Future IMO and ILO Legislation - Passenger and Ro-Ro Passenger Ships

Autumn 2024 – Upcoming changes to mandatory statutory regulations and instruments

Including adopted amendments entering into force on or after 1 November 2024, requirements which have entered force but are phasing in for some ships, and significant
developments up to and including the Marine Environment and Protection Committee (MEPC 82) in October 2024.
 How to use this document
4. If there is a shipbuilding delay after contract signing, it is important to note that most
IMO requirements apply based on the keel laying date and some also have a delivery
date requirement, so a delay may necessitate different equipment or design.
Adopted future IMO and ILO legislation 5. Some requirements only apply to certain operational choices, such as geographical
trading area or activities which may or may not be carried out. In these cases, the
Part 1 – Adopted requirements in a transitional period for full application widest possible applicability is shown in the tables, and it is necessary to assess
This part includes requirements that have already entered into force but are still in a whether the requirement applies to an individual ship.
transitional period for their full effect due to a phased approach to their application. For
example, some parts of a requirement may apply on different dates depending on the Further information from Lloyd’s Register
type and size of ship.
As well as this document, we publish reports of IMO meetings which are relevant to
Part 2 – Adopted requirements entering into force in future Lloyd’s Register(LR). To register to receive these by email, and to download previous
This part includes requirements that have been adopted and have an entry into force documents, please visit www.lr.org/imo .
date which has been established by the IMO or ILO, but which has not yet been reached.
It also covers requirements that have been adopted but have no certain entry into force When clicking on resolutions like below, it will take you to Regs4ships, a subscription
date because the conditions for entry into force have not been met. service from OneOceanLR .

In development future IMO and ILO legislation

Part 3 – IMO and ILO requirements still under development
This part covers requirements that are still under discussion at the IMO and have not
been adopted. The entry in force date has not been agreed although a predicted entry
into force is suggested. This section is subject to change as discussions progress.
Further details of Regs4ships can be found below
Part 4 – Prospective IMO and ILO requirements
This part covers potential requirements due to be considered at the IMO and ILO.

Notes
1. Non-mandatory legislation is not included.
2. In the Application section for each entry, references to ’all ships’ should be taken to
mean all ships to which that convention, annex or chapter applies, which might include
other ships types to those listed in the tables. It is also assumed that ships are engaged
on international voyages.
3. SOLAS amendments now follow a four-year cycle (next entry into force date is 1
January 2028) unless adopted under conditions of exceptional circumstance (see IMO Regs4ships provides uninterrupted access to live and archived regulatory publications –
Circular MSC.1/Circ.1481) in which case implementation may be earlier e.g. due to the covering not just IMO content but multiple sources, including the ILO and numerous
effects of the Coronavirus pandemic an additional entry into force date of 1 January flag States.
2026 for amendments to SOLAS and associated IMO instruments has been agreed.

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Table I – All NEW and EXISTING SHIPS – Adopted amendments coming into effect
Item Number
Prior to 1 November 2024 188/264* 341 342 370 373* 377* 368 350 365 366 403 518
23 December 2024 ILO0006 ILO0008 ILO0009 ILO0011 ILO0013
1 January 2025 570 571 689 690
1 February 2025 543
26 June 2025 155
1 August 2025 466 611 656
1 October 2025 612
1 January 2026 379 383 395 406 409 413 431 446 449 525 532 573 585 658 661 676
1 March 2026 770 771
1 January 2028 442

Table II – All NEW and EXISTING SHIPS – Likely amendments coming into effect
______________________ Item Number
Expected 1 March 2027 467 613 731
Expected 30 March 2027 750
Expected 1 April 2027 813
Expected 1 September 2027 378
Expected 1 January 2028 589 606 642 708 721 728 807 808
Expected 1 March 2028 828
Expected 1 March 2029 572
Expected 1 June 2031 637
Expected 1 January 2032 497 586
Expected other 823
Proposed IMO / ILO work 566 608 610

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Part 1
Adopted IMO and ILO requirements in a transitional period
This part includes requirements that have already entered into force but are still in a transitional period for their full effect due to a phased approach
to their application. For example, some parts of a requirement may apply on different dates depending on the type and/or size of ship.

