A European problem of fires that do not end on land
From the Chlewnica Fire to a Ship’s Cargo Hold
The previous article began with the fire at the Waste Management Facility in Chlewnica. That fire revealed a simple but uncomfortable truth about the waste-management system currently in operation: the place where the flames appear need not be the place where the risk originated. A battery may pass safely through collection, transport and transfer, with only mechanical damage during sorting or shredding triggering a reaction that leads to a fire.
It is now worth following that battery a little further. A battery discarded in the wrong container does not disappear when it passes through the facility gate. It may, for example, end up in a pile of scrap metal, then in a lorry, at a port and ultimately in a ship’s cargo hold. It may change owners, documents and countries. The battery, however, knows nothing of this. If it is damaged, it may still cause a fire.
Fires at waste-management facilities, scrap yards and aboard ships are therefore not three separate problems. They are successive chapters in the same story.
These Are No Longer Isolated Incidents
For several years, the European waste-management sector has regarded battery fires as one of the key threats to facility operations. Data from individual countries are not fully comparable, but the scale of the phenomenon speaks for itself. According to FEAD, the number of lithium battery-related fires at waste-management facilities in France doubled between 2019 and 2023. Austria estimates that as many as 180–240 such fires occur each year. In Germany, reports indicate as many as 30 fire incidents per day in waste collection vehicles and facilities, with approximately 80% believed to be associated with lithium batteries. In the United Kingdom, more than 1,200 battery-related fires were recorded in 2023—71% more than in the previous year. [1]
Between March 2025 and March 2026, 1,518 fires were recorded at recycling centres in the United Kingdom. At least 541 were directly linked to batteries, while a further 216 occurred in waste collection vehicles. Battery fires are estimated to cost the sector more than GBP 1 billion annually. [2] By comparison, a 2021 Eunomia analysis referred to approximately 201 lithium-ion battery fires per year and costs of around GBP 158 million. [3]
EuRIC points out that the problem affects not only waste electrical and electronic equipment (WEEE), but also metal scrap. The most serious incidents analysed in the European WEEE chain required an average of one to six hours of firefighting, while average costs amounted to approximately EUR 190,000 for smaller incidents and EUR 1.3 million for more serious ones.[4]
Behind each of these figures is an ordinary situation. A phone is placed in the wrong container, with the battery still inside. An e-cigarette ends up in mixed waste. Then comes a baler, grab or shredder. A small object that once fitted in a pocket suddenly becomes a problem for a facility worth millions.
Scrap Is No Longer Just a Piece of Metal
Scrap intuitively brings to mind things that are difficult to ignite: a steel beam, part of a vehicle body or a machine component. The actual waste stream, however, may also contain plastics, rubber, oils, containers, parts of devices and batteries. The sheer mass of metal can effectively conceal a very small ignition source. In February 2024, around 70 firefighters tackled a scrap-yard fire in Silvertown, London. The London Fire Brigade identified the probable cause as a lithium-ion battery failure. In July 2024, a lithium battery was also cited as the most likely cause of a scrap-yard fire in Bellingham. In March 2025, approximately 100 m2 of scrap and electrical waste burned in Brentford, with a lithium-ion battery once again identified as the most likely cause.[5] Not every pile of scrap is a ticking time bomb. The problem is more prosaic: sometimes all it takes is one battery in the wrong place.
When Scrap Is Loaded Aboard a Ship
Maritime transport adds another complication. Thousands of tonnes of material are loaded into a deep cargo hold, while the heat source may lie several metres below the surface. Unfortunately, reaching it is nothing like moving a burning container away from a wall. In 2026, The Nautical Institute described a fire during the loading of scrap metal. Preliminary findings by the UK Marine Accident Investigation Branch (MAIB) indicated that the likely source was an undischarged battery or another source of sparks. The cargo had been classified as SCRAP METAL, Group C under the IMSBC Code, but it contained batteries, oil drums and oily residues.[6] In another documented case, a scrap-metal fire was fought for many hours using large quantities of water. The ship ultimately sank alongside the quay. The investigation found, among other things, that the master had not considered using the fixed CO2 system, while the hatch closure—necessary before the gas could be released—was obstructed by a loader arm left in place.[7] It is therefore possible to extinguish a fire while simultaneously creating another problem.
