Future Amendments | Knowledge Of Sea

Entry into force 1 January 2025

Amendments to the International Maritime Solid Bulk Cargoes Code (IMSBC Code) -Amendment 07-23

Background: The IMO Resolution MSC.539(107) introduces amendments to the International Maritime Solid Bulk Cargoes (IMSBC) Code. These amendments include a combination of addition of new individual schedules and amendments to existing ones.

Agreed new individual schedules:

DUNITE and DUNITE FINES
BROWN FUSED ALUMINA
CRUSHED GRANODIORITE
DIRECT REDUCED IRON (D) (by-product fines with moisture of at least 2%)
BARYTE, FLOTATION CHEMICAL GRADE
ELECTRIC ARC FURNACE DUST, PELLETIZED
POTASSIUM NITRATE, SODIUM NITRATE
SODIUM NITRATE AND POTASSIUM NITRATE MIXTURE

Agreed amendments to the IMSBC Code:

various editorial corrections (such as the usage of more gender-neutral terminology. e.g. instead of the word “his”, using the word “their”)
amendments to provision 1.6 of the IMSBC Code as to align it with the relevant amendments to SOLAS chapter VI

Implication: If requested, any of the new cargoes may be added to a vessel’s Carriage of Solid Bulk Cargoes Certificate of Compliance, provided that all survey requirements have been verified.

Application: The amendments to the IMSBC Code apply to the carriage of solid bulk cargoes other than grain. The amendments will enter into force on 1 January 2025, but can be implemented voluntarily from 1 January 2024, subject to the agreement of the flag Administration.

Amendments to the International Convention on Standards of Training, Certification and
Watchkeeping for Seafarers (STCW), 1978 – Amendments to regulations I/1 and I/2 – Electronic
seafarers’ certificates

Background: As part of the continuing digitisation of the shipping industry it’s important to move certification from paper format to electronic format. The amendment allows seafarers’ certification to be in an electronic form provided minimum information is available to the Administration in accordance with the STCW Code.

Implication: This allows seafarers, ship managers and ship masters to keep electronic seafarers’ certificates onboard.

Application: All seafarers.

Amendments to part A of the Seafarers’ Training, Certification and Watchkeeping (STCW) Code –
(section A-I/2) – Electronic seafarers’ certificates

Background: As part of the continuing digitisation of the shipping industry it’s important to move certification from paper format to electronic format. This amendment provides the minimum information to be included on seafarers’ certificates, and how, in any format.

Implication: This allows seafarers, ship managers and ship masters to keep electronic seafarers’ certificates onboard.

Application: All seafarers.

Establishment of the date on which regulations 15.3, 15.5, and 34.3 to 34.5 of MARPOL Annex I, in
respect of the Red Sea and Gulf of Aden Special Areas, shall take effect

Background: The Red Sea area was recognised as a Special Area under Annex I (regulation 1.11.4) of MARPOL. However, for the Special Area status to come into effect adequate reception facilities must be provided in all relevant ports of the Red Sea coastal States which are Parties to MARPOL Annex I. As per MARPOL Annex I Regulation 1.11, a Special Area means a sea area where for recognised technical reasons in relation to its oceanographic and ecological condition and to the particular character of its traffic the adoption of special mandatory methods for the prevention of sea pollution by garbage is required. At MEPC 80, based on information provided related to the status of available necessary reception facilities for MARPOL Annexes I and V wastes and residues, covering all the ports and terminals within the areas, the Special Area status was agreed.

Implication: Any ship transiting through the Red Sea area (i.e. the Red Sea proper including the Gulfs of Suez and Aqaba bounded at the south by the rhumb line between Ras si Ane (12º 28.5΄ N, 43º 19.6΄ E) and Husn Murad (12º 40.4΄ N, 43º 30.2΄ E)), and the Gulf of Aden area (the Gulf of Aden area means that part of the Gulf of Aden between the Red Sea and the Arabian Sea bounded to the west by the rhumb line between Ras si Ane (12°28.5 N, 043°19.6 E) and Husn Murad (12°40.4 N, 043°30.2 E) and to the east by the rhumb line between Ras Asir (11°50 N, 051°16.9 E) and the Ras Fartak (15°35 N, 052°13.8 E)) will have to comply with the discharge requirements of MARPOL Annex I regulations 15.3, 15.5, 34.3, 34.4 and 34.5, from 1 January 2025.

The previously mentioned regulations prohibit the discharging of oil or oily mixtures from ships of 400GT and above, unless all of the following conditions are satisfied:

the ship is proceeding en route;
the oily mixture is processed through an oil filtering equipment meeting the requirements of regulation 14.7 of Annex I;
the oil content of the effluent without dilution does not exceed 15 parts per million.
the oily mixture does not originate from cargo pumproom bilges on oil tankers; and
the oily mixture, in case of oil tankers, is not mixed with oil cargo residues.
For oil tankers any discharge into the sea of oil or oily mixture from the cargo area shall be prohibited while in a Special Area.

Application: All ships transiting through the Red Sea and Gulf of Aden Special Areas from 1 January 2025.

Establishment of the date on which regulation 6 of MARPOL Annex V, in respect of the Red Sea
Special Area shall take effect

Background: The Red Sea area was recognised as a Special Area under Annex V (regulation 1.14.4) of MARPOL.

However, for the Special Area status to come into effect adequate reception facilities must be provided in all relevant ports of the Red Sea coastal States Parties to MARPOL. As per MARPOL Annex V regulation 1.14, “Special Area” means a sea area where for recognised technical reasons in relation to its oceanographic and ecological condition and to the particular character of its traffic, the adoption of special mandatory methods for the prevention of sea pollution by garbage is required. Based on information provided related to the status of available necessary reception facilities for MARPOL Annexes I and V wastes and residues, covering all the ports and terminals within the areas, the Special Area status was agreed.

Implication: Any vessel transiting through the Red Sea area (i.e. the Red Sea proper including the Gulfs of Suez and Aqaba bounded at the south by the rhumb line between Ras si Ane (12º 28.5΄ N, 43º 19.6΄ E) and Husn Murad (12º 40.4΄ N, 43º 30.2΄ E)), will have to comply with the discharge requirements of MARPOL Annex V regulation 6 from 1 January 2025. This includes requirements for the discharge of:

Food wastes (as far from land as practicable but not less than 12 nautical miles from nearest land and having been ground down or comminute).
Cargo residues that cannot be recovered using commonly available methods for unloading.
Cleaning agents or additives contained in deck and external surfaces wash water (only if not harmful to the environment).

Application: All ships transiting through the Red Sea Special Area from 1 January 2025.

Entry into force 1 February 2025

Amendments to the International Ballast Water Management Convention – Amendments to Appendix
II (Form of Ballast Water Record Book)

Background: The information gathered to date in the Experience-Building Phase of the BWM Convention has noted that 70% of reported deficiencies reported by port States related to incorrect entries in the Ballast Water Record Book (BWRB). It has been recognised that the current form of the BWRB does not provide sufficient clarity to meet the requirements of Appendix II of the BWM Convention. Appendix II of the BWM Convention has been updated to amend the existing version of the BWRB, to include additional information on entries to be included in the BWRB and an updated BWRB page.

Implication:
Ship operators: will need to complete and maintain the newly agreed format of the BWRB from 1 February 2025. Updated supporting guidance (BWM.2/Circ.80/Rev.1 – 2024 Guidance on ballast water record-keeping and reporting) has been issued.

Application: All ships designed to carry ballast water operating between two ports of different countries.

Entry into force 26 June 2025

Hong Kong International Convention on the Safe and Environmentally Sound Recycling of Ships,
2009

Background: It is known that ships may contain environmentally hazardous substances (e.g. asbestos, heavy metals, PBC’s) and the recycling of a ship at the end of its life is associated with many working and environmental concerns. As such, the IMO Hong Kong Convention aims to ensure that the recycling of ships does not pose an unnecessary risk to human health, safety or the environment.