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 188+264* Amendments to Chapter 4 of MARPOL Annex VI: Regulation 24 – Phase 2 Implementation of Energy
Efficiency Design Index (EEDI)
Adopted by
MEPC.203(62) Background: EEDI requirements were adopted within MARPOL Annex VI to promote more efficient new ships to reduce CO2 emissions from new
ships. EEDI implementation has a phased increase in the value of reduction factors from the reference value defined in MARPOL Annex VI, Regulation
(MEPC.203(62) has 24.3.
been further amended by
EEDI reflects the amount of CO2 generated per tonne-mile (cargo carrying capacity). It provides a uniform approach to calculating a ship’s energy
MEPC.251(66), efficiency during its design and construction and it promotes efficient ship design.
MEPC.301(72) and Table - Shows the reduction factor as a percentage for the Required EEDI compared to the EEDI Reference line for Phase 2 implementation. The
MEPC.324(75) all of Phase 2 (Tranche 2) requirements were effective from 1 January 2020 for the listed ship types and sizes. The Table also shows those ship types whose
which have been Phase 2 (Tranche 1) implementation ended on 31 March 2022. Note that additional amendments to EEDI for Phase 3 (Tranche 1 & 2) implementation
consolidated by of the listed ship types have been adopted by Resolution MEPC.324(75). The Phase 3 (Tranche 1) requirements were effective from 1 April 2022, while
MEPC.328(76)) Phase 3 (Tranche 2) requirements will be effective from 1 January 2025 and further details of Phase 3 implementation can be found in item 373.

Ship Type Size (DWT) Phase 2 Phase 2

Entry into force
1-Jan-20 – 31-Mar-22 1-Jan-20 – 31-Dec-24
1 January 2013
Bulk carrier 20,000 DWT and above 20
Class News 10,000 and above but less than 20,000 DWT 0-20*
No. 18/2018 15,000 DWT and above 20
Gas carrier 10,000 and above but less than 15,000 DWT 20
2,000 and above but less than 10,000 DWT 0-20*
Tanker 20,000 DWT and above 20
4,000 and above but less than 20,000 DWT 0-20*
200,000 DWT and above 20
120,000 – 200,000 DWT 20
Container ship 80,000 – 120,000 20
40,000 – 80,000 DWT 20
15,000 – 40,000 DWT 20
10,000 – 15,000 DWT 20
General Cargo ships 15,000 DWT and above 15
30,000 – 15,000 DWT 0-15*
Refrigerated cargo carrier 5,000 DWT and above 15
3,000 and above but less than 5,000 DWT 0-15*

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 Combination carrier 20,000 DWT and above 20
4,000 and above but less than 20,000 DWT 0-20*
Ro-ro cargo ship (vehicle carrier)** 10,000 DWT and above 15
LNG Carrier** 10,000 DWT and above 20
Ro-ro cargo ship** 2,000 DWT and above 20
1,000 and above but less than 2,000 DWT 0-20*
Ro-ro passenger ship** 1000 DWT and above 20
250 and above but less than 1,000 DWT 0-20*
Cruise passenger ship** 85,000 GT and above 20
having non-conventional propulsion 25,000 – 85,000 GT 0-20*
* Reduction factor to be linearly interpolated between the two values dependant upon ship size. The lower value of the reduction factor is to be
applied to the smaller ship size.
** Reduction factor applies to those ships delivered on or after 1 September 2019, as defined in paragraph 2.1 of regulation 2.

Implication:
Shipbuilders and Designers: Ships will need to be designed and constructed to reduce CO2 emissions. There are several ways to achieve this which
include:
• Increase ship size: engine power ratio
• Reduce lightship weight
• Innovative solutions (e.g. air bubble – friction reduction)
• Optimise propeller efficiency
• Hydrodynamics improvement
• Speed reduction
• Use of renewable power source (e.g. wind, solar power)
• Low carbon fuels (e.g. LNG)
• Energy saving devices (e.g. WHR, shaft generators)

Shipowners and Ship Managers: There are several technical and operational measures that can be considered to reduce GHG emissions. Any EEDI
assessments carried out by designers in the initial and final design stages for above mentioned new ships are to adopt the latest reduction factor
requirements as per the table above.
Owners/Managers, if considering a major conversion of an existing ship will need to assess if the ship will be considered as a new ship following
conversion.