Sion Star: The First Spark Is Not the Whole Story
On 2 July 2026, a fire broke out in the cargo hold of the bulk carrier Sion Star, which was carrying scrap metal and was moored at Nabrzeże Szczecińskie in the Port of Gdańsk. The Polish State Marine Accident Investigation Commission is investigating the incident.
[8] Public reports demonstrate the enormous scale of the response: at its peak, around 100 firefighters were involved, and fireboats, a thermal-imaging camera and grabs were used to reach the source of the fire deep within the cargo.[9] Two questions must be posed and then distinguished. First: what started the fire? Second: what happened once the fire was already burning? From the perspective of liability, these are two separate stages of control over the risk. Information contained in the case materials, in which I represent the owner of the scrap metal, indicates that the fundamental error concerned the response after the fire had started and the improper safeguarding and implementation of procedures falling within the shipowner’s sphere of responsibility. Public reports confirm that water and foam were applied inside the cargo hold, while some of the scrap was removed with a grab and sprayed outside it.[10] At sea, the instinctive response—“there is a fire, so let us pour water on it”—may prove to be a costly oversimplification. Large quantities of water in a cargo hold increase weight and may affect the ship’s stability. If the source of the fire lies deep within compacted scrap, water may have limited access to it. In appropriate circumstances, it may be safer to close the hatch and ventilation and use a fixed CO2 system. The Nautical Institute identifies precisely this solution in its analysis of scrap-metal fires.[6] This does not mean that water must never be used to fight any scrap-metal fire aboard any ship. The point is more fundamental: the shipowner, master and crew must have a procedure tailored to the actual hazard and be able to apply it from the very first minutes.
Twenty Days Later: Federal St Laurent
On 22 July 2026, another scrap-metal fire occurred, once again in the Port of Gdańsk—this time in the cargo hold of Federal St Laurent. The fire was suppressed by releasing carbon dioxide into the enclosed space. Seven fire crews and a rescue unit took part, and the operation ended after approximately five hours.[11] The two fires should not be compared mechanically solely by reference to their duration, as each may have developed differently. The comparison is nevertheless instructive: it demonstrates the importance of rapidly isolating the cargo hold and using a gaseous fire-extinguishing system. The entity supplying the cargo does not take control of the bridge, the CO2 system or the decision to close the hatch. Once the cargo is aboard, another sphere of control comes into play: the ship.
General Average: When a Fire Opens Another Account
A fire aboard a ship may trigger another mechanism which, from the cargo owner’s perspective, can be just as important as establishing the cause of the fire itself: general average. If extraordinary and reasonable measures are taken, or extraordinary expenditure is incurred, for the common safety of the ship and cargo, the resulting burden may subsequently be apportioned among the interests participating in the common maritime adventure. Earlier errors do not, however, disappear from the picture. Rule D of the York-Antwerp Rules preserves the right to contribution in general average even where the event giving rise to the sacrifice or expenditure was associated with the fault of only one party to the common maritime adventure, while leaving open claims and defences arising from that very fault. Improper firefighting procedures, a failure to isolate the cargo hold correctly or an incorrect response by the shipowner may therefore remain relevant even when general average is adjusted.[16]
In the case of Sion Star, this context is particularly interesting. If failings within the shipowner’s sphere of control contributed to the escalation, the economic consequences cannot be analysed as though the only material fact were what was in the cargo hold at the moment of first ignition, because the first spark and the subsequent management of the hazard are separate stages in the chain of causation. It is also necessary to distinguish between concepts that easily overlap in everyday language. The owner of the scrap need not be the charterer. The cargo interest, cargo owner, shipper, charterer and party to a particular contract of carriage may in fact be different participants, and the rights and obligations of one should not automatically be attributed to another. This opens a broader discussion about charterparties, bills of lading, the allocation of risk, standing, and the relationship between general average and contractual liability.[17] It all leads to one conclusion: general average should not obscure who actually controlled each stage of the risk. A cargo owner does not become a charterer merely because it owns the cargo, and general average does not render the shipowner’s failings irrelevant. This is a separate chapter of maritime law—and material for a separate article.