The Hong Kong convention has requirements for the design, construction, operation and preparation of ships to facilitate safe and environmentally sound recycling without compromising the safety and operational efficiency of ships; the operation of ship recycling facilities in a safe and environmentally sound manner; and the establishment of an appropriate enforcement mechanism for ship recycling, incorporating certification and reporting requirements.

Implication:
Shipowners: Will need to ensure that they have a properly regulated method of building, operating and recycling a ship, that safeguards both crew and recycling facility workers safety, whilst minimising the environmental impact.

Key dates:

From 26 June 2025 new ships* will have to have an approved and certified IHM onboard upon their delivery.
“New ships” means a ship:
for which the building contract is placed on or after 26 June 2025; or
in the absence of a building contract, the keel of which is laid, or which is at a similar stage of construction on or after 26 December 2025; or
the delivery of which is on or after 26 December 2027.
From 26 June 2025 ships going for recycling will have to:
be recycled at a ship recycling facility which has a valid Document of Authorisation for Ship Recycling (DASR).
hold an approved and valid IHM Parts I, II and III.
have a ship specific recycling plan, in compliance with HKC, developed by their chosen ship recycling facility.
have a ready for recycling certificate onboard.
By 26 June 2030 existing ships will have to:
have an approved and certified Inventory of Hazardous Materials (IHM) Part I onboard.

Ship Recycling Facilities:
By 26 June 2025 – ship recycling facilities will have to have a valid DASR and issue ship specific recycling plans for each ship they plan to recycle.

Manufacturers and Shipbuilders:
Will need to ensure that they complete / compile the required Material Declarations (MD) and Supplier Declarations of Conformity (SDoc) for any items being supplied to the ship which are part of the ships structure or fitted equipment. For shipbuilders they will need to use the MD and SDoC to comply an IHM during the build process.

Application: Applies to all ships over 500GT on international voyages including:

Submersibles.
Floating craft.
Floating platforms.
Self-elevating platforms.
Floating Storage Units (FSUs);
Floating Production Storage and Offloading Units (FPSOs); and
A vessel stripped of equipment or being towed.

Exceptions: Warships, naval auxiliary, ships used for government non-commercial service.

Also applies to ship recycling facilities operating in a country which has adopted the Hong Kong Convention.

Entry into force 1 August 2025

Amendments to regulation 13.2.2 of MARPOL Annex VI on a marine diesel engine replacing a steam
system

Background: Amendments to regulation 13.2.2 of MARPOL Annex VI have been adopted to clarify that a diesel engine replacing a steam system is an engine replacement (within the context of a major conversion) and is not a minor modification. In connection to these amendments, the 2013 Guidelines, as required by regulation 13.2.2 of MARPOL Annex VI in respect of non-identical replacement engines not required to meet the Tier III limit, have been replaced by the 2024 Guidelines as required by regulation 13.2.2 of MARPOL Annex VI in respect of non-identical replacement engines not required to meet the Tier III limit. This will support the decision of Administrations to allow a Tier II engine to be installed instead of a Tier III engine.

Implication: Shipowners and operators should be aware that any replacement of a steam system with a marine diesel engine after these amendments enter force will require compliance with Regulation 13 of MARPOL Annex VI, taking into account any amendments to the relevant guidelines.

Application: To the replacement of an engine with power output of more than 130 kW with a non-identical replacement engine including replacement of a steam system. A Tier III engine is to be installed if the ship is operating in an area designated as a NOx ECA and the replacement takes place on or after the applicable date for the relevant ECA. However, the installation of a Tier II engine will be allowed where it is demonstrated that:

A replacement engine of similar rating complying with Tier III is not commercially available; or
The replacement engine, in order to be brought into Tier III compliance, needs to be equipped with a NOx reducing device which owing to:
- size cannot be installed in the limited space available on board; or
- extensive heat release could have an adverse impact on the ships structure, sheeting, and/or equipment whilst additional ventilation and/or insulation of the engine-room/compartment will not be possible.

Amendments to MARPOL Annex VI regulation 27 and Appendix IX on IMO DCS

Background: Amendments to MARPOL Annex VI, regulation 27, and appendix IX, have been adopted which include the ability for a company to request the non-anonymised data for its ships to be made public as well as new obligations to report the following data:

Fuel consumption per consumer both when underway and not underway.
Total onshore power supplied.
Total transport work.
Installation of innovative technology; and
On a voluntary basis Laden distance travelled.

Implication: From the entry into force of the amendments the requirement to collect and report the data in the amended Appendix IX will apply to ships of 5,000GT or above. This new data provides further granularity on fuel consumption and voyage data.

Ship operators ahead of the entry into force date, will need to ensure that the SEEMP Part II is modified as necessary to cover capture of the newly required data.

The associated amendments to the 2022 SEEMP Guidelines specify that the collection of fuel oil consumption per consumer type methods may include:

use of flow meters.
on board bunker fuel oil tank monitoring; or
method using subtraction (from the total fuel oil consumption when data for only one consumer is not available).
There is also provision for an alternative method to the satisfaction of the Administration to be used.

Application: All ships of 5,000GT and over.

Amendments to MARPOL Annex VI, regulations 2, 14, and 18 and Appendix I (Low-flashpoint fuels
and other fuel oil related issues)

Background: Inconsistencies were identified with the reporting of fuel flashpoint on the bunker delivery note due to the different terminology used in SOLAS chapter II-2 and MARPOL Annex VI as they apply to low-flashpoint fuels and their sampling. Additionally, several other ʺfuel oilʺ related issues have been identified. These amendments to regulation 2 of MARPOL Annex VI update the definition of “fuel oil” and include a definition of “gas fuel”, along with amendments to regulation 14 that result in fuel sampling points not being applicable to gas fuels, in addition to low-flashpoint fuels.

Further, regulation 18 is amended to reflect the new definition of “fuel oil” and to provide clarity on the requirements for gas and low-flashpoint fuels.

Implication:
Fuel oil suppliers: Are expected to include information within their bunker delivery note (BDN) (as per Appendix V of MARPOL, Annex VI) for all the fuel oil delivered to and used on board a ship for MARPOL compliance.

In case of a gas or low-flashpoint fuel, the BDNs need not include all the information required of marine fuel oil, but are required to provide at least the following:

Name and IMO Number of the receiving ship.
Port.
Date of commencement of delivery.
Name, address, and telephone number of fuel oil supplier.
Product name(s);
Quantity in metric.
Density as determined by a test method appropriate to the fuel type together with the associated temperature.
Declaration signed and certified by the fuel oil supplier’s representative that the fuel oil meets the applicable sulphur content, does not cause an engine to exceed the applicable NOx limits; does not contain inorganic acid, does not jeopardise the safety of the ship or adversely affect the performance of machinery, and is not harmful to personnel or contribute overall additional air pollution; and
Documentation of the actual sulphur content as determined by a test method appropriate to the fuel type, or with the agreement of the appropriate authority at the port of supply, a statement that the sulphur content, when tested, is less than 0.001% m/m.

Shipowners: must ensure that the bunker delivery note includes information for all the fuel oil that is to be carried onboard ships whether consumed or not to comply with regulation 18. Ships with gas or low-flashpoint fuels are to ensure the minimum information (as stated above) is included within the BDNs.

Application: All ships, including offshore units.

Entry into force 1 October 2025

Amendments to regulations A-1 and B-2 of the BWM Convention on the use of electronic record books

Background: Regulation B-2.1 of the BWM Convention provides for the record book to be electronic. However, there is no associated guidance to support this to ensure a harmonised approach with the MARPOL Annexes and the NOx Technical Code. To assist in harmonising the approach to electronic record keeping, MEPC 80 adopted Guidelines for the use of electronic record books under the Ballast Water Management Convention (MEPC.372(80)).

MEPC 81 adopted amendments to the BWM Convention to mandate the harmonised approach to electronic record keeping. The amendments include:

A definition for the “Electronic Record Book” under Regulation A-1.
Reference to the requirements for an electronic record book to be approved by the Administration, taking into account the necessary guidelines developed by the IMO, under regulation B-2.