Application: Bulk Carriers, Combination Carriers, Containerships, Cruise Passenger Ships with non-conventional propulsion, Gas Carriers, General
Cargo Ships, LNG Carriers, Ro-ro Cargo Ships, Ro-ro Cargo (vehicle carrier) Ships, Ro-ro Passenger Ships, Refrigerated Cargo Carriers and Tankers all

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 of which are new ships as defined in Regulation 2.2.18 of MARPOL Annex VI, new ships which undergo major conversion or are new or existing ships
which undergo major conversion that is so extensive that the ship is regarded by the Administration as a newly-constructed ship.

According to UIs in MEPC.1/Circ.795/Rev.9, for the purpose of EEDI application, a new ship is a ship:
• For ship types where Phase 2 ends on 31 March 2022:
.1 the building contract of which is placed in Phase 2, and the delivery is before 1 April 2026; or
.2 the building contract of which is placed before Phase 2, and the delivery is on or after 1 January 2024 and before 1 April 2026; or
in the absence of a building contract:
.3 the keel of which is laid or which is at a similar stage of construction on or after 1 July 2020 and before 1 October 2022, and the delivery is
before 1 April 2026; or
.4 the keel of which is laid or which is at a similar stage of construction before 1 July 2020, and the delivery is on or after 1 January 2024 and
before 1 April 2026.

• For ship types where Phase 2 ends on 31 December 2024:

.1 the building contract of which is placed in Phase 2, and the delivery is before 1 January 2029; or
.2 the building contract of which is placed before Phase 2, and the delivery is on or after 1 January 2024 and before 1 January 2029; or in the
absence of a building contract:
.3 the keel of which is laid or which is at a similar stage of construction on or after 1 July 2020 and before 1 July 2025, and the delivery is before 1
January 2029; or
.4 the keel of which is laid or which is at a similar stage of construction before 1 July 2020, and the delivery is on or after 1 January 2024 and
before 1 January 2029.

A “major conversion” means a conversion of a ship:

• which substantially alters the dimensions, carrying capacity or engine power of the ship;
• which changes the type of the ship;
• the intent of which in the opinion of the Administration is substantially to prolong the life of the ship;
• which otherwise so alters the ship that, if it were a new ship, it would become subject to relevant provisions of the present Convention not
applicable to it as an existing ship; or
• which substantially alters the energy efficiency of the ship and includes any modifications that could cause the ship to exceed the applicable
required EEDI or the applicable required EEXI.

Related Instruments
• MEPC.1/Circ.850/Rev.3 - Guidelines for determining minimum propulsion power to maintain the manoeuvrability of ships in adverse
conditions.
• MEPC.231(65) – 2013 Guidelines for calculation of reference lines for use with the Energy Efficiency Design Index (EEDI).
• MEPC.233(65) – 2013 Guidelines for calculation of reference lines for use with the Energy Efficiency Design Index (EEDI) for cruise passenger
ships having non-conventional propulsion.
• MEPC.364(79) - 2022 Guidelines on the method of calculation of the attained Energy Efficiency Design Index (EEDI) for new ships.

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 • MEPC.365(79) - 2022 Guidelines on survey and certification of the Energy Efficiency Design Index (EEDI), as amended by MEPC.374(80).
• MEPC.1/Circ.896 - 2021 Guidance on treatment of innovative energy efficiency technologies for calculation and verification of the attained
EEDI and EEXI.
• MEPC.1/Circ.795/Rev.9 - Unified Interpretations to MARPOL Annex VI

341 Amendments to SOLAS II-1/1 and II-1/8-1.3 requiring the provision of computerised stability support
for the master in case of flooding
Adopted by
MSC.436(99) Background: Amendments to SOLAS chapter II-1 to require the provision of a computer, able to carry out damage stability calculations on existing
passenger ships, were considered to be necessary to support the master in the case of flooding.
Entry into force
SOLAS chapter II-1/1 makes it clear which regulations are applicable to “new” and “existing” ships. Regulation II-1/8-1 has been amended to include a
1 January 2020 requirement for crews onboard existing passenger ships to have the capability to assess stability after damage, either onboard or with onshore
assistance. New passenger ships (keels laid on or after 1 January 2014) are already required to provide this.

