How a vehicle is classified under the IMDG Code – exempt under Special Provision 961, or Class 9 under SP 962 – is one question. Whether a container line, a RoRo operator or a RoPax ferry will actually accept it for loading is a separate one, and the two don’t always align: a lithium-ion battery vehicle that is fully compliant with SP 961/962 can still be turned away at the gate if it doesn’t meet a carrier’s own state-of-charge or inspection policy.
Four distinct layers sit behind that gap, and this article keeps them separate rather than folding them into one another: IMDG classification (which UN entry applies), the SP 961 exemption (whether the Code applies at all), carrier acceptance policy (what the operator’s own booking terms require on top of the Code), and SOLAS shipboard safety requirements (what the vessel itself must have in the way of detection and suppression). For the clause-by-clause breakdown of SP 961 and SP 962, including the UN 3166/3171/3556/3557/3558 entries, see our companion article, Special Provisions 961 & 962: When a Vehicle Is Exempt — and When It’s Class 9. What follows here covers the other three layers: what container vessels, RoRo vessels and RoPax ferries each actually require by vehicle fuel/battery type, what ECG (the Association of European Vehicle Logistics) and EMSA (the European Maritime Safety Agency) recommend, what individual carriers publish, and where IMO’s own amendments are taking the framework next.
Disclaimer: Regulatory position reviewed as of 30 August 2026. This article is a general information reference on carrier, industry-body and IMO policy current at the time of writing. It does not cover IMDG Code classification – see the linked companion article for that – and it is not a substitute for a carrier’s own booking terms, a class society’s requirements, or professional regulatory advice. Carrier policies and IMO instruments change periodically; always confirm current requirements directly with your carrier, terminal or classification society before booking a shipment.
1. SP 961/962 Classification vs. Vessel-Type Acceptance Policy by Fuel / Battery Type
The same vehicle may be subject to different transport requirements depending on how and where it’s carried — including whether the conditions of SP 961 are met and what additional carrier or shipboard requirements apply. Container vessels carry vehicles packed inside CTUs; RoRo (cargo) vessels and PCTCs carry them driven on and off under their own power; RoPax ferries do the same but also carry fare-paying passengers, which is why they carry the most extensive fire-safety requirements of the three (see Table 5). For container vessels, both possible IMDG Code outcomes are shown — the non-dangerous-goods condition under SP 961, and the Class 9 fallback under SP 962 that applies whenever SP 961 isn’t met.
| Fuel / Battery Type | Container Vessels | RoRo Vessels (incl. PCTC) | RoPax Ferries |
|---|---|---|---|
| Diesel / petrol (ICE) — UN 3166 |
|
The IMDG provisions don’t prescribe an additional vehicle-specific SoC or acceptance requirement here; carrier and shipboard operational requirements may still apply. Standard ventilation and fire-patrol provisions cover the vehicle deck generally. | Same position as RoRo: no IMDG-specific requirement beyond the classification above, though the weather-deck ventilation and fire-detection provisions covering the vehicle deck generally still apply. |
| CNG / LPG (flammable gas) — UN 3166 |
|
Accepted under the same valve-closure conditions; carriers may require the vehicle to be driven on with the system isolated. | Individual ferry operators may apply additional restrictions on gas-fuelled vehicles in enclosed vehicle decks; confirm with the specific operator. |
| Hydrogen fuel cell — UN 3166 |
|
Accepted on the same basis as gas-fuelled vehicles; ventilation of the vehicle deck is the primary operational control. | Treated with the same caution as other gas-fuelled vehicles; falls within the same enhanced detection and ventilation requirements as the rest of the vehicle deck. |