Implication:
Shipowners: Those choosing to use electronic record books for compliance with the Ballast Water Management Convention, are to follow the Guidelines for the use of electronic record books under the BWM Convention. Furthermore, when a shipowner chooses to use a BWRB in an electronic format, the BWM Convention mandates the approval of that electronic record book.

Application: All ships designed to carry ballast water operating on international voyages between two ports of different countries.

Entry into force 1 January 2026

Amendments to the LSA Code – single fall and hook systems with on-load release capability

Background: Lifeboats and rescue boats with single fall and hook systems face a similar risk of potential accidental release during recovery operations as those with twin fall and hook systems. As these systems are used and tested in a similar way as twin fall lifeboats, they should have similar safety standards. Having discussed the issue, the IMO has now adopted amendments to paragraphs 4.4.7.6.8 and 4.4.7.6.17 of the LSA Code in order to ensure adequate safety standards for lifeboats and rescue boats fitted with single fall and hook systems.

Implication:
Life-saving appliance manufacturers: Requirements are updated for all new installations of lifeboats and rescue boats with a single fall and hook system. The amendments require that:
(4.4.7.6.8) to prevent accidental release during recovery of the boat, the hook shall not be able to support any load unless the hook is completely reset. In the case of a hook which is capable of releasing the lifeboat or rescue boat with a load on the hook when it is not fully waterborne, the handle or safety pins shall not be able to be returned to the reset (closed) position, and any indicators shall not indicate the release mechanism is reset, unless the hook is completely reset. Additional danger signs shall be posted at each hook station to alert crew members to the proper method of resetting; and (4.4.7.6.17) where a single hook and fall system is used for launching a lifeboat or rescue boat in combination with a suitable painter, the requirements of 4.4.7.6.7 and 4.4.7.6.15 need not be applicable provided that the single fall and hook system does not have the capability to release the lifeboat or rescue boat with a load on the hook when it is not fully waterborne.

Shipyards and Owners: To be aware of the need to comply with the new requirements.

Application: The amendments will enter into force on 1 January 2026. They will apply to lifeboats and rescue boats installed on cargo ships of 500GT and over and passenger ships on or after 1 January 2026, where a single fall and hook system is used for launching them.

The expression “installed on or after 1 January 2026” means:

(b) for ships other than those ships specified in (a) above, all installations of lifeboats or rescue boats with a single fall and hook system, having a contractual delivery date for the equipment to the ship on or after 1 January 2026 or, in the absence of a contractual delivery date to the ship, actually delivered to the ship on or after 1 January 2026.

New SOLAS II-1, Regulation 3-13 (lifting appliances and anchor handling winches)

Background: The IMO has developed new mandatory requirements to cover lifting appliances and anchor handling winches. These consist of amendments to SOLAS and supporting guidelines.

Implication: Lifting appliances that are installed on or after 1 January 2026 will need to:

Be designed, constructed and installed in accordance with the requirements of a classification society recognised by the Administration.
Load tested and thoroughly examined after installation and before being taken into use for the first time and after repairs, modifications or alterations.
Be permanently marked with, and provided with documentary evidence for, the safe working load (SWL).

Lifting appliances that are installed before 1 January 2026 will need to:

Be tested and thoroughly examined, based on MSC.1/Circ.1663 Guidelines for Lifting Appliances and be permanently marked with, and provided with documentary evidence for, the safe working load (SWL) no later than the date of the first Passenger Ship Safety Certificate, Cargo Ship Safety Certificate or Cargo Ship safety Construction Certificate renewal survey on or after 1 January 2026.

Anchor handling winches installed on or after 1 January 2026 shall be designed, constructed, installed and tested to the satisfaction of the Administration, based on MSC.1/Circ.1662 Guidelines for Anchor Handling Winches.

Anchor handling winches installed before 1 January 2026 shall be tested and thoroughly examined, based on MSC.1/Circ.1662 Guidelines for Anchor Handling Winches no later than the date of the first Passenger Ship Safety Certificate, Cargo Ship Safety Certificate or Cargo Ship safety Construction Certificate renewal survey on or after 1 January 2026.

The expression “installed on or after 1 January 2026” means:
.1 for ships the keel of which is laid, or which is at a similar stage of construction on or after 1 January 2026, any installation date on the ship; or
.2 for ships other than those specified in .1, including those constructed before 1 January 2009, a contractual delivery date for lifting appliance or anchor handling winches, or in the absence of a contractual delivery date, the actual delivery date of the lifting appliance or anchor handling
winches to the ship on or after 1 January 2026.

All lifting appliances and anchor handling winches, regardless of installation date, and all loose gear utilised with any lifting appliances and anchor handling winches, are to be operationally tested, thoroughly examined, inspected, operated and maintained, based on the Guidelines developed by
the IMO (MSC.1/Circ.1662 and MSC.1/Circ.1663).

Application: This regulation applies to all lifting appliances, anchor handling winches and loose gear which have a SWL of 1000kg and above. For those lifting appliances with a lower SWL, the Administration is to determine to what extent the lifting appliance should comply with the regulation.

This regulation does not apply to:

Lifting appliances on ships certified as MODUs.
Lifting appliances used on offshore construction ships (pipe/cable laying/repair or offshore installation vessels, including ships for decommissioning work);
Integrated mechanical equipment for opening and closing hold hatch covers; and
Lifesaving launching appliances complying with the International Life-Saving Appliance (LSA) Code.

Amendments to the International Life-Saving Appliance Code – Ventilation of totally enclosed
lifeboats

Background: The report of the investigation into the sinking of the MOL Comfort in the Indian Ocean refers to the discomfort experienced by many crew members in totally enclosed lifeboats. It recommended that further investigation into the issue of the ventilation of totally enclosed lifeboats
should be carried out with a view to improving the thermal loading of occupants in emergency situations.

Implication: Totally enclosed lifeboats will need to be designed and fitted with a means of ventilation to achieve a ventilation rate of at least 5m /h per person for the number of persons the lifeboat is permitted to accommodate and for a period of not less than 24 hours.

Application: This applies to all totally enclosed lifeboats installed on ships on or after 1 January 2029. *

*The expression “installed on or after 1 January 2029” means:
(a) for ships for which the building contract is placed on or after 1 January 2029, or in the absence of the contract, constructed on or after 1 January 2029, any installation date on the ship; or
(b) for ships other than those ships described in (a) above, a contractual delivery date for the equipment to the ship on or after 1 January 2029 or, in the absence of a contractual delivery date, the actual delivery date of the equipment to the ship on or after 1 January 2029.

Amendments to the LSA Code to address the in-water performance of SOLAS adult lifejackets

Background: After the deaths of three seafarers whilst wearing SOLAS lifejackets in favourable environmental conditions, the subsequent enquiries have shown that the current requirements for the design and testing of SOLAS lifejackets do not provide consistent assurance of their in-water performance.

Implication: Equipment manufacturers: Minimum performance standards for SOLAS adult life jackets will be enhanced, necessitating potential modifications to life jacket designs to align with the updated standards The amendments ensure that the lifejacket is designed and tested to turn the body of an unconscious person to a face-up position where the nose and mouth are both clear of the water. Lifejackets meeting the new standards will need to be tested and approved as such in advance of 1 January 2026.

Shipowners/operators and shipyards: When replacing lifejackets on existing ships or sourcing lifejackets for new ships, it should be noted that the lifejackets will need to meet the new performance standards and approved accordingly.

Application: This will apply to new SOLAS adult lifejackets carried onboard cargo ships of 500GT and over and all passenger ships from 1 January 2026.

The new requirements are applicable to new ships for which a building contract is in place or in the absence of a contract, the keel is laid or is at similar stage of construction on or after 1 January 2026. For existing ships, this will be applicable for all adult lifejackets with contractual delivery date or actual delivery date to the ship on or after 1 January 2026.

Amendments to SOLAS Chapter II-2/20 – Fire safety on ships fitted with vehicle, special category,
open and closed ro-ro spaces and weather decks intended for the carriage of vehicles

Background: The IMO has reviewed SOLAS chapter II-2 and associated codes regarding vehicle, special category, ro-ro spaces and weather decks of new and existing ro-ro ships based on the findings of the FIRESAFE II study. It should be noted that the IMO issued the Interim guidelines for minimising the incidence and consequences of fires in ro-ro spaces and special category spaces of new and existing ro-ro passenger ships (MSC.1/Circ.1615), pending changes to SOLAS, to address the risks related to ro-ro passenger ships.

