Shipping Electric Vehicles by Sea: UN 3556, RoRo and Container Rules

An electric or plug-in hybrid car shipped by sea is a Class 9 dangerous goods item under the IMDG Code unless a specific exemption applies, and since 1 January 2026 the correct entry for a lithium-ion vehicle is UN 3556, not the old UN 3171. Whether the exemption applies depends mostly on how the car is stowed: on a RoRo deck it can be exempt, while in a container it is declared and handled as dangerous goods. State-of-charge limits, battery condition and paperwork are set by the carrier, so confirm them before you book. This guide covers both routes and the documents, destination rules and insurance questions that come with them. For the general RoRo-versus-box decision, read our RoRo vs container shipping guide for vehicles and machinery. Everything here is as of November 2026.

Is an electric car dangerous goods at sea?

Lithium-ion batteries are dangerous goods under the IMDG Code, and a vehicle powered by one is carried under a vehicle entry, not as a battery. Two special provisions decide what that means in practice. Special Provision 961 can exempt a vehicle from almost all of the Code if the vehicle meets its conditions. If none are met, Special Provision 962 applies, and the vehicle is Class 9 with a lighter set of requirements.

The detail matters, and I could only read the Code's wording through secondary summaries (a carrier notice, a law firm article and a consultancy summary), not the Code itself. Those summaries agree on the main points: the 961.1 exemption applies to vehicles stowed in a dedicated vehicle, special category or RoRo space (or on a ship's weather deck) with no visible leaks, and it does not carry over to a vehicle inside a container on a ship. The law firm Hill Dickinson (article dated 26 February 2024) says electric vehicles in container slots on RoRo ships, and electric vehicles on container ships, must be declared as dangerous goods. Confirm the exact text in the current IMDG Code, or ask the carrier which route your booking falls under.

A common misconception is that electric cars cannot be shipped. They are carried on car carriers; the restrictions are about condition, charge level, stowage and declaration.

UN 3171, UN 3556, UN 3557 and UN 3558: what changed in 2026

IMDG Code Amendment 42-24 became mandatory on 1 January 2026. Maersk's advisory of 6 January 2026 states that the generic entry UN 3171, "Battery-powered vehicle", is no longer permitted for lithium-ion or sodium-ion powered vehicles, and that shipments must be declared with the entries below. Arkas Line's regulatory update says the same and adds that UN 3171 remains valid only for vehicles powered by wet cell batteries, sodium metal or sodium alloy batteries.

Hybrids are the grey area. Carrier handling instructions refer to both battery electric vehicles and plug-in hybrids, but I could not confirm from a primary source which entry applies to a vehicle with both a combustion engine and a lithium battery. Ask the carrier how it wants a hybrid declared rather than guessing. Older booking templates and forwarder systems that still default to UN 3171 are an obvious source of rejected bookings. For the wider declaration process, see our dangerous goods declaration guide and the overview of IMDG Code and IATA regulations.

RoRo or container for an electric car?

RoRo is the usual route for a car that drives on and off. A car carrier stows vehicles in decked spaces, so the car can be exempt under Special Provision 961 if its conditions are met, and there is no lashing or packing cost beyond the freight. Some carriers do not accept used vehicles inside containers at all: Wallenius Wilhelmsen's used-unit shipping guidelines say used vehicles stowed in containers, trailers or trucks are not accepted, with an exception only where the unit has enough openings for ventilation and safe lashing. That is one carrier's rule, so check the one you are booking.

A container is the route when the car is going to a port that RoRo lines do not serve, when you want to ship other goods with it, or when you want a closed box for security. Then the car is declared under its UN number as Class 9, the booking is a dangerous goods booking and the carrier must accept dangerous goods on that sailing. Expect fewer sailings and, usually, a higher cost than RoRo for a single car. Our lithium battery shipping guide covers the battery rules that sit alongside the vehicle entries.