| Wet-cell (lead-acid) / sodium-metal / sodium-alloy battery — UN 3171 |
|
Accepted under the same short-circuit protection condition, with no separate SoC requirement. | Same short-circuit protection condition; ferries treat this chemistry no differently from ICE vehicles. |
| Lithium-ion / lithium-metal BEV or PHEV — UN 3556 / UN 3557 |
|
Accepted at a maximum state of charge of 50% (Wallenius Wilhelmsen/EUKOR; up to 70% with prior notice), UN 38.3-tested, and passed through a pre-delivery inspection for damage and function before loading. | Same SoC and inspection principles as RoRo/PCTC, applied under a stricter fire-safety envelope: enhanced smoke/heat detection, continuous video monitoring, and fixed water-based extinguishing on weather vehicle decks (IMO SOLAS amendments, see Table 5). Individual RoPax operators can set a tighter cap than the general range — Grimaldi, for example, applies 40% on some routes (see Table 4). |
| Sodium-ion battery — UN 3558 |
|
Same short-circuit exemption applies. Carrier SoC policy for this newer chemistry hasn’t matured yet — check directly with the line before booking. | Same exemption route applies here too, though RoPax operators haven’t settled a distinct policy for sodium-ion as a rule. |
TakeawayContainer vessels see the most restrictive treatment of the three, for a structural reason: the SP 961.1 location exemption requires stowage in a vehicle, special-category or approved Ro-Ro/weather-deck space, and a container cargo space on a Ro-Ro ship is expressly excluded from that exemption. A lithium-ion or lithium-metal vehicle packed in a CTU is therefore always Class 9, regardless of how the battery is prepared. RoRo and RoPax carriage can still qualify for the SP 961 exemption, provided the vehicle and its paperwork meet its conditions.
2. ECG — The Association of European Vehicle Logistics
| Aspect | ECG Position |
|---|---|
| Scope | Covers European finished-vehicle logistics — RoRo/PCTC and short-sea trades — rather than container shipping specifically. |
| State of charge | Surveys and publishes the SoC values individual OEMs and shipping lines apply to BEVs leaving European factories, following EMSA’s 20%-50% recommendation. |
| Status | An industry reference survey, not a binding rule — published for general information; ECG advises confirming current figures with each carrier or OEM directly. |
| Source | ECG – Association of European Vehicle Logistics – EV SoC Requirements |
3. EMSA — European Maritime Safety Agency
| Aspect | EMSA Position |
|---|---|
| Guidance covered | Guidance for Alternative Fuel Vehicles (AFVs) in Ro-Ro Spaces, with separate chapters for RoPax (Ch. 1, 2 + Annexes) and RoRo/PCTC (Ch. 1, 3 + Annexes). |
| State of charge | Recommends a 20% floor to 50% ceiling SoC window for vehicles carried on ro-ro cargo ships and vehicle carriers; SoC below roughly 30% is noted to make thermal runaway unlikely. This is an EMSA recommendation, not an IMO requirement — individual carriers set their own figure, and some run tighter than the general range (see Table 4 for examples such as Grimaldi’s 40% cap). |
| Underpins | EMSA’s FIRESAFE research (2016–2018) fed into the IMO’s 2026 SOLAS fire-safety amendments for Ro-Ro and passenger vehicle spaces (see Table 5). EMSA’s follow-on STARRS study — its first technical/regulatory review published January 2026 — is now feeding further findings into IMO’s ongoing work on new-energy-vehicle fire risk. |
| Status | Advisory guidance addressed to flag/port States and operators, not a mandatory IMO instrument in itself — though widely adopted commercially. Still references the pre-Amendment-42-24 UN 3171 entry for EVs rather than the newer UN 3556/3557/3558 split. |
| Source | EMSA – European Maritime Safety Agency – Guidance for Alternative Fuel Vehicles in Ro-Ro Spaces |
4. Other Carrier, Flag & Class Society Policy
| Body | Vessel Type Covered | Key Policy Points | Source |
|---|---|---|---|
| Europe | |||
