freight and dangerous goods training.
If you're unsure whether your lithium battery shipment qualifies for SP188 or requires a full dangerous goods declaration, contact DG Solutions NZ before shipping.
This article reflects industry discussions as at September 2026. Proposed changes should not be treated as amendments to the IMDG Code unless formally adopted and brought into force.