EV Cargo Inspection on PCTC Vessels: What the 2026 SOLAS Regulations Mean for Your Pre-Loading Documentation

Electric vehicles are arriving at your terminal in growing numbers. They are also arriving with a documentation problem that the industry has not yet solved.

New fire safety amendments to SOLAS came into force on 1 January 2026, tightening firefighting and detection requirements on ro-ro vehicle decks. They sit alongside IMO guidance on carrying alternatively powered vehicles and a marine insurance market that is rapidly re-pricing EV cargo risk. Mandatory pre-loading inspection of electric vehicles is not yet written into SOLAS — but the direction is unmistakable: the condition, state of charge, and documented inspection of EVs before loading are moving from best practice toward formal expectation, and PCTC and RoRo operators are being asked to evidence them.

This post sets out what is now in force, where the pre-loading documentation expectation is heading, and why the evidence gap is the one most likely to create liability exposure in the near term — with the window before FVL North America in April the right moment to get ahead of it.

Why EV Cargo Is a Different Risk Category

Lithium-ion battery fires on car carriers do not behave like conventional vehicle fires. Thermal runaway — the chain reaction that causes battery fires — can begin hours or days after a vehicle has been loaded. It cannot be suppressed with standard fixed firefighting systems. And on a vessel at sea, it is catastrophic.

The incidents are not hypothetical. The Felicity Ace, lost in 2022 with 3,965 Volkswagen Group vehicles aboard — including a significant number of EVs — demonstrated the scale of the exposure. Marine insurers, including IUMI, have been explicit: the risk profile of EV cargo is materially different, and the underwriting framework is adjusting accordingly.

SOLAS amendments tightening fire detection and fixed firefighting on ro-ro vehicle decks entered into force on 1 January 2026 (IMO resolutions MSC.550(108) and MSC.532(107)). Alongside them, IMO Maritime Safety Committee guidance on fire-fighting plans for alternatively powered vehicles (MSC.1/Circ.1615) and EMSA’s guidance on the safe carriage of alternative fuel vehicles in ro-ro spaces address the specific hazards of battery electric vehicle cargo. Marine insurers are moving faster still — building EV-specific expectations around vehicle condition, state of charge, and pre-loading evidence into their underwriting.

The direction of travel is clear: pre-loading documentation is no longer optional best practice. It is moving toward a formal compliance requirement.

What the Regulations Mean in Practice

The specific obligations vary by flag state and vessel class, but the emerging standard across IMO guidance and major flag state interpretations requires operators to capture and retain the following for each EV loaded:

State of charge at loading

IMO guidance recommends EVs are loaded with battery charge at or below 50%, as elevated charge increases thermal runaway risk. Verifying and recording this at the point of loading requires a documented inspection step — not a visual check, but a recorded measurement with timestamp and evidence trail.

Pre-existing battery or structural damage

Any damage to the undercarriage, battery housing, or charging port must be documented before loading. If a vehicle arrives at the terminal with pre-existing damage and a fire event occurs at sea, the absence of pre-loading documentation shifts liability in ways that are very difficult to recover from.

Vehicle identification and VIN-level traceability

The ability to confirm, post-incident, exactly which vehicles were loaded in which configuration and condition is becoming a baseline expectation for marine insurers and port authorities. This requires VIN-level records tied to inspection data, not aggregate manifests.

Chain of custody from terminal to vessel

Where a vehicle passes through multiple handling stages — terminal receipt, PDI, yard storage, loading — the documentation trail must be continuous. Gaps in the chain of custody are gaps in liability protection.

The Documentation Gap Most Operators Are Carrying

The honest position for most PCTC operators today is this: the inspection capability exists, but the evidence trail it produces is not EV-compliant in the way regulators and insurers are beginning to require.

Paper-based pre-loading checks produce records that are difficult to retrieve, cannot be linked to VIN-level data at scale, and do not generate the timestamped, GPS-tagged evidence that a marine insurance claim or flag state investigation will require. Generic inspection apps capture photos but lack the enforced hierarchical documentation — at job, unit, and damage level — that creates a defensible chain of custody.

The gap is not in the willingness to inspect. It is in the quality and structure of the evidence the inspection produces.

What Good Pre-Loading EV Documentation Looks Like

Operators who get ahead of this will build pre-loading EV inspection into their existing vehicle condition reporting workflow, rather than treating it as a separate compliance process. The practical requirements are:

• A structured inspection record created per vehicle, linked to VIN, with timestamp and GPS coordinates at the point of inspection
• Mandatory photo capture at the unit level (exterior condition, undercarriage where accessible, charging port) and damage level for any pre-existing issues
• State of charge recorded as a data field, not a free-text note
• Digital signature from the receiving inspector or terminal operative, creating a legally binding handover record
• Automated report generation for the vessel manifest, so the master receives complete pre-loading condition data in a format that can be retained and retrieved

This is not a new inspection category. It is a documentation standard applied to an existing process. The vehicle still needs to be inspected before loading. What changes is the structure, completeness, and retrievability of the record that inspection produces.

Getting Ready Before the Season

FVL North America in April will surface this topic in conversations with PCTC operators across the US market. The regulatory question is already live in underwriting conversations, and operators who can demonstrate a structured pre-loading documentation workflow will be in a stronger position — with OEM clients, with marine insurers, and with port authorities.

The steps worth taking now:

1. Audit your current pre-loading documentation workflow. Can you retrieve a complete inspection record for any specific VIN loaded in the last 90 days? If not, that is the gap.
2. Review your inspection template for EV-specific fields. State of charge, battery condition, charging port status — these need to be structured fields, not free-text notes.
3. Check your chain of custody. If a vehicle moves through terminal receipt, PDI, and loading as separate handover points, does your documentation trail connect those steps at VIN level?
4. Engage your marine insurer. IUMI and Lloyd’s market underwriters are actively developing EV cargo endorsements. Understanding their documentation requirements now is better than discovering them at renewal.

How Bison Inspect Supports EV Pre-Loading Compliance

Bison Inspect was built for exactly this kind of structured, evidence-led inspection workflow. The hierarchical photo capture, GPS-tagged timestamp records, configurable inspection templates, and VIN-level digital signatures are the capabilities that turn an EV pre-loading check into a defensible compliance record.

Inspectors capture this evidence in the field on the Bison App, the native iOS and Android companion to Bison Inspect — available on the Apple App Store and Google Play.

If you are reviewing your pre-loading documentation process ahead of the 2026 season, we are happy to walk through how other PCTC operators are using Bison Inspect to build EV-ready inspection workflows into their existing operations.

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Bison Grid is a finished vehicle logistics quality management platform used by Siem Car Carriers, Wallenius Wilhelmsen, TOTE Maritime, and Petrucela & Co. The Bison App — the native iOS and Android field-inspection companion — is available on the Apple App Store and Google Play. For more on the regulatory framework referenced in this post, see the 2026 SOLAS fire safety amendments (IMO resolutions MSC.550(108) and MSC.532(107)), IMO MSC.1/Circ.1615 on firefighting for alternatively powered vehicles, EMSA’s guidance on the safe carriage of alternative fuel vehicles in ro-ro spaces (2022, updated 2025), and IUMI’s position on electric vehicle cargo.