| Brittany Ferries | RoPax ferries (UK–France–Spain) | Press coverage describes EVs being marked with a windscreen sticker at boarding, for deck placement, and no onboard charging on offer — neither detail confirmed on Brittany Ferries’ own site, which publishes no SoC or AFV policy of its own. | Press reporting only – The Connexion |
| Caledonian MacBrayne (CalMac) | RoPax ferries (Scotland, UK) | Secondary reporting groups CalMac with the operators that bar onboard EV charging. Nothing on CalMac’s own site sets out an SoC or AFV policy beyond that. | Press/aggregator reporting only – Ferry Schedule Hub |
| CMA CGM | Container vessels | All EV/HEV declared as DG regardless of SP 961/971 eligibility; signed LOI required; SoC adjusted by shipper for the voyage (no fixed % published); on-deck-only stowage, 6 m DG separation, no block stow; 7-year vehicle age limit. | CMA CGM – Loading Electric and Hybrid Cars |
| Color Line | RoPax ferries (Norway–Denmark/Germany) | One of the Northern European “green ferry” operators reported to offer bookable onboard EV charging on select routes — Color Line just hasn’t paired that with a published SoC or AFV policy of its own. | Press/aggregator reporting only – Ferry Schedule Hub |
| DFDS | RoPax ferries (English Channel, North Sea, Baltic) | A 2010 car-deck battery fire drew press coverage suggesting DFDS doesn’t allow onboard EV charging — never confirmed on the company’s own site, which also has no published SoC or AFV policy. Worth checking directly before booking. | Press reporting only – The Connexion |
| Fjord Line | RoPax ferries (Norway–Denmark) | Its high-speed Norway–Denmark service is credited in secondary reporting with bookable onboard EV charging bays, though Fjord Line has no formal SoC or AFV policy of its own to go with it. | Press/aggregator reporting only – Ferry Schedule Hub |
| Grimaldi Group / Grimaldi Lines | RoPax ferries (Mediterranean / Adriatic) | Publishes its own SoC limit: pure electric or rechargeable hybrid vehicles must not exceed 40% state of charge at boarding — stricter than the general 20%-50% industry range used elsewhere in this article. LPG/CNG-fuelled vehicles must not exceed 50% tank capacity. Any AFV with a fault in the fuel system, tank or battery is refused unless the fault is removed. This traces to a Greek Ministry of Maritime Affairs and Island Policy circular (2070.0/28541/2024) on AFV carriage, which Grimaldi applies on affected Greek routes (e.g. Brindisi–Igoumenitsa, Brindisi–Corfu). | Grimaldi Lines – Instructions for Passengers with AFVs |
| Maersk | Container vessels | The old generic UN 3171 entry is no longer accepted for lithium- or sodium-ion vehicles; shipments must use UN 3556, 3557 or 3558 as applicable. Maersk recommends placarding SP 962 containers on all four sides, rather than the standard two, to account for varying port interpretations — verify before gate-in. | Maersk – IMDG Code 42-24: Battery Vehicle Changes (Jan 2026) |
| P&O Ferries | RoPax ferries (English Channel, UK–Europe) | Grouped by secondary sources with the Channel and Mediterranean operators that prohibit charging electric devices on the vehicle deck. P&O Ferries has published nothing of its own on SoC or AFV handling. | Press/aggregator reporting only – Ferry Schedule Hub |
| Stena Line | RoPax ferries (North Sea, Irish Sea, Baltic) | Stena Line sits at the other end of the spectrum: a company spokesperson has publicly said it applies no additional SoC or boarding restrictions beyond IMDG Code standard compliance, while continuing to track lithium-ion battery safety research. That’s a reported statement, not a published policy page. | Press reporting only – The Irish Times |
| TT-Line (Travemünde–Trelleborg) | RoPax “green ferries” (Germany–Sweden) | An outlier among the “no published policy” entries here: TT-Line’s Green Ships reportedly carry around 32 bookable onboard EV charging points, reserved at booking — yet the line has no formal SoC or AFV policy to match. (Distinct from TT-Line Company of Australia, below — same name, unrelated business.) | Press/aggregator reporting only – Ferry Schedule Hub |