The amendments to SOLAS chapter II-2/20 for ships fitted with vehicle, special category, open and closed ro-ro spaces and weather decks intended for the carriage of vehicles include, but are not limited to.

Individually identifiable smoke and heat detector systems, (including linear heat detectors), for open and closed vehicle ro-ro spaces.
Fire detection and alarm system requirements for weather decks intended for the carriage of vehicles, including a safety distance from vehicle lanes to accommodation spaces, control stations and normally occupied service spaces.
Video monitoring on vehicle spaces, open and closed ro-ro spaces and special category spaces.
Fixed water-based fire-extinguishing systems to protect weather decks primarily using water monitor(s), with nozzles being acceptable for areas which monitors cannot cover. Detailed specifications for nozzles are also included, as well as water supply capacity.
Changes to structural fire protection of ro-ro and special category spaces including the protection for openings which is extended to include access to embarkation and assembly stations, as well as intakes for machinery.
Openings in ro-ro spaces provided with closing devices such as steel A-class ramps and steel A-class doors should be permitted below survival craft and accommodation spaces (including normally occupied service spaces and control stations).
Openings in ro-ro spaces below accommodation spaces, control stations and normally occupied service spaces are permitted when the fire integrity of the ship’s side, including windows and doors, is A-60 within a specified rectangular area (A-0 windows protected by a water-based system may be accepted as equivalent to A-60 windows).

Implication: Shipyards, equipment manufacturers and owners: Equipment installation requirements are updated for both new and existing ships fitted with vehicle, special category, open and closed ro-ro spaces and weather decks intended for the carriage of vehicles. The new requirements will need to be complied with.

Application: The amendments to SOLAS chapter II-2/20 apply to ships constructed* on or after 1 January 2026, fitted with vehicle, special category, open and closed ro-ro spaces and weather decks intended for the carriage of vehicles.

The expression “ships constructed” means ships the keels of which are laid, or which are at a similar stage of construction as defined in SOLAS chapter II-2/1.

Ships constructed before 1 January 2026, including those constructed before 1 July 2012, are also to comply with regulations adopted by resolution MSC.550(108), as follows:

SOLAS II-2/20.4.1.6 regarding requirements for a fixed fire detection and fire alarm system complying with the FSS Code: passenger ships constructed before 1 January 2026, including those constructed before 1 July 2012, shall comply not later than the first survey on or after 1 January 2028.
The requirements of SOLAS II-2/20 paragraphs 4.1.1 through 4.1.4 regarding requirements for a fixed fire detection and fire alarm system complying with the FSS Code shall only apply to passenger ships constructed on or after 1 January 2026. Passenger ships constructed before 1 January 2026, including those constructed before 1 July 2012, shall comply with the requirements of paragraph 4.1.6 and the previously applicable requirements of paragraph 4.1 (Fixed Fire Detection and Alarm Systems).
The requirements of SOLAS II-2/20.4.1.5 regarding requirements for a fixed fire detection and fire alarm system complying with the FSS Code shall apply to cargo ships constructed on or after 1 January 2026. Cargo ships constructed before 1 January 2026, including those constructed
before 1 July 2012, shall comply with the previously applicable requirements of paragraph 4.1 (Fixed Fire Detection and Alarm Systems);
SOLAS II-2/20.4.4 regarding video monitoring: The requirements of paragraphs 4.4.1 and 4.4.2 apply to ships constructed on or after 1 January 2026. Passenger ships with vehicle, special category or ro-ro spaces constructed before 1 January 2026, including those constructed before 1 July 2012, shall comply with the requirements of paragraphs 4.4.1 and 4.4.2 not later than the first survey on or after 1 January 2028.
SOLAS II-2/20.5 regarding structural fire protection and arrangement of openings: Applies to passenger ships constructed on or after 1 January 2026. Passenger ships constructed before 1 January 2026 shall comply with the previously applicable requirements of paragraph 5; and
SOLAS II-2/20.6 regarding fire extinction: The requirements of paragraphs 6.2.1 and 6.2.2 regarding fixed water-based fire-extinguishing system on weather decks intended for carriage of vehicles shall apply to ro-ro passenger ships constructed on or after 1 January 2026. Passenger ships with vehicle, special category or ro-ro spaces constructed before 1 January 2026, including those constructed before 1 July 2012, shall comply with the requirements of paragraph 6.2.3 regarding fixed water-based fire-extinguishing system based on monitors not later than the first survey on or after 1 January 2028.

Amendments to SOLAS Regulation II-2/7.5.5 – Fire protection of control stations and cargo control
rooms on new cargo ships

Background: The IMO adopted amendments to SOLAS regulation II-2/7.5.5 and approved consequential amendments to MSC.1/Circ.1456 with respect to the protection of accommodation and service spaces and control stations where a fixed fire detection and alarm system is required. The following text is added to the protection methods in paragraphs 5.5.1, 5.5.2 and 5.5.3: “and in all control stations and cargo control rooms”. The revised circular was published as MSC.1/Circ.1456/Rev.1 which supersedes MSC.1/Circ.1456 and MSC.1/Circ.1492.

Implication: Shipyards and shipowners will need to comply with the amended SOLAS requirements for protection of accommodation and service spaces and control stations where a fixed fire detection and alarm system is required. As a result, control stations and cargo control rooms on new ships will have to comply with the protection method selected.

Application: The amendments to SOLAS chapter II-2/7.5.5 apply to all new cargo ships of 500GT and over with keels laid or at a similar stage of construction on or after 1 January 2026. The expression a “similar stage of construction” means the stage at which:

construction identifiable with a specific ship begins; and
assembly of that ship has commenced comprising at least 50 tonnes or 1% of the estimated mass of all structural material, whichever is less.

Ships constructed before 1 January 2026 will need to comply with the current requirements of paragraph 5.5.

Amendments to SOLAS chapter II-2 – Provisions to prohibit the use of fire-fighting foams containing
PFOS

Background: The IMO developed amendments to SOLAS chapter II-2 and consequential amendments to other instruments to prohibit the use of fire-fighting foams containing perfluorooctane sulfonic acid (PFOS) due to its toxic nature.

The prohibition applies to both fixed and portable systems as the intent is to prohibit the use of all extinguishing media containing PFOS that can be
used in fire extinguishing systems and equipment. Amendments are also applied to the 1994 (MSC.536(107)) and 2000 (MSC.537(107)) HSC Codes.

Implication: Firefighting foams containing PFOS will be banned, and any substances containing PFOS will need to go to appropriate shore reception facilities.

Equipment manufacturers: are to take note and change the chemical makeup of extinguishing media.
Shipowners and Ship operators: are to comply with carriage ban and remove the PFOS containing extinguishing media from ships to reception facilities ashore.

Application: Applies to new and existing ships not later than the date of the first initial, annual, periodical or renewal survey (for passenger ship safety certificate, cargo ship safety equipment certificate, cargo ship safety certificate and high-speed craft safety certificate), whichever occurs first, after the date of entry into force. Enters into force 1 January 2026.

Amendments to the IGF Code – 2026

Background: The IGF Code is reviewed regularly. These amendments incorporate a number of consolidations and additional new provisions based on the industry’s gained experience.

Implication: The amendments are (but not limited to):

Part A-1

4.2.2 – Necessary reference addition based on the proposed change to 8.4.2 listed below.
5.12.1 – For ships constructed on or after 1 January 2026, clarification as to whether the requirement for “door sill” applies to the outer door (i.e. the door leading to the hazardous area).
6.7.3.1.1 – For ships constructed on or after 1 January 2026, the proposed changes are to improve the design requirements for the pressure relief system of the LNG fuel tanks, ensuring that the pressure relief system is of sufficient capacity when implementing the isolation requirements
specified in paragraph 6.7.2.6 and that fuel tanks shall not be bunkered until the full relieving capacity is restored.
6.9.1.1 – For ships constructed on or after 1 January 2026, new changes to permit utilisation of more than one method in order to control the tank pressure and temperature, e.g. by one of the following methods:
1 reliquefication of vapours.
2 thermal oxidations of vapours.
3 pressure accumulation; or
4 liquefied gas fuel cooling.

