Biofouling and Ship Recycling among topics to pick up momentum alongside GHG at the IMO

Amendments to mandatory requirements

MEPC 83 adopted amendments to the NOx Technical Code 2008 concerning the use of multiple engine operational profiles for a marine diesel engine, including clarifying engine test cycles. The amendments will enter into force on 1 March 2027. 

The Committee also adopted amendments to the NOx Technical Code 2008 concerning the certification of an engine subject to substantial modification or being certified to a tier to which the engine was not certified at the time of its installation. These amendments will enter into force on 1 September 2026.

A Convention on Biofouling 

MEPC 83 agreed to a new output on the “Development of a legally binding framework for the control and management of ships' biofouling to minimize the transfer of invasive aquatic species- a biofouling Convention”. The work on such a convention will commence in 2026 and we expect the process to be a lengthy one- with the Committee allocating two two-year periods to complete the work- meaning that a draft legal document and process for adoption would not likely be finalised until 2029 with ratification to the agreed level then required for the entry-into-force.  

The current absence of internationally-agreed legislation has meant that some states have taken the initiative to implement domestic legislation to address biofouling. We believe that an international convention should provide a unified framework for addressing biofouling management globally. It should help avoid the patchwork of national regulations that can be discriminatory and impractical for the industry and help ships to gain access to in-water cleaning in more places than we see today. 

BIMCO has been at the forefront of advocating for effective biofouling management practices. Our industry surveys carried out over the past seven years have provided us with valuable insights into the current state of biofouling management. During the convention development phase, we will continue to work with our members to address challenges and issues as they arise and ensure we have an instrument that is practical and fit-for-purpose. We encourage our members to continue to share their experience on the application of the 2023 IMO Biofouling Guidelines.  

It should be noted that MEPC also adopted in-water cleaning guidance designed to help shipowners, charterers, operators, crews and in-water cleaning service providers to safely plan and conduct in-water cleaning operations while addressing risks to the environment and ship coatings.  This will be made available to members when published by the IMO.  

An experience-building phase for ship recycling 

The entry into force in June 2025 of the Hong Kong Convention (HKC) will herald a new era in ship recycling by introducing safety, human health and environmental requirements at the end of life of ships. However, it has been 15 years since the HKC was adopted, and based on experiences with other IMO conventions, various issues will arise at the early phase of implementation of a convention. As such, MEPC agreed to a new output on ship recycling to take place over two two-year periods where the first two years will focus on gaining experience on the application of the HKC followed by two years during which amendments will be considered.  

Data compiled by BIMCO indicates that the number of ships destined for recycling is expected to more than double in the next decade. This anticipated surge underscores the urgent need for a robust and unified global standard to ensure that the recycling process is conducted safely and sustainably. By facilitating a smooth implementation of the HKC during the experience-building phase, stakeholders can work towards a cohesive approach that not only adheres to international norms but also supports continuous improvement and transparency.  

We will work with our ship recycling alliance to contribute to the experience-building phase, with a focus on improving safety and environmental measures and increasing knowledge sharing particularly related to best practices.  

A new ECA for the North-East Atlantic  

MEPC supported the Designation of the North-East Atlantic as a new emission control area (ECA) for Nitrogen Oxides (NO_x), Sulphur Oxides (SO_x) and particulate matter. The ECA is expected to be adopted at the extraordinary session of the MEPC to be held later this year and would therefore come into effect in 2027.  

The new ECA would prohibit ships from using fuel with a sulphur content greater than 0.10% m/m, or achieve equivalent emission reductions using approved technology, and would require all ships constructed after a certain date to comply with NO_x Tier III limits as specified in Reg.13 of MARPOL Annex VI.  

The North-East Atlantic Emission Control Area (NE Atlantic ECA) broadly encompasses the Exclusive Economic Zones (EEZ) and territorial seas, extending up to 200 nautical miles from the baselines, of Greenland, Iceland, the Faroe Islands, Ireland, and the mainlands of the United Kingdom, France, Spain, and Portugal. 