| UECC | RoRo vessels (Northern European short-sea) | Specifies a minimum 20% and maximum 50% SoC for HV traction batteries during marine carriage; vehicles set to “transport mode” must retain enough charge for basic functions. | UECC – Electric Vehicle Guideline v1 |
| UK MCA — MGN 653(M) | RoPax ferries (UK-flagged / UK-trading) | UK Maritime & Coastguard Agency guidance focused on RoPax EV fire safety, applicable in practice to RoRo and PCTC as well. | UK MCA – MGN 653 (M), Amendment 1 |
| East Asia | |||
| Bohai Ferry Group | RoPax ferries (Bohai Gulf, China) | Research context, not carrier policy: a published Bayesian-network study has modelled EV fire risk specifically for Bohai Gulf RoPax routes, evidence of how much EV traffic already moves through this corridor. The study should not be read as a statement of Bohai Ferry Group’s own carriage policy, which hasn’t been located separately. | Academic research only – ScienceDirect |
| Hankyu Ferry (Kobe–Shinmoji/Izumiotsu, Japan) | RoPax ferry (Japan domestic) | Suspends acceptance of unmanned (unaccompanied) EV transport — cars, trucks and buses, new or used — from 1 July 2025, citing overseas ship-fire incidents and firefighting difficulty as the stated reason. PHEV and HV are explicitly excluded from the suspension and continue to be accepted; EVs travelling with their driver aboard aren’t covered by it either. | Hankyu Ferry – EV Unmanned Transport Notice (Japanese) |
| Shin Nihonkai Ferry (Japan Sea coast routes) | RoPax ferry (Japan domestic) | Suspended acceptance of unmanned EV transport from 1 January 2024, citing a need for additional transport verification. No published restriction on EVs travelling with their driver aboard. | Shin Nihonkai Ferry – EV Unmanned Transport Notice (Japanese) |
| MOL’s Sunflower (Osaka–Beppu, Osaka–Shibushi) | RoPax ferry (Japan domestic) | Runs a fully reservation-based onboard EV charging service on these routes — a commercial amenity rather than an SoC or acceptance restriction. ClassNK, Japan’s national classification society, separately publishes general EV maritime transport safety guidance that operators can draw on. | Ferry Sunflower – EV Charger Reservation Notice (Japanese) |
| PanStar | RoPax ferry (Korea–Japan) | No dedicated EV/AFV carriage policy was located on PanStar’s public English-language site during this review — that’s a search finding, not confirmation that no internal or route-specific requirement exists. | PanStar – company site (no AFV policy page found) |
| Wallenius Wilhelmsen / EUKOR | RoRo vessels / PCTC | Max 50% SoC (up to 70% with prior notice); UN 38.3-tested batteries; Alternative Fuel Vehicle questionnaire at booking; pre-delivery inspection for damage, function and charge level; damaged or defective batteries not accepted for loading. | EUKOR – Electric Vehicles 101 FAQ |
| Oceania | |||
| Interislander (KiwiRail, New Zealand) | RoPax ferry (Cook Strait, New Zealand) | Plug-in vehicles must avoid rapid/fast charging for at least 2 hours before check-in; no onboard charging facilities exist. Modified or collision-damaged EVs may not be carried. Hydrogen vehicles are carried in the open air to prevent gas build-up. Notably, the stricter rule sometimes cited for New Zealand — under-30% SoC and dangerous-goods declaration — applies only to commercial car-transporter operators, not private passenger vehicles. | Interislander – Alternatively Fuelled Vehicles |
| Spirit of Tasmania (TT-Line Company, Australia) | RoPax ferry (Bass Strait, Australia) | No onboard charging permitted. Vehicle must carry sufficient charge to embark and disembark (no fixed % published). EVs are loaded into dedicated areas, inspected and marked as EVs at boarding, and the company reserves the right to refuse vehicles showing battery warning lights, active recalls, or collision damage. | Spirit of Tasmania – Electric Vehicles Terms |
Reading this table“No published policy” is not the same as “no restrictions.” A carrier with nothing on its website can still refuse a vehicle at the ramp for reasons that never made it into a policy page. Call before you book.
