Pete Pedrozo on “The Law and Containerized Missile and Rocket Launch Systems”

Can a commercial merchant ship be lawfully used as a launch platform for a surprise missile attack?  Today, popular Lawfire^® contributor Prof Pete Pedrozo unpacks for us some of the potential legal implications of the growing number of containerized missile and rocket launch systems. 

These self-contained systems have much utility and can be used lawfully.  Nevertheless, as Pete points out, they also can be “easily camouflaged as a harmless civilian shipping container and…be fired with little or no warning from a commercial merchant ship.”  Such use, however, “during an international armed conflict would likely violate the law of naval warfare.”

Here’s more detail:

Containerized Missile and Rocket Launch Systems 

by Raul (Pete) Pedrozo

China Complains

In August 2025, a People’s Liberation Army (PLA) spokesperson warned that a new U.S. containerized missile and rocket launch system could “seriously undermine regional strategic stability.” The launcher can purportedly be used to fire a range of missiles and rockets, including those used in the M270 Multiple Launch Rocket System (MLRS) and the M142 High Mobility Artillery Rocket System (HIMARS).

Because the launcher can be hidden inside a shipping container, the PLA spokesperson cautioned that any vehicle capable of transporting a standard shipping container could be “used as a platform to launch long-range guided rockets and missiles.”

The launch system could be “mixed in with ordinary containers, camouflaged with civilian paint and maritime freight, and delivered to a designated launch location in secret.” The spokesperson advised that the ability to conceal the launch system improves its survivability and will enable U.S. forces “to achieve tactical surprise when necessary” by quickly deploying and launching attacks at multiple dispersed locations.

U.S. Palletized Field Artillery Launcher Project

The PLA spokesperson is referring to a prototype launch system that is part of the Palletized Field Artillery Launcher (PFAL) project. The PFAL palletized erectable launcher that provides a harder-to-spot, flexible strike capability that can launch the MLRS family of munitions (except the Precision Strike Missile (PrSM) short-range ballistic missile), such as the 227mm guided artillery rocket and the Army Tactical Missile System (ATACMS).

The system offers a long-range strike capability that can be employed against both land-based targets and maritime targets, and can be fired from a fixed ground position, a Palletized Load System (PLS) trailer, or a railcar, or naval vessel that can carry a standard shipping container can be transformed into a “platform capable of firing long-range guided rockets and missiles.” Containerized launchers are well-suited for use in expeditionary or distributed operations in the Indo-Pacific region in the event of a conflict with China.

Containerized Missile Systems

Containerized missile systems are not new. Russia, China, and Iran have been developing rocket and missile launchers concealed inside shipping containers for a long time. Israel, the United States, the Netherlands, Denmark, and other nations are also developing containerized missiles.

The Russian Club-K missile system, for example, has been for sale on the global weapons market since 2010 at a cost of $10-$20 million. Potential customers include Iran, Venezuela, and Syria, but there is a danger that the missiles could end up in the hands of terrorists.

The system, which is equipped with four ground or sea-launched cruise missiles housed in a 20- or 40-foot equivalent (TEU) shipping container, provides a long-range precision strike capability that can be easily concealed among other shipping containers on a train, truck, or ship without attracting attention.

When required (and without warning), the roof of the container roof lifts off and the missiles stand upright and can be launched autonomously at targets on land or sea using targeting data from an external source.

China began developing its version of the Club-K in 2016—the Containerized Sea Defense Combat System (CSDCS). An improved version of the CSDCS, which (unlike the Russia Club-K, which is limited to firing only Kh-35 and Kalibr missiles), can launch multiple missile types (YJ-12E, YJ-18E, YJ-83/YJ-62, and PL-16), was revealed in 2022. Chinese domestic legislation, enacted in 2016, requires (inter alia) civilian shipping companies to directly support military operations.

Consistent with this law, China has conducted naval exercises testing the use of a converted civilian container ship as a launch platform for WZ-10 attack helicopters, as well as converted roll-on/roll-off (RORO) passenger/car ferries to launch armed amphibious vehicles in support of amphibious operations. These exercises demonstrate that China will use commercial vessels in direct support of military operations.