7.3.2.1 – For ships constructed on or after 1 January 2026, the formula to calculate the thickness of the piping has been amended to make it clearer.
8.4.1 to 8.4.3 – Changes aimed at addressing the leaks during bunkering operations at the connection between the bunker system and the bunkering manifold and aligning the IGF Code to ISO standard 21593:2019 and ISO 20519:2021. This change is available for early implementation
(subject to the flag Administration’s approval).
9.3.1 – For ships constructed on or after 1 January 2026, fuel supply systems require redundancy and segregation so a leak or failure in one system doesn’t result in an unacceptable loss of power. If there is leakage or failure, Administrations may accept partial reduction in propulsion
capacity from normal.
9.4.7 – For ships constructed on or after 1 January 2026, requires that there is automatic ventilation of the gas supply pipe between the master valve and the double block and bleed valves, and between the double block and bleed valves and the consumer, when the master gas fuel valve
is automatically shut down.
9.4.8 – For ships constructed on or after 1 January 2026, “engine” will be replaced by “gas consumer”.
9.6 – The amendment now specifies that the fuel piping referenced is “Gas” fuel piping.
9.6.1 – Sub-paragraph 1 includes a requirement for purging high pressure systems when the master gas valve is closed. This requirement is not included for low pressure systems. As there is no justification for having the difference, this was deleted.
9.8.1, 9.8.2, 9.8.4 – Changes in determining design pressure of pipes and ducts. Applicable to ships constructed on or after 1 January 2026.
11.3.1 – The fuel preparation room shall, for the purpose of the application of SOLAS regulation II-2/9, be regarded as a machinery space of category A. Applicable to ships constructed on or after 1 January 2026.
11.6.2 – A 5kg portable dry powder fire extinguisher is to be located in the fuel preparation room. For ships constructed before 1 January 2026, this shall be provided not later than the first survey on or after 1 January 2026.
12.5.1 – Interbarrier spaces are now considered Hazardous area zone 0. Applicable to ships constructed on or after 1 January 2026.
12.5.2.1 – Interbarrier spaces are removed from Hazardous area zone 1. Applicable to ships constructed on or after 1 January 2026.
15.4.1.3 – Since the requirements for the liquid level gauging in the IGF Code should be more in line with the IGC Code, additionally to 15.4.1.3.1 and 15.4.1.3.2, liquefied gas fuel tank liquid level gauges may also be:
Closed devices which penetrate the liquefied gas fuel tank, but which form part of a closed system and keep the gas fuel from being released.
Such devices shall be considered as tank connections. A shut off valve, located as close as possible to the tank, should be provided if the closed gauging device is not mounted directly onto the tank.
18.4.1.1.1 – Introduction of “compatibility of maximum possible delivery pressure and vessel’s bunkering line design pressure” as an additional item to agree in writing before any bunkering operation commences.

Application: The application of the amendments is included under each item. In general, they will apply to ships constructed on or after 1 January 2026 which use low-flashpoint fuel, other than ships covered by the IGC Code. Otherwise, they apply to both new and existing ships using low flashpoint fuel.

“Ships constructed on or after 1 January 2026” means those:

for which the building contract is placed on or after 1 January 2026.
in the absence of a building contract, the keels of which are laid, or which are at a similar stage of construction on or after 1 July 2026; or
the delivery of which is on or after 1 January 2030.

Amendments to the IGC Code – High manganese austenitic steel

Background: Following the adoption of MSC.475(102) & MSC.476(102), high manganese austenitic steel is now introduced in the IGC code (Table 6.3 of chapter 6).

Implication: High manganese austenitic steel can now be used – subject to the required conditions specified in MSC.1/Circ.1599/Rev.3 – for the manufacturing of plates, sections and forgings for cargo tanks, secondary barriers and process pressure vessels on ships that comply with the IGC Code.

Application: The amendments apply from 1 January 2026 to ships regardless of their size, including those of less than 500GT, engaged in the carriage of liquefied gases having a vapour pressure exceeding 0.28 MPa absolute at a temperature of 37.8°C and other products, as shown in IGC Code Chapter 19 – Summary of minimum requirements, when carried in bulk.

Amendments to the IGF Code – High manganese austenitic steel

Background: Following the adoption of MSC.475(102) & MSC.476(102), high manganese austenitic steel is now introduced in the IGF code (Table 7.3 of chapter 7) as a new material for construction.

Implication: High manganese austenitic steel can now be used – subject to the required conditions specified in MSC.1/Circ.1599/Rev.3 – for the manufacturing of plates, sections and forgings for fuel tanks, secondary barriers and process pressure vessels on ships that comply with the IGF Code.

Application: The amendments apply from 1 January 2026 to ships which use low-flashpoint fuel, other than ships covered by the IGC Code.

Amendments to SOLAS Chapter II-2 on the reporting of confirmed cases where oil fuel suppliers have
failed to meet the flashpoint requirements specified in SOLAS regulation II-2/4.2.1

Background: The IMO has agreed that the Marine Safety Committee should take a more robust stance on the safety issues related to fuel oil characteristics and incorporate amendments into SOLAS to address these concerns. The SOLAS amendments to Chapter II-2 regulation 4.2.1 have been developed to incorporate the safety requirements for fuel. The proposed amendments to the “Definitions” in Chapter II-2 Regulation 3 do not include reference to the operational processes relating to acceptance of a sample analysis report by the Administration.

Implication:
Oil fuel suppliers: will have to update the Bunker Delivery Notes (BDNs) in accordance with the amended requirements of SOLAS Ch II-2/4.2.1.

Ship operators: should be aware of the requirements placed on oil fuel suppliers to supply BDNs in accordance with the amended requirements of SOLAS Ch II-2/4.2.1.

Contracting Governments: should be aware of the requirements placed on them, or their designated authorities, to inform the relevant organisations and take action, as appropriate, against oil fuel suppliers that have been found to deliver oil fuel that does not comply with the amended requirements of SOLAS Ch. II-2/4.2.1.

Application: The SOLAS amendments will enter into force on 1 January 2026 and apply to all ships using oil fuel which are subject to SOLAS, regardless of the date of construction.

Amendments to SOLAS chapter XIV and related Amendments to the Polar Code

Background: After reviewing the technical analysis of the feasibility and consequences of applying chapters 9 and 11 of the Polar Code to non SOLAS ships, the IMO has published amendments to
SOLAS Chapter XIV together with amendments to the Polar Code. MSC.532(107) amends regulation 2 of SOLAS Chapter XIV (Application) to include non-SOLAS ships and MSC.538(107) adds new chapters 9-1 (Safety of Navigation for NonSOLAS ships) and 11-1 (Voyage Planning for Non-SOLAS ships) to the Polar
Code.

Implication:
Designers, builders, equipment manufacturers, owners and operators of fishing vessels, pleasure yachts and cargo ships with the applicable length or GT operating in polar waters will need to take note of, and comply with, the new requirements from chapters 9-1 (Safety of Navigation for Non-SOLAS ships) and 11-1 (Voyage Planning for Non-SOLAS ships).

Application:
The amendments to SOLAS Ch. XIV will apply to all ships as well as:

Fishing vessels of 24 metres of length overall and above;
Pleasure yachts of 300GTand over not engaged in trade; and
Cargo ships of 300GT and over but below 500GT

Fishing vessels, pleasure yachts and cargo ships, as defined above, which are constructed before 1 january 2026, are to meet the relevant requirements of chapters 9-1 and 11-1 in part I-A of the Polar Code by 1 January 2027.

Fishing vessels, pleasure yachts and cargo ships, as defined above, constructed on or after 1 January 2026, are to meet the relevant requirements of chapters 9-1 and 11-1 in part I-A of the Polar Code by 1 January 2026.