5. IMO’s Own Amendments — In Force and Upcoming
| Instrument | What It Covers | Applies To | Timeline |
|---|---|---|---|
| IMDG Code Amendment 42-24 — MSC.556(108) | The 2024 Edition of the IMDG Code, including the new UN 3556 (lithium-ion), UN 3557 (lithium-metal) and UN 3558 (sodium-ion) vehicle entries alongside the existing UN 3166 and UN 3171 entries. | All vessel types carrying packaged/classified dangerous goods vehicles | IN FORCE Voluntary from 1 Jan 2025; entered into force 1 Jan 2026 |
| IMDG Code Amendment 43-26 — MSC.587(111) | Adopted at MSC 111 in May 2026. Tightens the vehicle entries further by ruling out shipment of any vehicle presenting visible leakage from its battery, engine, fuel cell, gas cylinder, accumulator, fuel system or braking system; visible damage to electrical wiring or equipment; damage to airbags, seatbelt tensioners or other supplemental restraint systems; or a history of exposure to severe events such as flooding, storm damage, fire or submersion. A pre-shipment condition check becomes part of the classification criteria itself, not just good practice. | Vehicle entries (UN 3166 / 3171 / 3556 / 3557 / 3558) across all vessel types | ADOPTED, NOT YET IN FORCE Voluntary from 1 Jan 2027; mandatory from 1 Jan 2028 |
| SOLAS II-2/7 & 20 and FSS Code Ch. 7 & 9 — MSC.550(108) & MSC.555(108) | Individually addressable smoke/heat detection (incl. linear heat detectors), fixed water-based extinguishing on weather vehicle decks and continuous video monitoring for vehicle, special category and Ro-Ro spaces — concentrated on Ro-Ro passenger ships, the FIRESAFE study’s original focus. Cargo RoRo ships and PCTCs get a narrower slice of the same package: added detection and alarm coverage for control stations and cargo control rooms, not the full passenger-ship suite. | Ro-Ro passenger ships (RoPax) primarily; cargo RoRo ships and PCTCs for the control-station detection provisions | IN FORCE New ships: in force 1 Jan 2026. Existing ships: compliance by first survey after 1 Jan 2028 |
| New-energy-vehicle fire safety framework — under development by IMO’s Sub-Committee on Ship Systems and Equipment (SSE) | A dedicated evaluation of fire protection, detection and extinction arrangements in vehicle, special category and Ro-Ro spaces, specifically to address new-energy vehicles including BEVs. Roadmap and goal-based approach agreed at SSE 10 (March 2024), continued at SSE 11 (February 2025), and still in progress as of SSE 12 (March 2026) via an intersessional Fire Protection Correspondence Group. No draft SOLAS text has been issued yet. | RoPax, RoRo and PCTC vessels | NOT YET ADOPTED No adopted instrument or confirmed entry-into-force date. IMO’s own sub-committee has described this as long-term work, potentially aligning with a future SOLAS amendment cycle — treat any specific year quoted elsewhere in the industry press as unconfirmed until IMO publishes draft amendment text. |
Amendment 43-26 is adopted but not yet in force, and the new-energy-vehicle fire safety framework hasn’t been adopted at all — both shown for forward-planning purposes alongside the confirmed, in-force items above them. Two general containership/bulk carrier measures from the same 1 January 2026 SOLAS package — mandatory electronic inclinometers and lost-container reporting — are not shown here as they are not specific to vehicle carriage decisions. Mark 1 January 2027 and 1 January 2028 against your own fleet or booking calendar now: those are the dates Amendment 43-26’s damage and history checks move from voluntary to mandatory.
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