Similarly, China intends to surreptitiously deploy CSDCS missile systems on board commercial container ships to conduct a crippling first strike against U.S. targets in Guam, Hawaii, and the western United States in the event of a war in the Pacific. China’s large merchant fleet (5,600-plus vessels) and tens of thousands of fishing vessels provide the People’s Liberation Army-Navy (PLAN) with unlimited launch platforms.

Attacking Enemy Merchant Vessels

Generally, belligerent warships may not attack enemy merchant vessels unless they become a military objective by their conduct or operation (e.g., engaging in belligerent acts; acting as a naval auxiliary; collecting intelligence; sailing under convoy with enemy warships; armed with weapons beyond what is required for self-defense) (The Newport Manual on the Law of Naval Warfare, § 8.6.3).

International law, reflected in the 1936 London Protocol, prohibits attacking an enemy merchant vessel unless the safety of the passengers and crew is first assured, unless the vessel persistently refuses to stop when hailed or actively resists visit and search.

Although the Protocol was largely ignored during the Second World War, the rules remain valid today, subject to reinterpretation in light of state practice during the war (The Commander’s Handbook on the Law of Naval Operations, § 8.6.2.1).

Perfidy

Given that the Club-K is easily camouflaged as a harmless civilian shipping container and that it can be fired with little or no warning from a commercial merchant ship, use of the Club-K by Russia or China during an international armed conflict would likely violate the law of naval warfare.

Perfidy is defined in article 37 of Additional Protocol I as an act that invites the confidence of the enemy to lead them to believe that they are entitled to, or is obliged to accord, protection under the law of armed conflict, with intent to betray that confidence, to kill, injure, or capture the enemy.

Feigning civilian status as a merchant ship and then engaging the enemy with a Club-K missile to kill, injure, or capture the enemy would likely constitute perfidy. There is no indication that the U.S. Department of Defense plans to deploy containerized missile systems on civilian merchant ships.

To date, the U.S. Navy has only test-fired containerized missiles from unmanned surface vessels (USV) and a littoral combat ship (LCS). In 2021, the Navy test-fired an SM-6 standard missile from a containerized vertical launch system (Mk 41) on board USV Ranger. Two years later, the USS Savannah (LCS-26) fired an SM-6 at a surface target from an Mk70 containerized missile launcher during a live-fire exercise in the Eastern Pacific Ocean.

Additionally, U.S. Marine littoral regiments and Army multidomain task forces have conducted live-fire exercises using land-based containerized missile launchers. The Army and Marines started developing land-based containerized launchers after the United States withdrew from the Intermediate-Range Nuclear Forces (INF) Treaty in 2019.

People’s Liberation Army Rocket Force

The only nation undermining regional strategic stability in the Pacific through missile development and deployments is China. Over the past twenty-five years, China has developed the “largest and most diverse” land-based conventional missile arsenal in the world.

According to the 2024 Annual Report to Congress on Military and Security Developments Involving the People’s Republic of China, China’s People’s Liberation Army Rocket Force (PLARF) deploys a wide range of conventional mobile ground-launched ballistic missiles and ground-launched cruise missiles (GLCM), including:

• • 300 launchers/900 short-range ballistic missiles (SRBM)—DF-15, DF-11, DF-16;
  • 300 launchers/1,300 medium-range ballistic missiles (MRBM)—DF-21 (land-attack and anti-ship variants), DF-17 (hypersonic glide vehicle capable);
  • 250 launchers/500 intermediate-range ballistic missiles—DF-26, DH-10
  • 150 launchers/400 intermediate range GLCM—DF-26, DH-10, DF-100 (GLCM)

The DF-21D medium-range anti-ship ballistic missile (ASBM) variant, with a range exceeding 1,500 km, allows the PLA to “conduct long-range precision strikes against ships … out to the Western Pacific from mainland China.” The DF-17 MRBM, with a range between 3,000 and 4,000 km, can also be used to strike foreign military bases and ships at sea in the Western Pacific.

Similarly, the DF-26 IRBM, with a maximum range of between 3,000 and 5,500 km, can conduct precision land-attack and anti-ship strikes in the Western Pacific out to the Second Island Chain, the Indian Ocean, and the South China Sea from mainland China.

DF-15 and DF-11A SRBMs are deployed along the Taiwan Strait for use in a potential Taiwan contingency. The DF-16, with a range of 800 to 1,000 km, can be used to strike targets within the First Island Chain. When fired, these missiles will strike Taiwan within six to eight minutes. DF-21D and DF-26 medium-range ASBM are deployed in China’s southern and northern provinces, putting the entire South and East China Seas, as well as U.S. and allied forces in South Korea, Japan, and Guam, within range.

