Lithium-Ion Cells in Containers: The New CINS Guidelines, in Plain English

Why Cells, Not Just Batteries

CINS — the shipping-line-led Cargo Incident Notification System, working with the International Group of P&I Clubs and TT Club — published new Guidelines for Shipping Lithium-ion Cells in Containers in mid-2025. The distinction in the title matters: a lithium-ion cell is the individual electrochemical unit, not the finished, protected battery pack it eventually becomes part of. As a component rather than a finished product, a cell carries higher risk in transport than a new, non-waste battery — less built-in protection, more exposure if something goes wrong.

Classification, in Brief

Lithium-ion cells and batteries are Class 9 dangerous goods, declared as UN 3480 (lithium-ion batteries) or UN 3481 (lithium-ion batteries contained in or packed with equipment). The hazards behind that classification are concrete, not theoretical: flammable electrolytes that can ignite and trigger thermal runaway, toxic gas release (including hydrogen fluoride) if they do catch fire, explosion risk from internal pressure buildup, and short-circuit risk from mishandling.

The SP188 Exemption — and Why It Doesn't Mean 'No Rules'

Small, low-energy cells and batteries can be shipped under IMDG Special Provision 188, which exempts them from the full dangerous goods declaration and placarding requirements — but SP188 comes with its own strict conditions: individual protection against short-circuit, strong rigid outer packaging, a mandatory lithium battery mark on every package, and a 1.2-metre drop test the packaging must survive undamaged. SP188 is a different compliance path, not an absence of one. CINS' guidance is explicit that shippers should still tell the shipping company when a container holds lithium-ion cells under this exemption, even though no formal Dangerous Goods Declaration is required.

Packing and Stowage, the Numbers That Matter

• Packing instruction depends on the cell's condition: P903/LP903 for new, UN38.3-tested cells; P908/LP904 for damaged or defective cells (governed by SP376); P909 for cells being disposed of or recycled (SP377); P911/LP906 for cells liable to rapidly disassemble or emit dangerous gas.
• Stowage category: new, tested cells are Category A — on deck or under deck. Damaged, defective, or disposal/recycling shipments (SP376/377) step up to Category C — on deck only. CINS' own guidance goes further and recommends on-deck stowage in every case, not just where the Code requires it.
• Physical clearances: a minimum 30cm gap between the top of the cargo and the container ceiling, 30cm from the container doors, and no direct contact between the packaging and container walls — all there to assist firefighting access and heat dissipation, not just tidy stowage.
• Positioning: CINS strongly recommends stowing lithium-ion cell containers at least two 40-foot bays clear of the accommodation block and machinery spaces — on both sides, for vessels with two accommodation islands.