The IMO has finalized a significant new global reporting requirement aimed at improving navigational safety, environmental protection, and container recovery efforts. With the adoption of SOLAS amendments through Resolution MSC.550(108) and parallel MARPOL Protocol I amendments through Resolution MEPC.384(81), shipowners, operators, and masters will soon face mandatory reporting obligations for containers lost at sea or observed drifting, regardless of the vessel’s type or trade.

These changes enter into force 1 January 2026 and apply to any ship carrying one or more containers and any ship that observes containers adrift, not just container vessels.

Background and Why the Change Matters

The Maritime Safety Committee’s adoption of SOLAS Chapter V amendments (MSC.550(108)) and the Marine Environment Protection Committee’s amendments to Article V of Protocol I of MARPOL (MEPC.384(81)) reflect the growing recognition that lost containers pose a serious navigational hazard, particularly for smaller craft, fishing vessels, and coastal traffic.

Beyond collision risks, drifting containers can lead to pollution, cargo release, and complex salvage challenges, especially when carrying dangerous goods.

These amendments also align the reporting requirements of SOLAS Regulations V/31 and V/32 with MARPOL’s Protocol I to ensure a unified global reporting format submitted through the Global Integrated Shipping Information System (GISIS).

For companies operating globally, this bridges a longstanding gap between safety and environmental reporting obligations and creates a standardized expectation across Flag States, coastal States, and industry stakeholders.

Who Must Report

Starting 1 January 2026, reporting is mandatory for:

• Ships that lose freight containers at sea

• Ships that observe containers drifting, even if they were not involved in the loss

This applies to all ship types, not only container vessels.

Reporting Requirements Under SOLAS V/31

1. When a Ship Loses Containers

Under SOLAS Regulation V/31, the master must report the loss without delay to:

• Ships in the vicinity

• The nearest coastal State

• The Flag State

If the ship cannot transmit these reports (e.g., abandonment), the ISM Company assumes responsibility to the fullest extent possible.

The Flag State must then report the incident into GISIS.

Reports must include:

• Ship identity, date, and time

• Position of the loss

• Verified number of containers lost

• Cargo information (dangerous or non-dangerous, UN number if known)

• Container description (type, dimensions, e.g., reefer)

• Additional available information such as wind speed, direction, or cargo spill details

An initial report may be sent if information is incomplete.

2. When a Ship Observes Drifting Containers

If a ship is not involved in the loss but observes drifting containers, the master must also report the sighting without delay to:

• Ships in the vicinity

• The nearest coastal State

Reports must include:

• Vessel identity, date, and time

• Position of observed containers

• Number of containers sighted

• Any additional information, such as container type, dimensions, weather conditions, or signs of cargo spill

Additional messaging requirements related to danger messages are found in SOLAS Regulation V/32.

Actions Shipowners and Operators Should Take Now

With the entry-into-force date approaching, companies should begin preparing:

1. Update the Safety Management System (SMS)

• Incorporate procedures for reporting container loss and drifting containers.

• Define responsibilities between ship, DPA, and company management.

• Ensure alignment with SOLAS V/31, V/32, MARPOL Protocol I Article V, and MSC.550(108)/MEPC.384(81).

2. Train Masters and Watchkeeping Officers

• Familiarize crew with reporting formats and required data points.

• Practice initial vs. final reporting workflows.

3. Review Bridge Checklists and Emergency Procedures

• Integrate container-loss reporting actions into navigation and emergency reporting checklists.

• Ensure communications equipment and protocols support timely reporting.

References

• SOLAS Convention, Chapter V, Regulations 31 & 32

• MARPOL Convention, Protocol I, Article V

• MSC.550(108) – Amendments to SOLAS Chapters II-2 and V

• MEPC.384(81) – Amendments to Protocol I of MARPOL