Andre Klynsmith

Cargo Handling

Four Thousand Laptops, No Dangerous Goods Declaration: The Battery Loophole the IMO Is Being Asked to Close

A container can be packed with thousands of lithium batteries and still travel with no dangerous goods declaration and no placarding. The World Shipping Council has asked the International Maritime Organization to close that gap.

Cargo Handling

18 September 2026 • 4 min read

The exemption was written for the single laptop in a parcel. It is now being used for four thousand of them in one box — and nobody down the chain is told. The people who find out first are the ones who open the doors.

What Special Provision 188 actually allows

Special Provision 188 of the International Maritime Dangerous Goods Code exempts small lithium batteries from certain dangerous goods requirements when they meet specified testing, packaging and capacity criteria. The provision was designed to simplify the movement of individual devices with small batteries. What it does not do is cap the number of exempt batteries that may be consolidated into a single container.

The World Shipping Council’s worked example is blunt. A container holding around 4 200 laptops carries roughly 416 kilowatt-hours of stored energy — the equivalent of three or four electric vehicles’ battery capacity — and requires no dangerous goods documentation and no container placarding. “The SP188 exemption intends to simplify the transport of individual devices with small batteries, not to make entire container loads invisible,” said WSC President and CEO Joe Kramek.

What is being proposed

The WSC, supported by five governments and a coalition of industry organisations, has submitted a paper to the IMO proposing a container-level threshold. Battery shipments above that threshold would have to be declared and could attract placarding requirements. The IMO’s Sub-Committee on Carriage of Cargoes and Containers is considering the issue at a meeting in London, and the WSC has asked it to treat the matter as a priority so improved rules can be folded into Amendment 44-28 of the IMDG Code, which becomes mandatory on 1 January 2030.

That date is the honest part of the story. Even on a good outcome, the regulatory fix is years away. The WSC is careful to add that lithium batteries move safely every day when they are properly declared. The problem is not the cargo — it is the information.

Why this reaches inland SADC, not just the sea leg

The debate is framed around ships, stowage position and separation from other cargo. But a container that arrived undeclared does not acquire a declaration when it leaves the terminal gate. It goes onto a truck, through a depot, into a warehouse and across a border with the same silence attached.

For a road operator running a box from Durban or Walvis Bay to Lusaka or Harare, that means three practical exposures: a driver and vehicle carrying a fire load nobody priced; a yard stacking that box beside anything, because nothing on it says otherwise; and an insurer who may take a different view of a claim than the operator assumed. None of those risks are created by the regulation. They are inherited from it, several handoffs downstream.

About the Author
	Andre Klynsmith Entrepreneur & Technology Enthusiast Andre's expertise spans technology, blockchain, transport, and logistics — with a passion for innovation and driving positive change across industries. info@laaimylorrie.com | laaimylorrie.com