IN Brief:
- CMA CGM requires lithium-ion battery cargo from India to be declared at booking or before container loading regardless of dangerous goods status.
- The requirement includes qualifying batteries moved under Special Provision 188 and can require MSDS, UN 38.3 or compliance documentation.
- Undeclared lithium-ion battery containers can be treated as dangerous goods misdeclarations and attract a $15,000 penalty per container.
CMA CGM has reinforced its declaration requirements for lithium-ion battery cargo moving from India, requiring customers to identify relevant batteries before loading even when the shipment qualifies for reduced treatment under Special Provision 188. The declaration regime has been in place since July, while the latest instruction reiterates the documentation, approval and enforcement process for Indian exports.
All cargo containing lithium-ion cells or batteries related to UN 3480 must be declared at booking or before the container is loaded, regardless of dangerous goods status, watt-hour rating, lithium content or an applicable IMDG exemption. Special Provision 188 allows qualifying smaller cells and batteries to move outside many of the full dangerous goods provisions when prescribed conditions are met, but the underlying fire risk and packaging requirements remain.
Lithium-ion cells can enter thermal runaway after internal failure, mechanical damage, overheating or an electrical short circuit. Once heat generated inside a cell begins accelerating further chemical reactions, temperatures can rise enough to affect neighbouring cells or surrounding combustible material, and an enclosed container can make the resulting incident harder for a vessel crew to access and manage at sea.
CMA CGM is therefore applying its own acceptance controls alongside the regulatory classification. A shipment may qualify for SP188 while still having to be visible to the carrier before it reaches the terminal, allowing the booking to pass through the appropriate cargo approval process and giving operational teams accurate information about what is inside the container.
Customers must tell the booking agent that lithium-ion batteries are present and complete the carrier’s questionnaire, with supporting material potentially including a recent material safety data sheet, a UN 38.3 test record or documentation showing compliance with the relevant special provision. UN 38.3 testing subjects cells and batteries to a defined series of transport tests covering altitude, thermal cycling, vibration, shock, external short circuit, impact or crush, overcharge and forced discharge, establishing whether the design meets prescribed transport requirements.
Those tests address the design of the cell or battery before it enters normal transport, while the condition of the individual shipment still matters. A product that has passed the required test regime can be damaged later through poor handling, defective packaging or an electrical fault, which is why declaration, packaging and securing controls continue to apply after the design has been approved.
Cells and batteries moving under SP188 must therefore be placed in inner packaging, protected against short circuits and enclosed in strong outer packaging, while the loaded cargo must also comply with the CTU Code for bedding, blocking, bracing, lashing and securing. A correctly classified battery can still be damaged if its load shifts during terminal handling or vessel movement, so safe carriage depends on both the product and the way the complete consignment is packed.
Where a container includes batteries regulated as dangerous goods alongside batteries moving under SP188, CMA CGM requires separate approvals for the two categories. Customers must receive approval before gate in, moving the control point upstream of the terminal and allowing classification or documentation issues to be resolved before the container enters the loading system.
Resolving those issues during booking avoids some of the operational disruption that follows when an incorrect declaration is discovered at the terminal. A box already at the gate or inside the yard may require additional holds, document checks and physical handling, while a problem identified earlier can be corrected before transport to the port begins.
CMA CGM may also carry out random document inspections, and an undeclared lithium-ion battery container can be treated as a dangerous goods misdeclaration with a $15,000 penalty per box alongside any other costs or liabilities arising under the carrier’s conditions of carriage. Emergency response, stowage decisions and handling procedures can all depend on knowing that batteries are present, giving incomplete cargo information consequences beyond the documentation error itself.
Lithium-ion cells now move through ocean supply chains in many forms, including standalone batteries, units packed with equipment and cells installed inside machinery or consumer products. Those configurations create different documentation and packaging requirements even when the underlying chemistry is similar, increasing the risk of a battery shipment being treated as ordinary cargo by a shipper unfamiliar with the rules.
Even where SP188 reduces the dangerous goods provisions applying to qualifying cells and batteries, CMA CGM still requires their presence to be declared so that its own acceptance controls can be applied before loading. Regulatory treatment and carrier approval therefore remain separate parts of the process rather than one automatically determining the other.
By requiring battery presence to be declared before the container reaches the gate, CMA CGM is placing visibility ahead of physical acceptance. The process leaves the IMDG framework and transport tests unchanged, but it makes carrier approval a separate requirement for Indian shipments, including qualifying SP188 cargo, so that the battery content, supporting documents and handling status are established before loading begins.
