CCC 12: A Hidden Battery Fire Gap, and Nine New Bulk Cargoes Coming

What CCC 12 Is

CCC is the IMO sub-committee responsible for cargo and container safety — the IMSBC and IMDG Codes, the CTU Code, cargo securing standards, and the safety guidelines governing alternative marine fuels. Nothing that came out of this session takes effect immediately; everything below is draft work, at various stages of approval, with the earliest changes reaching voluntary application in 2027–2028. But two items are worth knowing about now, well before they become mandatory.

The One Genuine Safety Gap Still Open

Buried in the IMDG Code discussion is a real, currently-unaddressed hazard: SP188, the provision exempting small lithium and sodium batteries from most dangerous goods requirements. Individually, a small battery is low risk. But SP188 allows large quantities to be consolidated within a single cargo transport unit with no dangerous goods documentation, no placarding, and no carrier awareness that a container is carrying, in aggregate, a serious fire hazard. This isn't a new proposal being finalised — it's a gap CCC 12 flagged and is still inviting draft amendments on. Worth watching, not yet worth changing your practice around.

New Bulk Cargo Schedules Coming

IMSBC Code Amendment 09-27 adds nine new cargo schedules — including untreated incinerator bottom ash (classified both flammable-gas-when-wet and toxic), contaminated soil (hydrocarbons/PFAS/asbestos/heavy metals), and several liquefaction-risk materials. Expected voluntary from 1 January 2028, mandatory from 1 January 2029. If your trade touches bulk cargo, these are worth knowing before they're compulsory, not after.