Maritime Law Sees Scrap. But Does It See Today’s Scrap?
SOLAS regulates the safe carriage of solid bulk cargoes, while the mandatory International Maritime Solid Bulk Cargoes Code—the IMSBC Code—elaborates on those requirements. The Code defines cargo-related hazards and procedures for safe loading, stowage, carriage and unloading.[12] The problem, however, is that SCRAP METAL is treated as a Group C cargo. Yet accidents demonstrate that actual scrap may contain batteries, oils and combustible materials. The documents say “scrap”, while the cargo hold sometimes replies: “it is more complicated”. The point is not, of course, to reject the IMSBC Code, but to adapt classifications and procedures to the changing material stream. In a world in which batteries surround us on all sides—inside scooters, tools, cars and dozens of small devices—their presence in scrap has ceased to be a rare exception.
The EU Regulates Batteries—but Fires Fall Between the Rules
Regulation (EU) 2023/1542 concerning batteries and waste batteries increases producer responsibility and collection and treatment obligations, and sets collection targets for portable batteries of 63% by the end of 2027 and 73% by the end of 2030; for batteries for light means of transport, the targets are 51% by the end of 2028 and 61% by the end of 2031.[13] The WEEE Directive requires batteries to be removed from separately collected waste electrical and electronic equipment.[14] The direction of travel is undoubtedly correct. The problem, however, begins with a battery of which the system is no longer aware: one left inside a device, discarded in residual waste or hidden in scrap. In 2025, Germany supplemented the system with the new Batterierecht-Durchführungsgesetz (BattDG). It requires the separate collection of waste batteries, expands free take-back and retains a EUR 7.50 deposit on starter batteries. The Bundestag also called for an examination of a deposit scheme for lithium-containing batteries, taking into account Denmark’s experience and a European solution.[15] This represents an important change in perspective. A deposit need not merely increase recycling rates. It can serve as a fire-prevention tool. After all, the least expensive fire is the one that never has to be extinguished.
What Should Change
First, European battery policy should treat the number of batteries entering the wrong waste streams as a safety indicator, rather than solely as a recycling problem. Collection targets are necessary, but the number of incidents and the costs of fires should also be measured. Second, an economic incentive for returning lithium batteries and devices containing them should be considered. Not every battery needs to be subject to the same deposit, but the current system too often assumes that information alone will suffice. Unfortunately, a waste bin cannot read. Third, Europe needs a standard for inspecting scrap before it is loaded aboard a ship. This cannot be an obligation to “find every battery”, because that is not always technically possible. There should, however, be a standard of due inspection, documentation of origin, and removal of identifiable contaminants and batteries. Fourth, the IMO should examine whether the current classification of SCRAP METAL under the IMSBC Code genuinely reflects today’s risks. If the cargo may contain batteries and other ignition sources, the documentation and procedures should account for this before a firefighter sees them through a thermal-imaging camera. Fifth, onboard procedures for the carriage of scrap should expressly cover early detection of temperature increases, rapid closure of cargo spaces, rules for the use of fixed fire-extinguishing systems, and control of the effect of firefighting water on stability. A procedure in a binder is worth little if, when a fire breaks out and every second matters, no one can translate it into a decision. Sixth, Europe needs a uniform register of battery fires across the entire chain: from waste collection vehicles and sorting facilities, through scrap yards and ports, to ships. The register should distinguish between confirmed, probable and undetermined causes and record how the fire developed and which extinguishing measures were used to contain it. Finally, responsibility should follow control over the risk. The producer is responsible for the product and information; the collection system—for a genuinely accessible return route; the holder and entity preparing the scrap—for actions within their sphere of control; and the shipowner, master and crew—for the ship, its systems and the response to fire. The first spark does not extinguish subsequent duties.
