Are lithium batteries dangerous goods for sea transport is a frequently asked question.

Lithium batteries listed in IMDG Code 39th amendment

Packing instructions for Lithium metal and Lithium ion batteries

When transporting above by sea all packages must be marked and labelled, cargo transport units must be placarded /marked and dangerous goods declaration must be handed over to the carrier.

However, special provision 188 of IMDG Code exempt certain requirements of IMDG Code

Applicable only for

  • Lithium metal or lithium alloy cell, the lithium content is not more than 1 g
  • Lithium metal or lithium alloy battery, the aggregate lithium content is not more than 2 g
  • Lithium ion cell, the watt-hour rating is not more than 20 Wh
  • lithium-ion battery, the watt-hour rating is not more than 100 Wh

Exempted from other requirements of IMDG Code but must meet below provisions:

  • Cells and batteries must meet the provisions of 2.9.4.1 and 2.9.4.5.
  • Must be packed in inner packagings that completely enclose the cell or battery (not applicable when contained in equipment), Inner packagings shall be packed in strong outer packagings.
  • Must be protected so as to prevent short circuits.
  • Cells and batteries when installed in equipment shall be protected from damage and short circuit, and the equipment shall be equipped with an effective means of preventing accidental activation.
  • Each package shall be marked with below lithium battery mark
Lithium battery mark
  • Each package shall be capable of withstanding a 1.2 m drop test in any orientation without damage to cells or batteries contained therein, without shifting of the contents so as to allow battery to battery (or cell to cell) contact and without release of contents (not applicable when installed in equipment).
  • Gross mass must not be more than 30 kg.

For full details refer IMDG Code 39th Amendment.


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By Shashi Kallada

35 years in Merchant Shipping, Last 23 years working on IMDG Code. Ex Sailor, Ex Manager Global Dangerous Goods Maersk Line.

4 thoughts on “Lithium Batteries special provision 188 – IMDG Code 39-18”
  1. Dear Sir,

    I want to confirm below:

     The revision of the in January 2026
     Lithium Battery International Maritime Regulation IMDG Amendment 42 – Clause SP188 (UN3480)
    Special Provision 188 (Cell Batteries)
    ADG 7.5 Special Provision 188 (SP 188) requires that: Loose cells and batteries must be packed in inner packaging that completely enclose them. The cells and batteries must be protected to prevent short circuits.

    Regards,
    May Wong
    Tel: 27866459

    1. Hello May Wong,

      As per the latest IMDG Code (42-24) which will become mandatory from 1st Jan 2026 below are the package requirements for those under special provision SP 188

      188.4
      Package Cells and batteries, except when installed in equipment, shall be packed in inner packagings that completely enclose the cell or battery. Cells and batteries shall be protected so as to prevent short circuits. This includes protection against contact with electrically conductive material within the same packaging that could lead to a short circuit. The inner packagings shall be packed in strong outer packagings which conform to the provisions of 4.1.1.1, 4.1.1.2, and 4.1.1.5.

      For full explanation please visitunderstanding-imdg-code-special-provision-sp-188-for-lithium-sodium-batteries/

      Regards

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