Implication: Existing passenger ships will have to be provided with suitable stability support. Obtaining the data needed for developing the hull
model could be challenging and owners are recommended to start considering what is needed at the earliest opportunity. Loading instruments
which comply with IACS UR L5 (Rev.4 June 2020) Type 4 Stability Software will meet these requirements.

Application: Passenger ships constructed before 1 January 2014 of 120m or more in length or with three or more main fire zones are to comply from
the first Passenger Ship Safety Certificate renewal survey after 1 January 2025.

Related Instruments
• MSC.1/Circ.1589 - Guidelines on operational information for masters in case of flooding for passenger ships constructed before 1 January
2014

342 Amendments to MARPOL Annexes I, II, V and VI and the NOx Technical Code 2008 - Use of electronic
record books
Adopted by
MEPC.314(74) Background: The IMO periodically reviews the administrative provisions of mandatory requirements and considers ways to make these more
efficient.
MEPC.316(74)
MEPC.317(74) Amendments to MARPOL Annexes I, II, V and VI and the NOx Technical Code 2008 have been adopted which allow the use of electronic record books
as an alternative to hard copy record books when complying with the record keeping requirements of MARPOL Annexes I, II, V and VI and the NOx
Entry into force Technical Code 2008.
1 October 2020
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 Implication: Companies have the option to use electronic recording systems approved by the Administration to comply with the record keeping
Class News requirements of MARPOL Annexes I, II, V and VI and the NOx Technical Code 2008. The electronic records generated and retained by the system are
No. 17/2020 currently required to be presented in the form of records required by the MARPOL Annexes.

To be used as an alternative, the electronic recording system is required to be approved by the Administration and electronic records generated and
retained by the system should be presented so that the records match the format defined in the relevant MARPOL Annexes. Any electronic system
considered to conform to the criteria for approval should be provided with a written declaration from the Administration. The declaration should be
carried on board the ship for the purpose of statutory surveys or inspections.

For those ships required to keep an ozone-depleting substances record book, the electronic recording system shall only be considered an electronic
record book if the system is approved by the Administration on or before the first IAPP renewal survey carried out on or after 1 October 2020, but not
later than 1 October 2025.

Application: All ships using electronic record books to comply with the record-keeping requirements of MARPOL Annexes I, II, V and VI and the NOx
Technical Code 2008.

Related Instruments
• MEPC.312(74) – Guidelines for the use of electronic record books under MARPOL

370 Amendments to regulations 2 and 14 and appendix VI of MARPOL Annex VI with regard to the in-use
sampling points, including corresponding amendments to the supplement to the IAPP certificate
Adopted by
MEPC.324(75) Background: The IMO had previously concluded sampling guidelines for fuel in use (MEPC.1/Circ.864), but without specifying the actual
requirements for a ship to have such a sampling point in MARPOL. These amendments introduce such requirements for procedures for sampling and
verification of the sulphur content of fuel oil including those requirements for in-use fuel oil sampling points.
Entry into force
1 April 2022 The amendments concerning sampling points consist of the following parts:
• MARPOL Annex VI regulation 2; a new definition in regulation 2 on low flashpoint fuel, for which sampling points will be exempted.
Class News
• MARPOL Annex VI regulation 14; Requirements on in-use fuel oil sampling points.
No. 21/2024
Implication:
Ship designers: are to ensure that the suitable installation or sampling point arrangements are considered in the design of the vessel, for availability
to carry out in-use fuel oil sampling in order to comply with the requirements of MARPOL Annex VI, Regulation 14.
Owners and/or Operators: are to arrange for in-use fuel oil sampling points to be installed or designated (in accordance with
MEPC.1/Circ.864/Rev.1) and ensure the arrangement is described in either a piping diagram or other relevant documents and made available for
survey.

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 Application: Sampling point(s) are to be fitted or designated for the purpose of taking representative samples of the fuel oil being used on board the
ships as follows:
• All new ships constructed on or after 1 April 2022. “Ships constructed” means ships the keels of which are laid or that are at a similar stage of
construction.
• All existing ships (i.e. ships constructed before 1 April 2022) will be required to comply at the first renewal survey of the IAPP certificate on or after
1 April 2023.