The Fire Starts Earlier, but Responsibility Does Not End with the First Spark
The first article in this series concluded with the proposition that the burden of ensuring safety should shift from the place where the flames appear to the place where they can truly be prevented. Scrap-metal fires and fires aboard ships require one sentence to be added: a fire may start earlier, but responsibility does not end with the first spark. A battery may travel a long way: from a device into waste, from waste into scrap, from scrap to a yard, from the yard to a port and from the port into a ship’s cargo hold. At each stage, someone controls something—and every participant should be responsible for their part of that journey. We do not need a system in which, after every major fire, everyone points to the preceding link. We need a system in which every link knows what to do and how to do it before anyone sees smoke. And if smoke has already appeared—it also knows what not to do.
Notes and Sources
[1] FEAD, Joint call for EU action to protect waste management from surging lithium battery fires; data concerning France, Austria, Germany and the United Kingdom.
[2] Data from the UK waste sector for the period March 2025–March 2026, cited on 22 August 2026; 1,518 fires at recycling centres, at least 541 directly linked to batteries, and 216 fires in waste collection vehicles.
[3] Eunomia / Environmental Services Association, Cutting Lithium-ion Battery Fires in the Waste Industry, 2021.
[4] EuRIC, Battery fires in recycling facilities – a burning issue and how to resolve it; WEEE Forum/EuRIC, Characterisation of fires caused by batteries in WEEE.
[5] London Fire Brigade: scrap-yard fire in Silvertown, 17 February 2024; scrap-yard fire in Bellingham, 22 July 2024; fire at a waste-recycling facility in Brentford, 22 March 2025.
[6] The Nautical Institute, MARS 202611, Scrap metal fire, 26 February 2026, based on the preliminary MAIB assessment.
[7] The Nautical Institute, MARS 202346, Scrap metal fire extinguished but vessel sunk, 28 September 2023, based on the JTSB report.
[8] Państwowa Komisja Badania Wypadków Morskich [Polish State Marine Accident Investigation Commission], ongoing investigation: 2 July 2026, Port of Gdańsk, fire in the cargo hold of Sion Star.
[9] The Maritime Executive, Fire Crews Battling Large Scrap Metal Fire on Bulker in Gdansk, 3 July 2026.
[10] PAP / PortalMorski.pl, fire in the cargo hold of a ship carrying scrap metal in the Port of Gdańsk, 3 July 2026.
[11] Radio Gdańsk, fire aboard a ship in the Port of Gdańsk, 22 July 2026—Federal St Laurent; the fire was suppressed by releasing CO2 into the enclosed cargo hold.
[12] International Maritime Organization, International Maritime Solid Bulk Cargoes (IMSBC) Code; SOLAS, Chapter VI.
[13] Regulation (EU) 2023/1542 of the European Parliament and of the Council concerning batteries and waste batteries.
[14] Directive 2012/19/EU (WEEE), Annex VII—selective removal of batteries from WEEE.
[15] Germany: Batterierecht-Durchführungsgesetz (BattDG), in particular Sections 6, 14 and 18–19; materials of the Federal Ministry for the Environment and the Bundestag from 2025.
[16] York-Antwerp Rules 2016, in particular Rules A and D; Comité Maritime International.
[17] The status of cargo owner is not automatically identical to that of charterer; the scope of rights and obligations depends on the specific structure of the contracts of carriage and transport documents.