State of charge: what the carriers actually say

There is no single figure. The widely repeated 30 per cent is the number I could least trace: in what I checked it came from air cargo guidance, not from the IMDG Code or an ocean carrier notice. For sea transport the limit is a carrier and manufacturer matter, and it changes.

• Wallenius Wilhelmsen's cargo handling instructions (page dated 3 November 2026) apply a state-of-charge requirement to battery electric and plug-in hybrid vehicles, run random checks at export ports, and refuse loading if a vehicle is above the limit in its table. The table is an image on the page, so I could not read the percentages.
• Its used-unit shipping guidelines say electric vehicles should be charged below 70 per cent, and that used electric vehicles need a certificate that they have not been in a crash and may be carried only if the battery shows no sign of leakage and is protected from short-circuiting. Other Wallenius Wilhelmsen pages I saw quote different figures, so do not rely on a number from a summary.
• The same carrier says it prohibits charging high-voltage batteries on board during the voyage. Its December 2023 article says the threshold is set by the vehicle manufacturer.

Practical rule: get the maximum and minimum state of charge in writing from the carrier for your vehicle and sailing, check the dashboard reading at hand-over, and keep a photo of it. A car left standing loses charge slowly, so ask whether a minimum applies as well as a maximum.

Packing an electric car in a container

If the car goes in a box, the packing is part of the compliance. The Arkas Line and Maersk notices I read describe the following for Special Provision 962 vehicles:

• No leakage from the vehicle, engine, battery or fuel system.
• For a hybrid or any fuelled vehicle, fuel not more than a quarter of a tank and not more than 250 litres unless the competent authority allows more; gas shut-off valves closed.
• Batteries protected against damage, short-circuit and accidental activation. In practice that usually means disconnecting or isolating the 12V battery as the manufacturer and carrier instruct, and securing charge-port covers. Ask the carrier what isolation it expects, because the notices I read do not standardise it.
• The car lashed to the container's securing points with wheel chocks and straps rated for the load, as in our guide to dunnage, lashing and bracing. A heavy battery vehicle changes the weight distribution, so confirm the axle and floor loading with the packer.
• A container packing certificate from whoever packs the box, plus the dangerous goods declaration. Our segregation and stowage guide explains why any other cargo in the same box needs checking.
• Placarding. Arkas Line says no label is needed in an open container where the vehicle is visible, but Class 9 labels are required on a closed container, on all four sides. Maersk recommends all four sides for SP 962 containers because ports interpret the rule differently. Label four sides unless the carrier tells you otherwise.

What the IMO has and has not done about EV fires

People expect a specific IMO rule on lithium-ion vehicle fires. As far as I could confirm in November 2026, there is no mandatory IMO requirement written specifically for carrying battery electric vehicles. What exists:

• MSC.1/Circ.1615 (June 2019) gives interim guidelines on minimising fires in RoRo spaces. It is not an electric vehicle circular, and UK Maritime and Coastguard Agency guidance describes its contents as not mandatory.
• At its tenth session in March 2024 the IMO Sub-Committee on Ship Systems and Equipment endorsed a roadmap and a goal-based approach for fire safety on ships carrying new energy vehicles, including battery electric vehicles. This is IMO's own meeting summary.
• Trade reporting on the twelfth session says the work continues in a correspondence group reporting to the March 2027 session, with interim guidelines for car carriers prioritised, and that any agreed SOLAS amendments would take effect on 1 January 2032 at the earliest.

For incidents, treat the headlines carefully. The Fremantle Highway caught fire off the Dutch coast on 25 July 2023, and one crew member died. The Dutch Safety Board's report concentrated on the emergency response, not on the cause. The cause of the Felicity Ace fire in February 2022 has not been publicly established, and the flag-state report was reported as not released. Neither case is a public finding that an electric vehicle started the fire. The concern behind carrier limits is that a battery fire is hard to extinguish and can reignite, so carriers control charge, condition and stowage.