Related Instruments
• MEPC.1/Circ.864/Rev.1 - 2019 Guidelines for on board sampling for the verification of the sulphur content of the fuel oil used on board ships

373* Amendments to Chapter 4 of MARPOL Annex VI: Regulation 24 - Phase 3 Implementation of Energy
Efficiency Design Index (EEDI)
Adopted by
MEPC.324(75) Background: Amendments to the time period and the reduction rates for EEDI phase 3 requirements for certain ship types and sizes as shown in the
table below have been adopted. The implementation of Phase 3 EEDI reduction factor requirements (Table 1 of Regulation 24, MARPOL Annex VI) has
Since consolidated into
been divided in two stages or ‘Tranches’. The Phase 3 (Tranche 1) requirements entered into force from 1 April 2022 (for Gas carriers of 15,000 DWT
MEPC.328(76) and above, Container ships, General cargo ships, LNG carriers, Cruise passenger ships having non-conventional propulsion) and the Phase 3 (Tranche
2) requirements enter into force on 1 January 2025, as shown in the below Table.
Entry into force
1 April 2022 Table
Ship Type Size (DWT) Phase 3 (Tranche 1) Phase 3 (Tranche 2)
1-Apr-22 onward 1-Jan-25 onwards

Bulk carrier 20,000 DWT and above 30

10,000 and above but less than 20,000 DWT 0-30*
Gas Carrier 15,000 DWT and above 30 30
10,000 and above but less than 15,000 DWT 30
2,000 and above but less than 10,000 DWT 0-30*
Tanker 20,000 DWT and above 30
4,000 and above but less than 20,000 DWT 0-30*
Container ship 200,000 DWT and above 50 30
120,000 and above but less than 200,000 DWT 45 30
80,000 and above but less than 120,000 DWT 40 30
40,000 and above but less than 80,000 DWT 35 30

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 15,000 and above but less than 40,000 DWT 30 30
10,000 and above but less than 15,000 DWT 15-30* 0-30*
General Cargo ship 15,000 DWT and above 30 30
3,000 and above but less than 15,000 DWT 0-30* 0-30*
Refrigerated cargo carrier 5,000 DWT and above 30
3,000 and above but less than 5,000 DWT 0-30*
Combination carrier 20,000 DWT and above 30
4,000 and above but less than 20,000 DWT 0-30*
LNG carrier** 10,000 DWT and above 30 30
Ro-ro cargo ship (vehicle 10,000 DWT and above 30
carrier)**
Ro-ro cargo ship** 2,000 DWT and above 30
1,000 and above but less than 2,000 DWT 0-30*
Ro-ro passenger ship** 1,000 DWT and above 30
250 and above but less than 1,000 DWT 0-30*
Cruise passenger ship** having 85,000 GT and above 30 30
non-conventional propulsion 25,000 and above but less than 85,000 GT 0-30* 0-30*
* Reduction factor to be linearly interpolated between the two values dependent upon ship size. The lower value of the reduction factor is to be
applied to the smaller ship size.
** Reduction factor applies to those ships delivered on or after 1 September 2019, as defined in paragraph 2.1 of regulation 2.

Implication:
Ship designers and builders: Need to consider potential changes to ship/machinery design to reduce GHG emissions, will now happen at a different
date than indicated previously in Table 1 of MARPOL Annex VI Regulation 24 for some vessel types. This requires planning within the design process
as some reduction dates moved earlier to 1 Apr 2022. There are several ways to achieve this, such as:
• Increase ship size: engine power ratio
• Reduce lightship weight
• Innovative solutions (e.g. air bubble – friction reduction)
• Optimise propeller efficiency
• Hydrodynamics improvement
• Speed reductionUse of renewable power source (e.g. wind, solar power)Low carbon fuels (e.g. LNG)
• Energy saving devices (e.g. WHR, shaft generators)

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 For Shipowners and Ship Managers: There are a number of technical and operational measures that can be considered to reduce GHG emissions.
Any EEDI assessments carried out by designers in the initial and final design stages for above mentioned new ships are to adopt the latest reduction
factor requirements as per the table above. Owners/Managers considering a major conversion of an existing ship will need to assess if the ship will be
considered as a new ship following conversion.