Amendments to SOLAS chapter XIV and related Amendments to the Polar Code

Background: After reviewing the technical analysis of the feasibility and consequences of applying chapters 9 and 11 of the Polar Code to non-SOLAS ships, the IMO has published amendments to SOLAS Chapter XIV together with amendments to the Polar Code. MSC.532(107) amends regulation 2 of SOLAS Chapter XIV (Application) to include non-SOLAS ships and MSC.538(107) adds new chapters 9-1 (Safety of Navigation for Non SOLAS ships) and 11-1 (Voyage Planning for Non-SOLAS ships) to the Polar Code.

Implication: Designers, builders, equipment manufacturers, owners and operators of fishing vessels, pleasure yachts and cargo ships with the applicable length or GT operating in polar waters will need to take note of, and comply with, the new requirements from chapters 9-1 (Safety of Navigation for Non- OLAS ships) and 11-1 (Voyage Planning for Non-SOLAS ships).

Application: The amendments to SOLAS Ch. XIV will apply to all ships as well as:

Fishing vessels of 24 metres of length overall and above;
Pleasure yachts of 300GTand over not engaged in trade; and
Cargo ships of 300GT and over but below 500GT

Fishing vessels, pleasure yachts and cargo ships, as defined above, which are constructed before 1 January 2026, are to meet the relevant requirements of chapters 9-1 and 11-1 in part I-A of the Polar Code by 1 January 2027.

Amendments to SOLAS Chapter V and associated certificates – Mandatory carriage of electronic
inclinometers on container ships and bulk carriers

Background: The loss of containers due to the heavy movement of container ships at sea or the movement of bulk cargoes liable to liquefaction or dynamic separation, have caused incidents in recent years that have resulted in many seafarers losing their lives and the loss at sea of containers with high value contents (notably the loss of over 300 containers from the MSC Zoe in January 2019). Electronic inclinometers help with the operational assessment of ship stability, and they are not considered as critical equipment for the safety of navigation. However, the data they measure, if recorded in the Voyage Data Recorder (VDR), will be helpful in accident investigations. So, MSC 107 adopted amendments to SOLAS Chapter V and associated certificates for the mandatory carriage of electronic inclinometers which are linked to the VDR.

Implication: Shipyards, designers, and owners will need to comply with the new requirements, which apply to new bulk carriers and container ships.

The new requirements will not apply to:

Cargo ships occasionally carrying cargoes in bulk.
General cargo ships carrying containers on deck.

Application: The new regulations will enter into force 1 January 2026 and will be applicable to new bulk carriers and container ships of 3,000GT and above, constructed* on or after this date. The requirements will not apply retroactively to existing container ships and bulk carriers.

*In the context of SOLAS V/2.1, “constructed” means:
A stage of construction where:

the keel is laid;
construction identifiable with a specific ship begins; or
assembly of the ship has commenced comprising at least 50 tonnes or 1% of the estimated mass of all structural material whichever is less.

Amendments 42-24 to the International Maritime Dangerous Goods (IMDG) Code

Background: The IMDG Code is regularly reviewed to take into account new requirements for existing substances or new substances. These amendments are published as Amendment 42-24 and to are included in the 2024 Edition.

Implication: The revisions will add new amendment to the Code and new and/or revised requirements for both new and existing substances.

Such amendments include (but are not limited to):

changes to the definition for “Recycled plastic material”
new definition for “Degree of filling”
amendments to “Classification of articles as articles containing dangerous goods N.O.S.”
new definition for “Explosive or pyrotechnic effect”
new definition for “Metal powders”
amendments to the table under “List of currently assigned organic peroxides in packaging” in the entry for for “DI-2,4-DICHLOROBENZOYL PEROXIDE”
new entries: DIBENZOYL PEROXIDE, 2,5-DIMETHYL-2,5-DI-(tert-BUTYLPEROXY) HEXANE, METHYL ETHYL KETONE PEROXIDE(S) new section in Chapter 2.9.2 Assignment to class 9 – introducing “Sodium ion batteries”
pharmaceutical products (such as vaccines) that are packed in a form ready to be administered, including those in clinical trials, and that contain GMMOs or GMOs are not subject to this Code.
amendments to Chapter 3.2 – Dangerous Goods List
amendments to Chapter 3.3 – Special provisions applicable to certain substances, materials or articles
amendments to Chapter 4.1 – Use of packaging, including intermediate bulk containers (IBCs) and large packaging
amendments to 4.1.6 Special packing provisions for goods of class 2
amendments to Chapter 4.2 – Use of portable tanks and multiple-element gas containers (MEGCs)
amendments to Chapter 5.2 – Marking and labelling of packages including IBCs
amendments to Chapter 5.3 – Placarding and marking of cargo transport units and bulk containers
amendments to Chapter 5.5 – Special provisions
amendments to Chapter 6.1 – Provisions for the construction and testing of packaging (other than for class 6.2 substances)
amendments to Chapter 6.2 – Provisions for the construction and testing of pressure receptacles, aerosol dispensers, small receptacles containing gas (gas cartridges) and fuel cell cartridges containing liquefied flammable gas
amendments to Chapter 6.5 – Provisions for the construction and testing of intermediate bulk containers (IBCs)
amendments to Chapter 6.6 – Provisions for the construction and testing of large packaging
amendments to Chapter 6.7 – Provisions for the design, construction, inspection and testing of portable tanks and multiple-element gas containers (MEGCs)
amendments to Chapter 6.10 – Provisions for the design, construction, inspection and testing of portable tanks with shells made of fibrereinforced plastics (FRP) materials
new entries in Appendix B – Glossary of terms

Application: These amendments to the IMDG Code apply to all ships (including cargo ships of less than 500GT) that carry dangerous goods in packaged form from 1 January 2026. It is possible to apply these amendments prior to that date, subject to the agreement of the flag Administration.

Amendments to the International Code for the Safe Carriage of Grain in Bulk (MSC.23(59)) – loading
conditions

Background: The International Code for the Safe Carriage of Grain in Bulk prescribes three loading conditions for the safe stowage of grain: “filled compartment, trimmed”, a “filled compartment, untrimmed” and a “partly filled compartment”. It has been observed that, in practice, there might
be discrepancies such as when grain is filled up to or above the bottom edge of the hatch end beams, but not to the highest possible level in way of the hatch opening.

Implication: Shipowners and operators of ships carrying grain in bulk should take note of new provisions for loading grain when dealing with “partially filled compartments” and how to calculate the total heeling moment.

Application: It applies to all cargo ships, including those of less than 500GT, carrying grain in bulk from the 1 January 2026.

Amendments to SOLAS V/31 and V/32, and to Protocol I of MARPOL Article V – Reporting on the loss of containers

Background: Following the recurrent loss of containers, and in response to the danger submerged containers pose to shipping, the IMO adopted amendments to SOLAS Chapter V to make the reporting of lost, or the observance of lost, freight containers mandatory through a standardised procedure. In the same context, MEPC 81 also adopted amendments to Article V of Protocol I of the MARPOL Convention.

Implication: The Master of every ship involved in the loss of any number of freight containers is required to report the incident without delay to both the nearest coastal State, any ships in the vicinity and to the Flag State.

The Master of every ship that observes freight container(s) drifting at sea, shall communicate the particulars of such an observation to any ships in the vicinity and to the nearest coastal State.

Application: The regulations apply to any ship carrying one or more containers or observing lost containers. The amendments enter into force 1 January 2026.

Amendments to the 2011 ESP Code – Modifications to the Procedures for approval and certification of
a firm engaged in thickness measurement of hull structures

Background: The amendments will better specify that Administrations can exercise the right to audit a firm conducting thickness measurement of hull structures. The current text in the ESP Code was observed to be unclear on this matter.

Implication: The impact of the proposed changes should be minimal and affect those Administrations which might want to certify a firm for thickness measurement.

Application: This specific amendment should affect Administrations engaged in approval of firms conducting thickness measurement of the hull structures of bulk carriers and oil tankers of 500GT and above.