Methodology for collecting data on fuel oil consumption, distance travelled and hours under way under the Ship Energy Efficiency Management Plan (SEEMP) 

MEPC agreed amendments to the guidelines for the development of a ship energy efficiency management plan (SEEMP), introducing a new section about differentiating between under way and not under way when collecting data on fuel oil consumption: 

"Under way” and “not under way” 

7.6     Under way is defined as the period between full ahead on passage (FAOP) and end of sea passage (EOSP) as per the guidelines for setting up a maritime single window (FAL.5/Circ.42/Rev.3). 

Full ahead on passage is more commonly referred to in performance monitoring systems as begin of sea passage, which is also defined in the IMO Compendium on Facilitation and Electronic Business (IMO Compendium) under IMO 0597 (Code EV10). 

“Not under way” is therefore the period between end of sea passage and full ahead on passage. 

Note that canal passage, that is the period between begin canal passage (EV08) and end canal passage (EV09) which are also defined in the IMO Compendium under IMO 0597 should be considered not under way due to frequent manoeuvring, acceleration and deceleration." 

This harmonised approach to reporting fuel oil consumption is intended to facilitate the collection of data that can contribute to making the operational carbon intensity indicator (CII) a more accurate indicator of a ship’s actual efficiency. 

CII reduction factors for 2027 to 2030 

Until now, CII reduction (Z) factors have been set to 11% by 2026 relative to the 2019 reference lines. MEPC has now agreed Z factors for the period 2027 to 2030. By 2030, ships are expected to have reduced their carbon intensity by 21.5% relative to 2019. 

The Z factors have been set at that level to ensure that the reduction in CO2 emissions per transport work by at least 40% by 2030, compared to 2008, can be achieved as an average across international shipping, as agreed in the IMO GHG Strategy. 

Changes to the CII 

MEPC has agreed a work plan for the continued review of the CII regulations until 2028, which will include consideration of both an enhanced SEEMP and development of other CII metrics, such as an energy-based metric. BIMCO has been advocating for a differentiation between CO2 emissions while under way and CO2 emissions associated with idling and port calls, as an essential step towards a CII that more accurately reflects a ship’s energy efficiency. 

The plan also specifies that the IMO in 2028 should develop a possible way forward for carbon intensity and/or energy efficiency regulations beyond 2030. 

Accessibility to data in the IMO DCS 

MEPC approved amendments to regulation 27 of MARPOL Annex VI concerning accessibility to the IMO Ship Fuel Oil Consumption Database (IMO DCS), and the associated guidelines on data management. 

In the future, a ship’s flag state and classification society will have access to all the reported data for all the preceding years, regardless of flag history. 

Upon request from a ship’s company, the flag state of the ship, or the class, shall provide the company with all reported data for the ship, including the preceding years. 

When the amendments enter into force, public user accounts will be able to access a database with anonymised aggregated data, where identification of specific ships will not be possible. 

Further progress on Ballast Water Management (BWM) amendments 

At MEPC 83, the Ballast Water Review Group (BWRG) advanced several important elements of the BWM Convention and Code review process.  

Key outcomes included agreement that the Operation, Maintenance and Safety Manual (OMSM) must be updated and approved at the same time as any modification to a type-approved ballast water management system (BWMS). A new BWMS maintenance log will be included in the ballast water record book (BWRB) for ships that do not have an equivalent system (e.g. planned maintenance systems (PMS)), with associated amendments to the BWRB format and guidance documents to follow. 

The revised Regulation B-6 “Duties of Officers and Crew” was finalised, focusing on ensuring that evidence of crew familiarisation with the ship-specific ballast water management plan (BWMP) is maintained onboard. 

Challenges linked to pre-emptive BWMS bypass approvals in coastal states were also recognised, and member states were encouraged to share up-to-date contact points with the IMO Secretariat to support smoother communications. 

Most importantly, the Group agreed to introduce a mandatory “challenging water quality (CWQ) performance evaluation” test during BWMS type approval. The test is intended to verify system performance in environments with elevated suspended solids or other limiting factors and, ultimately, enhance performance transparency across a wider range of real-world conditions. The CWQ test will be integrated into the BWMS Code and apply to all systems regardless of design. This marks a significant step towards ensuring that BWMS remain operational and effective under all conditions. 

Looking ahead, the Correspondence Group will be re-established, with the goal of completing the draft amendments to the BWM Convention and Code for approval in 2026. Work on draft amendments to the existing guidelines and development of draft new guidelines, will continue towards expected completion in 2028.