Application: Bulk Carriers, Combination Carriers, Containerships, Cruise Passenger Ships with non-conventional propulsion, Gas Carriers, General
Cargo Ships, LNG Carriers, Ro-Ro Cargo Ships, Ro-Ro Cargo (vehicle carrier) Ships, Ro-Ro Passenger Ships, Refrigerated Cargo Carriers and Tankers all
of which are new ships as defined in Regulation 2.2.18 of MARPOL Annex VI, new ships which undergo major conversion or are new or existing ships
which undergo major conversion that is so extensive that the ship is regarded by the Administration as a newly-constructed ship.
According to UIs in MEPC.1/Circ.795/Rev.9, for the purpose of EEDI application, a new ship is a ship: For ship types where Phase 3 commences with 1
April 2022 and onwards:
.1 the building contract of which is placed in Phase 3; or
.2 the building contract of which is placed before Phase 3, and the delivery is on or after 1 April 2026; or
in the absence of a building contract:
.3 the keel of which is laid or which is at a similar stage of construction on or after 1 October 2022; or
.4 the keel of which is laid or which is at a similar stage of construction before 1 October 2022 and the delivery of which is on or after 1 April 2026.
For ship types where Phase 3 commences with 1 January 2025 and onwards:
.1 the building contract of which is placed in Phase 3; or
.2 the building contract of which is placed before Phase 3, and the delivery is on or after 1 January 2029, or
in the absence of a building contract:
.3 the keel of which is laid or which is at a similar stage of construction on or after 1 July 2025; or
.4 the keel of which is laid or which is at a similar stage of construction before 1 July 2025 and the delivery of which is on or after 1 January 2029.
A “major conversion” means a conversion of a ship:
• which substantially alters the dimensions, carrying capacity or engine power of the ship;
• which changes the type of the ship;
• the intent of which in the opinion of the Administration is substantially to prolong the life of the ship;
• which otherwise so alters the ship that, if it were a new ship, it would become subject to relevant provisions of the present Convention not
applicable to it as an existing ship; or
• which substantially alters the energy efficiency of the ship and includes any modifications that could cause the ship to exceed the applicable
required EEDI or the applicable required EEXI.

Related Instruments
• MEPC.1/Circ.850/Rev.3 - Guidelines for determining minimum propulsion power to maintain the manoeuvrability of ships in adverse
conditions
• MEPC.231(65) - 2013 Guidelines for calculation of reference lines for use with the Energy Efficiency Design Index (EEDI)
• MEPC.233(65) - 2013 Guidelines for calculation of reference lines for use with the Energy Efficiency Design Index (EEDI) for cruise passenger
ships having non-conventional propulsion
• MEPC.364(79) - 2022 Guidelines on the method of calculation of the attained Energy Efficiency Design Index (EEDI) for new ships.

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 • MEPC.365(79) - 2022 Guidelines on survey and certification of the Energy Efficiency Design Index (EEDI), as amended by MEPC.374(80).
• MEPC.1/Circ.896 - 2021 Guidance on treatment of innovative energy efficiency technologies for calculation and verification of the attained
EEDI and EEXI.
• MEPC.1/Circ.795/Rev.9 - Unified Interpretations to MARPOL Annex VI

377* Amendments to MARPOL Annex I - Prohibition on the use and carriage for use as fuel of heavy fuel oil
by ships in Arctic waters
Adopted by
MEPC.329(76) Background: To reduce risks of use and carriage of heavy fuel oil (HFO) as fuel by ships in Arctic waters should an accident occur, amendments to
MARPOL Annex I have been adopted which have prohibited the carriage and use of HFO in unprotected fuel tanks from 1 July 2024.
Entry into force
Those ships with protected fuel tanks, or any ship registered in a State which borders the coastline of Arctic waters which has been issued with a
1 November 2022 waiver by its flag Administration, may continue to operate in Arctic waters until 30 June 2029.