Documents for exporting an electric or hybrid car

The vehicle paperwork is separate from the dangerous goods paperwork. A typical set:

• Ocean bill of lading, with the vehicle's make, model, year and 17-character VIN, and the UN number if declared as dangerous goods.
• Original title or registration, and proof of ownership, plus a lienholder's written consent if the car is financed.
• Commercial invoice or bill of sale, and the destination's import documents, such as a roadworthiness certificate where required.
• Dangerous goods declaration and container packing certificate if the car goes in a box.

From the United States, 19 CFR Part 192 applies to used self-propelled vehicles. Under section 192.2, for export by vessel the vehicle and its documents must be presented to CBP at least 72 hours before export. The documents are the original title or a certified copy plus two copies for a US-titled vehicle, proof of ownership for a foreign-titled one, or the Manufacturer's Statement of Origin for a new vehicle, along with the VIN. A vehicle with a lienholder needs a separate signed writing from that party allowing export. Read the rule on eCFR before relying on this summary, and see our AES and EEI guide for the export filing, which has its own timing rule.

Destination rules: duty, age limits and right-hand drive

Many importing countries restrict used cars, and the rules differ for electric ones. These examples come from government pages, and each needs checking against the current version before you ship.

• Kenya. The Kenya Revenue Authority's motor vehicle procedure page says a vehicle must be less than 8 years old from the year of first registration, must be right-hand drive, and is subject to a roadworthiness inspection by a Kenya Bureau of Standards appointed agent in the country of export. It lists import duty of 25 per cent, VAT of 16 per cent and an excise duty that ranges from 10 per cent for electric-only vehicles to 35 per cent for larger engines, among other charges on the customs value.
• Australia. The Department of Infrastructure runs separate approval routes, including a specialist and enthusiast vehicles scheme and a route for vehicles more than 25 years old. Its guidance on left-hand-drive vehicles differs between its April 2024 and November 2025 guides, so read the current guide, not a forum post.

The lesson is the same everywhere: age, steering side, approval and duty are decided at the destination, and a shipment that arrives non-compliant can be held, re-exported or refused. Check them before you pay for the freight, and see our guide on shipping used machinery and equipment internationally for the general used-goods checks.

Insurance for an electric vehicle at sea

Carrier liability is limited, and under the Hague-Visby Rules a carrier is generally not responsible for a fire unless it was caused by the carrier's own actual fault or privity, so the owner needs their own cover. Hill Dickinson notes that a cargo policy covering only fortuitous losses may be argued not to respond where a loss stems from a known risk such as a lithium-ion battery, and that cargo policies may exclude third-party liabilities. It also notes that under Article IV Rule 6 of the Hague-Visby Rules a shipper of undeclared dangerous goods can be strictly liable to the carrier for the resulting loss. Practical steps: tell the insurer it is an electric vehicle and how it is shipped (RoRo or container), ask in writing whether the policy covers fire and battery-related loss, and declare the vehicle correctly to the carrier. Our guides on cargo insurance and what cargo insurance does not cover explain the usual gaps.

What to do next

1. Ask two or three carriers or forwarders for quotes that state RoRo versus container, the UN number they will use and their written state-of-charge limit.
2. Confirm the destination's age, steering-side, inspection and duty rules with its customs or transport authority before you pay for freight.
3. Assemble the title, VIN, ownership and lienholder documents, and file the export declaration on time.
4. Tell your insurer it is an electric vehicle, confirm cover in writing, then book.

To find a forwarder that handles vehicle shipments, search the CargoLinked directory, where more than 29,300 logistics companies are searchable by country and service. If you would rather have forwarders quote you, post the shipment on the requests board, which lists freight that shippers have posted for forwarders to quote on directly.

This guide is general information as of November 2026, not legal, customs or dangerous goods advice. Rules and carrier limits change; confirm the current requirements with the carrier, the competent authority and the importing country's customs before you ship.