The 12th session of the International Maritime Organization's Sub-Committee on Carriage of Cargoes and Containers (CCC 12) convened last week, and the regulatory blind spot at the top of the agenda was Special Provision 188 (SP188) — the rule that lets certain small lithium and sodium batteries move through the supply chain under relaxed dangerous goods controls.

The committee's work on SP188 reflects what shippers, carriers and forwarders already see on deck: a fast-growing flow of battery-powered goods crossing the world's container terminals, outpacing the visibility systems designed to keep them safe.

What is SP188 and why does it matter?

SP188 sits inside the international transport codes governing how lithium cells and batteries move by sea. It carves out exemptions for small-format cells and batteries that meet specific test criteria, allowing them to ship without the full suite of dangerous goods documentation, packaging and stowage rules that larger lithium battery consignments face.

The provision has existed for years. What changed, according to industry observers, is the volume. Battery-powered goods now cross container terminals at a pace the original rule was never written to absorb.

What did the industry tell CCC 12?

Tigris, a supply chain risk and visibility firm, raised the issue through its report "Before the Fire: Dangerous goods safety and the visibility gap," which the company published ahead of the sub-committee meeting.

Tom Bebbington, Tigris's Industry Engagement & Strategic Partnerships Lead, framed the problem in commercial terms.

"The changing shape of goods being moved around the world reflects the global evolution of technologies: for example, the growth of batteries in transit," Bebbington said. "Such rapid growth has exposed the lack of rigour in the global shipping process and specific issues with Special Provision 188."

Bebbington warned against treating data dashboards as a fix on their own. "There is the risk that we over-rely on data as the solution, particularly when there is a lack of incentive to course-correct," he said. "Technology must be designed around human error and human self-interest."

What does a battery incident cost a carrier?

The operational price of a battery fire at sea is steep, Bebbington noted, and that cost explains why mitigation often stalls.

"Data only helps if people are empowered and willing to act on it in time," he said. "Even where the risk is visible, fixing it means diverting the vessel, restowing hundreds of containers, delaying the schedule, and burning more fuel."

For a container line, a single diversion can reset a rotation, bunch vessels at the next port of call, and trigger demurrage and detention exposure for shippers waiting at berth. Bebbington's point is that the economics of "do nothing" can look more rational than the economics of "act in time" — at least until the incident happens.

What happens next?

The sub-committee progressed work on alternative fuels, onboard carbon capture, cargo securing and dangerous goods during the same week, but the SP188 question remains open. No binding amendment to the provision has been adopted at CCC 12.

"Identifying and acknowledging the issue is a pivotal first step, but what happens next will be critical," Bebbington said.

The next test will be whether IMO members use the CCC 12 record to tighten the SP188 criteria, require enhanced stowage and monitoring for exempted cells, or push the burden of proof onto shippers and manufacturers to demonstrate compliance. Carriers, meanwhile, will weigh the cost of voluntary restrictions against the exposure of a single misdeclared container.