Class News
A full prohibition on the carriage and use of HFO takes effect from 1 July 2029.
No. 08/2023
Implication: If a ship has oil fuel tanks which do not comply with regulation 12A of MARPOL Annex 1 or regulation 1.2.1 of Chapter 1, Part II-A of the
Polar Code, the use and carriage of oils, other than crude oils, having a density at 15°C higher than 900 kg/m3 or a kinematic viscosity at 50°C higher
than 180 mm2/s (MARPOL Annex I, Regulation 43.1.2), in Arctic waters has been prohibited since 1 July 2024.

For ships which are required to meet the design requirements in regulation 12A of MARPOL Annex I or regulation 1.2.1 of chapter 1 of part II-A of the
Polar Code, the use and carriage of oils listed in regulation 43.1.2 of MARPOL Annex I (see above) as fuel is permitted until 30 June 2029. From 1 July
2029 those ships are prohibited from carrying or using such oils in Arctic waters as defined in regulation 46.2 of Annex I.

In addition, waivers may be issued by an Administration with a coastline bordering the Arctic, thereby allowing the use and carriage of oils listed in
MARPOL Annex I, Regulation 43.1.2 for ships operating under their flag. Any waivers issued will not apply on or after 1 July 2029.

Shipowners: will not need to undertake cleaning and flushing of tanks or pipelines if prior operations have included the use and carriage of oils listed
in MARPOL Annex I, Regulation 43.1.2.

Application: All ships operating in Arctic waters with the exception of:
• Ships engaged in securing the safety of ships;
• Ships engaged in search and rescue operations; or
• Ships dedicated to oil spill preparedness and response.

Related Instruments
• MEPC.1/Circ.915 - Guidelines on mitigation measures to reduce risks of use and carriage for use of HFO as fuel by ships in Arctic waters

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 368 Amendment to the AFS Convention - Controls on cybutryne
Background: Evidence of the environmental risks from the use of anti-fouling paints that contain cybutryne was submitted to the IMO in February
Adopted by
2019. The evidence was accompanied by a proposal to establish controls on Anti-Fouling Systems (AFS) containing cybutryne. Amendments to
MEPC.331(76) Annexes 1 and 4 to the AFS Convention and the form of the International Anti-fouling System Certificate (IAFSC) to include controls on cybutryne
were adopted.
Entry into force
1 January 2023 Implication: The amendments mean that anti-fouling systems containing cybutryne shall not be applied or reapplied to any ship on or after 1
January 2023. Ships* bearing an AFS that contains cybutryne in the external coating layer of their hulls or external parts or surfaces on 1 January
2023 shall either:
• Remove the anti-fouling system; or
• Apply a coating that forms a barrier to this substance leaching from the underlying non-compliant AFS at the next scheduled renewal of the anti-
fouling system after 1 January 2023, but no later than 60 months following the last application to the ship of an anti-fouling system containing
cybutryne.

Shipowners and Ship Managers: will be required to apply for a survey for the issue of an International AFS Certificate in the amended model form no
later than 1 January 2025. Such a survey should not affect the time available to shipowners and ship managers to comply with the new control
measures in Annex 1 to the AFS Convention.

*Ships except:
- fixed and floating platforms, FSUs, and FPSOs that have been constructed prior to 1 January 2023 and that have not been in dry-dock on or after 1
January 2023;
- ships not engaged in international voyages; and
- ships of less than 400GT engaged in international voyages, if accepted by the coastal State(s)

Application: All anti-fouling systems containing cybutryne and all ships*.

Related Instruments
• MEPC.356(78) – 2022 Guidelines for Brief Sampling of Anti-Fouling Systems on Ships
• MEPC.357(78) – 2022 Guidelines for Inspection of Anti-Fouling Systems on Ships
• MEPC.358(78) – 2022 Guidelines for Survey and Certification of Anti-Fouling Systems on Ships

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 350 Amendments to the International Code of Safety for Ships Using Gases or Other Low-Flashpoint
Fuels (IGF Code) - (Various – including definitions, probability index fv, loading limit, fuel
Adopted by distribution, internal combustion engines, fire protection)
MSC.458(101)
Background: These amendments are intended to improve the application of the IGF Code by taking account of lessons learned so far. Structural
Entry into force requirements do not need to be applied retrospectively to existing ships.
1 January 2024
Implication: Designers and owners constructing ships on or after 1 January 2024 which will use natural gas as fuel (which are not gas carriers)
should be aware of the following requirements for such ships.