Amendments to the STCW Code – Prevention and response to violence and harassment, including
sexual harassment, bullying and sexual assault

Background: The Joint ILO/IMO Tripartite Working Group to identify and address seafarers’ issues and the human element recognised the need to tackle bullying and harassment in the maritime sector, including sexual assault and sexual harassment, with the objective of ensuring a safe workplace for seafarers. A new mandatory competence has been developed in the STCW Code, Table A-VI/1-4, on the prevention and response to violence and harassment, including sexual harassment, bullying and sexual assault.

Implication: Seafarers will need to undertake specific training to be considered as competent.

Application: All seafarers.

Amendments to the International Life-Saving Appliance (LSA) Code- Launching appliances using falls
and a winch

Background: The current minimum lowering speed of survival craft and rescue boats, as specified in paragraph 6.1.2.8 of the LSA Code, can be expressed in relation to the launching height. This height refers to the distance from the davit head to the waterline when the ship is at its lightest sea-going condition. However, in recent years, larger cargo ships have been under construction, and the launching heights of certain types of cargo ships are expected to increase in the near future. For instance, a 20,000 TEU containership may have a launching height of 35m, requiring a minimum lowering speed of 1.1 m/s. The new requirements address the minimum and maximum lowering speed of survival craft and rescue boats.

Implication:
Equipment manufacturers: Are to ensure their equipment meets the new requirements which aim to limit the maximum lowering speed of a fully loaded survival craft or rescue boat to 1.3 m/s. Also to be aware that the amendment was adopted specifying that the minimum lowering speed of survival craft and rescue boats should be limited at an appropriate value of 1.0 m/s, when the launching height is more than 30 m.

Owners of cargo ships/ shipyards: To be aware of the new requirements which will enter into force on 1 January 2026.

There will likely be little impact on passenger ships, as they already adhere to a davit height limitation in SOLAS regulation III/24.

Application: The amendments enter into force on 1 January 2026. They will apply to survival craft and rescue boats installed on cargo ships of 500GTand over and passenger ships on or after 1 January 2026.
The expression “installed on or after 1 January 2026” means:

(a) for ships for which the building contract is placed on or after 1 January 2026, or in the absence of the contract, the keels of which are laid or which are at a similar stage of construction on or after 1 January 2026, all installations of the specified type on board those ships; or
(b) for ships other than those ships specified in (a) above, all installations of the specified type, having a contractual delivery date for the equipment to the ship on or after 1 January 2026 or, in the absence of a contractual delivery date to the ship, actually delivered to the ship on or after 1 January 2026.

Amendments to the International Code of Safety for High-Speed Craft, 1994 (1994 HSC Code) Chapter
7 – Provisions to prohibit the use of fire-fighting foams containing PFOS

The prohibition applies to both fixed and portable systems as the intent is to prohibit the use of all extinguishing media containing PFOS that can be used in fire extinguishing systems and equipment. Amendments are also applied to the 1994 (MSC.536(107)) and 2000 (MSC.537(107)) HSC Codes.

Implication: Fire fighting foams containing PFOS will be banned, and any substances containing PFOS will need to go to appropriate shore reception facilities. Suppliers to take note and change the chemical make up of extinguishing media, shipowners to comply with carriage ban and remove the PFOS containing extinguishing media from vessel to reception facilities ashore.

Application: Applies to new and existing ships not later than the date of the first initial, annual, periodical or renewal survey (for passenger ship safety certificate, cargo ship safety equipment certificate, cargo ship safety certificate and high speed craft safety certificate), whichever occurs first, after 1 January 2026.

Amendments to the International Code of Safety for High-Speed Craft, 2000 (2000 HSC Code) Chapter
7 – Provisions to prohibit the use of fire-fighting foams containing PFOS

The prohibition applies to both fixed and portable systems as the intent is to prohibit the use of all extinguishing media containing PFOS that can be used in fire extinguishing systems and equipment. Amendments are also applied to SOLAS chapter II-2 (MSC.532(107)) and 1994 HSC Code (MSC.536(107)).

Implication: Fire fighting foams containing PFOS will be banned, and any substances containing PFOS will need to go to appropriate shore reception facilities. Suppliers to take note and change the chemical make up of extinguishing media, shipowners are to comply with carriage ban and remove the PFOS containing extinguishing media from vessel to reception facilities ashore.

Application: Applies to new and existing ships not later than the date of the first initial, annual, periodical or renewal survey (for passenger ship safety certificate, cargo ship safety equipment certificate, cargo ship safety certificate and high speed craft safety certificate), whichever occurs first, after 1 January 2026.

Amendments to the Fire Safety Systems (FSS) Code – fire safety on Ro-Ro passenger ships (Chapter 7
amendments) and all ships (Chapter 9 amendments)

Background: The IMO has reviewed SOLAS chapter II-2 and the FSS Code with regard to vehicle, special category, ro-ro spaces and weather decks of new and existing ro-ro ships based on the findings of the FIRESAFE II study. It should be noted that IMO issued the Interim guidelines for minimising the incidence and consequences of fires in ro-ro spaces and special category spaces of new and existing ro-ro passenger ships (MSC.1/Circ.1615), pending changes to SOLAS, to address the risks related to ro-ro passenger ships.

The amendments to the FSS Code, chapter 7 provide specifications for fixed water-based fire-extinguishing systems on ro-ro passenger ships fitted with weather decks intended for the carriage of vehicles.

The amendments to the FSS Code, chapter 9/2.3 (Component requirements) and chapter 9/2.4 (Installation requirements) relate to linear heat detectors and positioning of detectors for combined smoke and heat detectors.

The amendments to the FSS Code, chapter 9/2.5 (System control requirements) relate to visual and audible fire signals on ro-ro passenger ships.

Implication: Shipyards and equipment manufacturers: will need to comply with the new requirements.

Application: The amendments to the FSS Code chapter 7 apply to ro-ro passenger ships fitted with weather decks intended for the carriage of vehicles constructed on or after 1 January 2026.

The amendments to the FSS Code chapter 9/2.3 (Component requirements) and chapter 9/2.4 (Installation requirements) apply to ships constructed on or after 1 January 2026.

The amendments to the FSS Code chapter 9/2.5 (System control requirements) apply to ro-ro passenger ships constructed on or after 1 January 2026.

“Ships constructed on or after 1 January 2026” mean ships, the keels of which are laid or which are at a similar stage of construction, on or after 1 January 2026.

Amendments to the resolution MSC.402(96) – Requirements for maintenance, thorough examination,
operational testing, overhaul and repair of lifeboats and rescue boats, launching appliances and
release gear

Background: As a consequence of the agreed amendments to the LSA Code and resolution MSC.81(70) with regard to new ventilation requirements for totally enclosed lifeboats, MSC 108 adopted an amendment to resolution MSC.402(96). This amendment includes the requirement for the examination and check of the ‘ventilation system, where fitted’ for satisfactory condition and operation on lifeboats (including free-fall lifeboats), rescue boats, and fast rescue boats.

Implication:
Authorised Service Providers: Totally enclosed lifeboats will need to undergo satisfactory examination and checks with regard to their ventilation systems as per the new requirements detailed in MSC.535(107). It is not expected that partially enclosed lifeboats, rescue boats and fast rescue boats will be fitted with ventilation systems.

Application: This will apply from 1 January 2026, but given that the new requirements for the ventilation of totally enclosed lifeboats applies to those installed on ships on or after 1 January 2029, it is not expected to be required to take place until such totally enclosed lifeboats are installed.

Revised annex to the International Convention on Standards of Training, Certification and
Watchkeeping for Fishing Vessel Personnel, 1995 (STCW-F)

Background: The International Convention on Standards of Training, Certification and Watchkeeping for Fishing Vessel Personnel (STCW-F), sets certification and minimum training requirements for crews of seagoing fishing vessels with the aim to promote the safety of life at sea and the protection of the marine environment, taking into account the unique nature of the fishing industry and the working environment.
Amendments inter alia include:

Requirements related to the use of simulators
Requirements for medical fitness of fishing vessel personnel
Clarity on when competency under the 1978 STCW Convention may be accepted
An additional option for accepted seagoing service for navigational officer candidates.