Intermediate-Range Nuclear Forces (INF) Treaty

China has been able to rapidly develop its conventional missile capabilities because it is not constrained by the INF Treaty. The treaty required the United States and the Soviet Union to eliminate the development and deployment of their nuclear and conventional ground-launched ballistic and cruise missiles with ranges between 500 and 5,500 km.

By June 1991, the United States and the Soviet Union had destroyed 2,692 short-, medium-, and intermediate-range missiles. If China had been a party to the INF Treaty, ninety-five percent of its missile arsenal would be non-compliant.

In 2014, the United States determined that Russia was in violation of its obligations under the INF Treaty by producing and fielding the noncompliant SSC-8 (9M729) ground-launched, intermediate-range cruise missile. Similar determinations were made in 2015, 2016, 2017, and 2018. The North Atlantic Treaty Organization (NATO) foreign ministers supported the U.S. findings and called on Russia to return to full and verifiable compliance with the Treaty.

Nonetheless, on February 2, 2019, after six years of failed diplomacy, the United States suspended its obligations under the INF Treaty. The U.S. suspension also noted that China and Iran were unconstrained by the Treaty, each possessing over 1,000 INF Treaty-range missiles, and that continued U.S. adherence would limit U.S. ability to counter those threats.

Six months later, the U.S. withdrawal took effect pursuant to article XV of the Treaty. NATO fully supported the U.S. withdrawal, attributing “sole responsibility” for the Treaty’s demise to Russia.

Operating Outside the Treaty

Both Russia and China were critical of the U.S. decision, attempting to shift the blame for the Treaty’s demise to the United States. Russia criticized the United States for “undercutting many years of efforts to reduce the probability of a large-scale armed conflict, including the use of nuclear weapons.”

Additionally, China rebuked the United States for shirking its international commitments and pursuing unilateralism, indicating that the United States withdrew from the Treaty to “unilaterally seek military and strategic edge.”  

This opposition is understandable. Russia wanted to continue to illegally operate outside the constraints of the Treaty by developing noncompliant missiles to the detriment of the NATO alliance, while the United States remained bound by its restrictions. Moreover, as a nonparty to the agreement, China was able to build up its missile arsenal unconstrained by the Treaty’s limitations to counter U.S. military power and threaten U.S. allies and partners in the Indo-Pacific region.

In April 2024, the United States deployed a Typhon missile system to the northern Philippines. The land-based medium-range missile system can fire both SM-6 and Tomahawk Land Attack Missiles. In April 2025, the United States deployed an anti-ship missile launcher to the Philippines’ northernmost province of Batanes.

Discussions for additional missile deployments along Philippine coastal regions are ongoing to deter Chinese aggression in the South China Sea and the Taiwan Strait. Despite Chinese protests, President Ferdinand Marcos, Jr., has rejected China’s demands to remove the missiles.

China has had a thirty-year head start in developing and deploying short-, medium-, and intermediate-range missiles to enable its anti-access/area denial strategy within the First Island Chain. The demise of the INF Treaty will erase China’s asymmetrical advantage.

Although the United States is playing catch-up, it has positioned itself to rapidly develop and deploy new medium- and intermediate-range land-based missiles, such as the PFAL project, in the Indo-Pacific Region to counter China’s extensive missile forces and deter Chinese aggression by enhancing U.S. strike capabilities.

About the author:

Captain Raul (Pete) Pedrozo, U.S. Navy (Retired), is the Howard S. Levie Chair on the Law of Armed Conflict and professor of international law at the Stockton Center for International Law, U.S. Naval War College. Prof. Pedrozo was the former senior legal adviser at U.S. Pacific Command and served as special assistant to the Under Secretary of Defense for Policy.

Disclaimers:

The views and opinions expressed in this article are those of the author and do not necessarily reflect those of the U.S. Naval War College, the U.S. Department of Defense, or the U.S. Government.

The views expressed by guest authors do not necessarily reflect my views or those of the Center on Law, Ethics and National Security, or Duke University. (See also here).

Remember what we like to say on Lawfire^®: gather the facts, examine the law, evaluate the arguments – and then decide for yourself!