CINS Li-Ion Container Guidelines Meet RoRo
The 2023 CINS lithium-ion guidelines were written for containers, but their verify-segregate-declare template fits vehicle-carrier loading almost intact.
In March 2023 the Cargo Incident Notification System, the International Group of P&I Clubs, TT Club and ICHCA published the Lithium-ion Batteries in Containers Guidelines, C-SAR 101.A. They were written for container shipping. Their core template of verifying battery condition, segregating damaged units, declaring accurately and reporting incidents maps onto the vehicle-carrier loading interface almost intact. What does not transfer is the ship-side part: stowage, detection and firefighting differ on a car deck.
What are the CINS lithium-ion guidelines?
An industry guidance document backed by most of the market that would pay for a battery fire. CINS members account for over 80% of the world's container slot capacity, and the International Group's clubs insure about 90% of ocean-going tonnage. The guidelines cover battery properties and their fire, explosion and toxicity risks, then work through classification and regulation, container packing, landside storage, ship stowage, detection and suppression, and loss prevention. Three follow-on documents were planned: regulatory compliance checklists, risk assessment and emergency response, and training.
Which parts translate to vehicle carriers?
The procedural core, because it concerns the cargo before it reaches the ship. A car carrier faces the same questions at its loading interface: is this battery in a safe condition, should it be carried at all, and does the paperwork describe what is actually being shipped?
- Condition verification before shipment, with evidence retained. For vehicles this means state of charge and visible or recorded damage, especially on used and salvage exports.
- Segregation of damaged, defective or recalled units. The IMDG Code already treats a damaged battery removed from a vehicle under strict special provisions; the guidelines' logic applies equally to a damaged battery still inside one.
- Accurate declaration. Since IMDG Amendment 42-24, lithium-battery vehicles have their own entry, UN 3556, replacing the generic UN 3171.
- Incident notification and shared learning, which the car-carrier trade still lacks in a common database.
What does not transfer to a car deck?
The ship-side controls. A container is a sealed box that can be stowed on deck, away from accommodation, and flooded or cooled as a unit; a vehicle deck is an enclosed, ventilated space where hundreds of cars sit close together and crews cannot reach an established fire. And the regulatory hook is weaker. Special Provision 961 exempts vehicles carried on a ro-ro deck from most of the IMDG Code when they meet its conditions, so the declaration that drives container controls often never reaches the ship.
What would adoption take?
Agreement on who holds the data. On a container, the shipper packs and declares the box. On a car carrier, battery information sits with the manufacturer, the dealer or the exporter, and the terminal and ship see only what is passed on. The ICS and International Group guidance on vehicle loading data already sketches a booking-to-discharge chain; applying the CINS template would mean making that chain carry battery condition as well as propulsion type and state of charge.
How RoRoSAFE helps
The CINS template brings procedure to the loading interface. Once the vehicles are aboard, the deck still needs eyes. RoRoSAFE adds per-vehicle thermal and battery-vent gas monitoring for the voyage, with tamper-evident logs that record what the procedure alone cannot: how each vehicle behaved after loading. That complements the declaration discipline the guidelines ask for.
Pilot: one deck · installed alongside the berth · no drydock · 6 months of dashboard access
Sources
- 1. CINS, International Group of P&I Clubs, TT Club and ICHCA — 'Lithium-ion Batteries in Containers Guidelines' (C-SAR 101.A), published 28 March 2023; TT Club press release 'Industry bodies unite in producing Guidelines for safe transport of Lithium-ion batteries in containers': scope, membership figures (over 80% of container slot capacity; ~90% of ocean-going tonnage) and the three planned follow-on documents.
- 2. IMO — IMDG Code Amendment 42-24, mandatory from 1 January 2026: UN 3556 for lithium-ion battery-powered vehicles; Special Provision 961 conditions for vehicles on ro-ro decks; SP 376 for damaged or defective batteries. As analysed in 'EVs Got a New UN Number — Does It Help?' and 'Can You Ship a Damaged EV Battery?'.
- 3. ICS and International Group of P&I Clubs — common guidance on vehicle loading data (declared propulsion type, recorded state of charge, OEM emergency guide). As analysed in 'What the New Vehicle Loading Guidance Requires'.
Questions, answered
What are the CINS lithium-ion battery guidelines?+
Industry guidance published on 28 March 2023 by the Cargo Incident Notification System, the International Group of P&I Clubs, TT Club and ICHCA, titled Lithium-ion Batteries in Containers Guidelines (C-SAR 101.A). It covers battery risks, classification, packing, storage, stowage, detection, suppression and loss prevention for container shipping.
Do the CINS guidelines apply to car carriers?+
Not formally, since they were written for containers. But their procedural core translates almost intact to the vehicle-carrier loading interface: verify battery condition before shipment, segregate damaged or recalled units, declare accurately (EVs now ship as UN 3556) and report incidents so the trade can learn from them.
What parts of container battery guidance don't fit a car deck?+
The ship-side controls. A container can be stowed on deck and isolated as a unit, while a vehicle deck is an enclosed, ventilated space packed with cars that crews cannot reach once a fire is established. The IMDG Code's Special Provision 961 also exempts most vehicles on ro-ro decks, so declarations often never reach the ship.
What is the main barrier to applying the CINS approach to vehicles?+
Data ownership. Battery condition sits with the manufacturer, dealer or exporter, not the carrier. The ICS and International Group vehicle loading guidance already describes a booking-to-discharge data chain; extending it to carry battery condition is what adopting the CINS template would take.
Continue the thread
What the 2025 IMDG Code Changes for RoRo
IMDG Code Amendment 42-24, mandatory 1 Jan 2026, gives EVs their own UN 3556 class and retires generic UN 3171 — changing how car carriers declare them.
The VCSF 10–15 Minute Rule & Detection Gap
The VCSF Fire Response guidance gives a master 10–15 minutes to control a vehicle fire before activating fixed systems — and the clock starts at detection.
What the New Vehicle Loading Guidance Requires
ICS/IGP&I Common Guidance sets a booking-to-discharge data chain for vehicles: declared propulsion type, recorded SOC, and an OEM emergency guide.