Since 1 January 2026, reporting containers lost at sea is a binding obligation under SOLAS Chapter V. IMO Resolution MSC.550(108) amended Regulations 31 and 32 to require the master of any ship involved in a container loss, or observing drifting containers, to report without delay to nearby ships, the nearest coastal state, and the flag state. With 576 containers lost in 2024 and a decade-long average of 1,300 per year, the IMO moved from voluntary tracking to mandatory reporting backed by port state control enforcement. Shipping companies that sign up for Marine Inspection's compliance platform can integrate these reporting obligations into their SMS with pre-configured templates and automated notification workflows.
What Regulations V/31 and V/32 Require
The amendments create two obligations: reporting when your vessel loses containers, and reporting when you observe drifting containers. Both apply to all ship types, not just container vessels. Schedule a demo to see how Marine Inspection structures both reporting paths into bridge-ready checklists.
The Reporting Chain: Step by Step
The regulation establishes a clear communication flow from bridge to IMO. Each step must be documented and timestamped for audit readiness.
SMS Updates and PSC Readiness
Every Safety Management System governing vessels that carry or may encounter containers needs specific updates. Classification societies including Lloyd's Register, ABS, and DNV have issued guidance emphasising this. PSC inspectors under Paris MoU and Tokyo MoU will verify updated procedures, bridge team knowledge, and communication equipment capability. Operators who sign up for Marine Inspection can document SMS updates digitally with a complete audit trail for ISM auditors.
| Area | Required Update | PSC Focus |
|---|---|---|
| Emergency Procedures | Container loss reporting procedure referencing SOLAS V/31 and V/32 | SMS reflects mandatory requirements |
| Bridge Orders | Drifting container observation reporting for all voyages | Pre-formatted danger message template accessible |
| Crew Training | Bridge familiarisation with V/32 data requirements and DG identification | Officers can describe reporting obligations |
| Contact Directory | Flag state and coastal state contacts for operating areas | Communication equipment operational and tested |
| Drill Programme | Container loss scenario in emergency exercises | Crew demonstrates familiarity with procedures |
| MARPOL Alignment | Protocol I updated per MEPC.384(81) for harmful substances | Environmental reporting procedures current |
Expert Review: Practical Considerations
Three implementation challenges stand out. First, "without delay" means bridge teams must send an incomplete initial report immediately. Waiting for complete data before transmitting is itself non-compliant. The IMO template from CCC.1/Circ.7 should be pre-loaded on the bridge.
Second, the observation obligation applies to all vessel types. A tanker spotting a drifting container has the same duty as a container ship, broadening SMS updates across every fleet segment.
Third, the MARPOL Protocol I amendments (MEPC.384(81)) ensure SOLAS reports satisfy MARPOL obligations for the same incident, avoiding duplication. When containers carry harmful substances, additional cargo detail is required. Sign up for Marine Inspection to configure workflows that route reports through both frameworks based on cargo classification.
Conclusion
The SOLAS 2026 amendments replaced voluntary tracking with a binding framework requiring immediate reporting, standardised data formats, and flag state GISIS uploads. Every vessel that carries or encounters containers must have updated SMS procedures, trained bridge teams, and accessible reporting templates. Walk through the compliance workflow to see how Marine Inspection integrates these requirements into digital operations with pre-configured templates, automated notifications, and audit-ready documentation.