Implication: Shipowners of seagoing fishing vessels will need to ensure that personnel serving onboard are suitably qualified under the STCW-F Convention and Code.

Application: Applies to personnel serving onboard seagoing fishing vessels flying the flag of a Party to the STCW-F Convention.

Standards of Training, Certification and Watchkeeping for Fishing Vessel Personnel (STCW-F) Code

Background: The new STCW-F Code contains mandatory provisions to which specific reference is made in the annex to the STCW-F Convention.

These requirements provide the minimum standards required to be maintained by Parties in order to give full and complete effect to the Convention. Also included are standards of competence required to be demonstrated by candidates for the issue and revalidation of certificates of competency under the provisions of the STCW-F Convention. The abilities specified in the standards of competence are grouped, as appropriate, under the following seven functions:

Navigation
Catch handling and stowage
Controlling the operation of the vessel and care for persons on board Marine engineering
Electrical, electronic and control engineering
Maintenance and repair
Radiocommunications at the following levels of responsibility:
Management level
Operational level
Support level.

Implication: Owners of seagoing fishing vessels will need to ensure that personnel serving onboard are suitably qualified under the STCW-F Convention and Code.

Application: Applies to personnel serving onboard seagoing fishing vessels flying the flag of a Party to the STCW-F Convention.

Amendments to SOLAS regulation II-2/4 related to oil fuel parameters other than flashpoint

Background: The amendment adds a new sub-paragraph to SOLAS II-2/4 to ensure that oil fuel delivered to and used on board ships will not jeopardise the safety of ships or adversely affect the performance of the machinery or be harmful to personnel.

Implication:
Oil fuel suppliers: Will need to comply with the new requirements.
Ship managers and crews: Will need to ensure that they order oil fuel that is suitable for the ship and not harmful to personnel.

Application: This amendment to SOLAS will enter into force on 1 January 2026. It applies to all cargo ships of 500GT and over and to all passenger ships.

Entry into force 1 March 2026

Amendments to MARPOL Annex VI establishing the Canadian Arctic Emission Control Area (ECA) for
nitrogen oxides, sulphur oxides and particulate matter

Background: MEPC 82 adopted amendments to MARPOL Annex VI which will give effect to an ECA in the Canadian Arctic for NOx and SOx.
This ECA is comprised of two segments starting at the Yukon mainland at 68.900° North 137.000° West; and ending at the north coast of Hans Island at 80.83183° North 66.45667° West and continuing from the south coast of Hans Island at 80.82144° North 66.45067° West, and ending at the coast of Newfoundland and Labrador at 60.000° North, 64.160° West.

Implication: Shipowners and operators should be aware that for ships ordered for keel laying on or after 1 January 2025 and intending to operate in the ECA will need to install a NOx Tier III engine.

In addition, owners and operators should be aware that from 1 March 2027, the sulphur limit of fuel oil used on board must not exceed 0.10%m/m or to use an alternative compliance method such as an Exhaust Gas Cleaning System.

Application:
NOx requirements: Ships the keels of which are laid or at a similar stage of construction on or after 1 January 2025 which have a marine diesel engine with power output of more than 130kW and operating within the ECA.

SOx requirements: Ships operating in the ECA from 1 March 2027.

Amendments to MARPOL Annex VI establishing the Norwegian Sea Emission Control Area (ECA) for
nitrogen oxides, sulphur oxides and particulate matter

Background: MEPC 82 adopted amendments to MARPOL Annex VI to give effect to an ECA in the Norwegian Sea. This ECA is defined as the same area specified in MARPOL Annex II regulation 13.9.4.

Implication: Shipowners and operators should be aware that for ships with a building contract placed on or after 1 March 2026, keel laying or similar stage of construction on or after 1 September 2026 (in the absence of a building contract) or delivered on or after 1 March 2030 and intending to operate in the ECA will need to install a NOx Tier III engine.

Application: NOx requirements: Ships which have a marine diesel engine with power output of more than 130kW and which will operate in the ECA to which the building contract is placed on or after 1 March 2026;
In the absence of a building contract, the keel of which is laid or which is at a similar stage of construction on or after 1 September 2026; or The delivery of which is on or after 1 March 2030.

SOx Requirements: Ships operating in the ECA from 1 March 2027.

Entry into force 1 January 2028

Amendments to SOLAS – New Regulation II-1/3-4.2 – Emergency towing arrangements for new ships,
other than tankers, of 20,000GT and over

Background: The IMO has agreed a revision to SOLAS chapter II-1, regulation 3-4, which extends the scope of the requirements for emergency towing arrangements to new ships other than tankers of 20,000GT and over. The amended regulation will enter into force on 1 January 2028. The IMO
is currently developing amendments to a number of guidelines to help the industry apply the new regulation.

New supporting guidelines are being developed for ships other than tankers and amendments to MSC.1/Circ.1175/Rev.1 – Revised guidance on shipboard towing and mooring equipment and MSC.1/Circ.1255 – Revised guidelines for owners/operators on preparing emergency towing procedures
are expected.

Implication: New ships will need to be fitted with towing arrangements which must, at all times, be capable of rapid deployment in the absence of main power on the ship and have adequate strength based on the size of the ship and the expected forces during bad weather conditions. The design
and construction and prototype testing of emergency towing arrangements must be approved by the Administration or their Recognised Organisations.

Application: Emergency towing arrangements are to be fitted on ships – other than tankers – of 20,000GT and above, constructed on or after 1 January 2028.
The expression “ships constructed” means ships the keels of which are laid, or which are at a similar stage of construction. In addition, the term “a similar stage of construction” means the stage at which:

construction identifiable with a specific ship begins; and
assembly of that ship has commenced comprising at least 50 tonnes or one per cent of the estimated mass of all structural material, whichever is less.

Adopted by Cape Town Agreement, 2012 and Torremolinos Convention 1977 and Protocol of 1993
(SFV-P/CONF.1)

International Convention for the Safety of Fishing Vessels (Torremolinos Convention) Cape Town
Agreement

Background: The Torremolinos Convention and its 1993 Protocol have not yet entered into force as the entry into force requirements have not beenmet. There have also been some problems with the technical requirements. In order to address these issues, an agreement has been reached which changes the entry into force requirements to 22 States with an aggregate of 3,600 fishing vessels of 24m in length and over and modifies some of the technical provisions. As of 13 November 2024, twenty-two States have become party to the Agreement, but the aggregate number of vessels has not been met. The diplomatic conference in Cape Town, South Africa, in October 2012 agreed that the survey and certification requirements were amended to a five-year cycle. A phased-in application for some parts of the requirements for existing fishing vessels was also agreed.

Implication:
Shipowners and Ship Managers: The Protocol has requirements covering the following areas:

Construction, watertight integrity and equipment
Stability and associated seaworthiness
Machinery and electrical installations and periodically unattended machinery spaces
Fire protection, detection, extinction and firefighting
Protection of crew
Life-saving appliances and arrangements
Emergency procedures, musters and drills
Radiocommunications
Shipborne navigational equipment and arrangements

When it enters into force these safety items will need to be provided on board fishing vessels. Some of the requirements are applicable to existing fishing vessels as well as to new construction.

It should be noted that some flag Administrations have already enacted the Torremolinos Convention and Protocol, so fishing vessels flagged with these Administrations will find that nothing will change following entry into force of these amendments.

Shipbuilders / Designers of fishing vessels will need to ensure that the regulations are complied with. This may require additional or different safety equipment to be provided.

Flag Administrations and their Recognised Organisations will have to survey new and existing fishing vessels to the extent required and issue appropriate certification.

Application: The Torremolinos Convention and Protocol is, in general, applicable to fishing vessels of 24 metres in length and over.
Although the majority of the requirements are applicable only to new ships, the following are also applicable to existing ships:

Life-saving appliances and arrangements – only regulation 13 ‘Radio life-saving appliances’ and regulation 14 ‘Radar transponders’
Emergency procedures, musters and drills
Radiocommunications
Shipborne navigational equipment and arrangements

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