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Regulatory update

Mandatory Reporting of Containers Lost at Sea (SOLAS 2026)

Reporting containers lost or observed drifting connects the event, recipients and available data with a timely message. From 1 January 2026 SOLAS V/31–32 distinguishes loss and observation: a loss also requires follow-up information, safe verification and a final report.

SOLAS Chapter Vcontainers lost at seaRes. MSC.550(108)danger message

Operational Explanation

First identify whether your own ship has lost containers or has observed containers drifting. Prepare the relevant message with UTC, identity, position and available information, clearly distinguishing estimates and unavailable data. Express position in latitude and longitude or, where possible, true bearing and distance in nautical miles from a clearly identified landmark. For a loss, additional information feeds follow-up messages and safe verification of the number or estimate leads to the final message; an exact count is not a prerequisite for initial reporting.

MSC.550(108) introduced two distinct duties. For a loss, the Master informs ships in the vicinity, nearest coastal State and flag State; for an observation, ships in the vicinity and nearest coastal State. Regulation 32 gives each message its own fields and gives a loss an initial/update/final sequence.

Regulatory Reference

MSC.550(108) — SOLAS V/31–32, in force from 1 January 2026. The Company assumes duties to the fullest extent possible for an abandoned ship or an incomplete/unobtainable report. The flag State reports the loss to IMO: direct submission to IMO does not replace the Master’s required recipients.

MEPC.384(81) — MARPOL Protocol I, Article V(3) aligns the report required by Article II(1)(b) for container loss with SOLAS danger messages.

Scope of Application

Within SOLAS chapter V’s scope, LOSS concerns the ship involved in losing freight containers; OBSERVATION concerns a ship observing them drifting at sea. Reporting is not limited to containers with dangerous goods, loaded containers or a particular cause of loss; LOSS also calls for the number or estimated number of empty containers as far as available and practicable. Use applicable communication channels and contacts, checking relevant instructions without assuming one national form applies everywhere.

Procedure / How to Complete It

LOSS — initial/update/final

  1. Without delay and to the fullest extent possible inform ships in the vicinity, nearest coastal State and flag State.
  2. State report type; UTC/date; ship identity; sender/representative; recipients; chronological message number for updates.
  3. Report the ship’s position at loss; if unknown, the estimated loss position; if that cannot be determined, the position on discovery; total or estimated number; dangerous-goods status and UN number if known; dimensions/type and empty estimate as available.
  4. Send additional information at the earliest opportunity. At the earliest safe and practicable opportunity verify by inspection the number or estimated number and send the same recipients a report marked final.
  5. The Company assumes the obligations to the fullest extent possible only if the ship is abandoned or the report is incomplete or unobtainable.

OBSERVATION

  1. Without delay and to the fullest extent possible inform ships in the vicinity and nearest coastal State; Regulation 31 does not add the flag State as recipient of this report.
  2. State report type, UTC/date, ship identity, Master as sender, recipient and UTC/date/position of observation.
  3. Report number observed and, if available, dimensions/type, cargo spill, wind, current, drift, sea state and wave height.

Practical Example

LOSS: the ship immediately reports an estimated 12 containers, assigns the message number and includes dangerous-goods status and available data; after a safe inspection it confirms 10 in the final report to the same recipients. OBSERVATION: another ship tells the nearest coastal State and nearby ships the position, UTC and three containers observed, adding available drift and weather.

What Typically Goes Wrong

Using the same procedure and recipients for loss and observation, omitting update/final and verified number or estimate, or triggering Company fallback generically whenever the Master cannot communicate.

Common Mistakes Mistake Library

MistakeConsequenceHow to Avoid It
Observation automatically sent to flag State as SOLAS dutyRecipients for the two events are confusedUse nearest coastal State and ships in vicinity for observation
Loss report limited to position and numberPrescribed fields and updates are missingUse initial/update/final model with message number
Company fallback generalisedCompany role exceeds Regulation 31Apply only for abandoned ship or incomplete/unobtainable report

What the PSCO Checks

As a practical readiness check, verify that personnel can distinguish LOSS and OBSERVATION, find the contacts and complete the relevant regulation 32 fields while retaining messages and times. For a loss, check update numbering and the final report with the verified number or estimate. This supports onboard preparation: the actual PSC inspection scope depends on applicable requirements and circumstances, rather than a universal list predetermined here.

Operational Tips

Preparation checklist

FAQ

Do loss and observation use the same procedure?
No. They have distinct recipients and fields; only loss includes the flag State as a SOLAS recipient and uses updates/final with verified number or estimate.
When does the Company step in?
If the ship is abandoned or the report is incomplete or unobtainable, assuming the duties to the fullest extent possible.
Are position and number enough?
No. Regulation 32 prescribes further loss fields and a distinct observation set.

Related Topics

Certified substantive revision: 16 October 2026 · page fingerprint d946d35f8d73