Where gaseous fuel pipes pass through enclosed spaces (except fully welded fuel gas vent pipes led through mechanically ventilated spaces), they
must be protected by a secondary enclosure which may be a ventilated duct or a double wall piping system or other system acceptable to the
Administration.

Liquefied fuel pipes must be protected by a secondary enclosure able to contain leakages. However, if the piping system is in a fuel preparation room
or a tank connection space, the Administration may waive this requirement. In addition, where required gas detection is not fit for purpose, the
secondary enclosures must be provided with leakage detection by means of pressure or temperature monitoring systems, or any combination, and
must be able to withstand the maximum pressure that may build up in the enclosure in case of leakage from the fuel piping.

The exhaust system must be equipped with explosion relief systems unless designed to accommodate the worst case overpressure due to ignited gas
leaks or justified by the safety concept of the engine. This requires a detailed evaluation of the potential for unburnt gas in the exhaust system to be
undertaken covering the complete system from the cylinders up to the open end.

Fuel storage hold spaces associated with a type C tank can be considered a cofferdam protecting fuel containment systems from machinery spaces
provided that the type C tank is not located directly above the machinery space or other rooms of similar fire risk, and the minimum distance to the
A-60 boundary from the outer shell of the type C tank or the boundary of the tank connection space is not less than 900mm.

In addition to the above, for all ships using natural gas as fuel which are not gas carriers, irrespective of date of construction, owners and operators
should be aware of the clarification that spaces containing fuel containment systems must be separated from machinery spaces of category A or
other rooms with high fire risk with a cofferdam of 900mm with A-60 insulation, and A-60 divisions without use of a cofferdam are not permitted.

Application: These amendments entered into force on 1 January 2024 and are applicable to all cargo ships of 500GT and over and to all passenger
ships that use natural gas as fuel, (as per SOLAS II-1 Part G) and are subject to the IGF Code, which are not gas carriers.

Most of the amendments apply to ships constructed on or after 1 January 2024 which in this context means:
• ships contracted on or after 1 January 2024; or
• in the absence of a building contract, keel laid on or after 1 July 2024; or

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 • delivered on or after 1 January 2028.

As indicated in the implications section, one amendment applies irrespective of date of construction.

365 Amendments to SOLAS regulation II-1/3-8 - Towing and mooring equipment

Background: The IMO recently published new requirements and issued related guidelines on towing and mooring equipment to improve the safety
Adopted by
of seafarers during mooring and unmooring operations and to counter the increase of dangerous and sometimes fatal incidents.
MSC.474(102)
These new requirements are incorporated in the amendments to SOLAS Regulation II-1/3-8 contained in Resolution MSC.474(102) and came into
Entry into force force on 1 January 2024.
1 January 2024
Implication: Shipowners, shipbuilders, designers, and operators need to consider these regulatory changes and guidelines when finalising any
Class News new build designs. Shipowners and operators need to ensure they have the required maintenance plans, procedures and records in place before
No. 15/2023 these changes come into force.
Shipowners (or ship managers) should establish the following onboard maintenance and inspection procedures:
• Procedures for mooring operations, inspection and maintenance of mooring equipment, including mooring lines.
• Procedures to allow the identification and control of mooring lines, tails and associated attachments.
• Periodic inspection of mooring lines, mooring line tails and associated attachments as part of the onboard maintenance plan or equivalent
maintenance management system.
• Manufacturersʹ criteria for replacement of mooring lines should be available.
• Records of the original design concept, equipment, arrangements and specifications should be available on board.

Normally the above are already covered by the onboard Safety Management System, it is highly recommended that companies review their
procedures, records and forms to ensure the above items have been properly addressed.

For new construction ships, designers and shipbuilders should ensure the supplied documentation provides sufficient information (e.g. technical
data, maintenance manuals, mooring rope specification and certificates) to support owners in developing their maintenance and inspection
procedures.

Ships constructed before 1 January 2007 were not required to comply with SOLAS, Chapter II-1/ 3-8, so may not have the original design concept to
support the development of the new SOLAS maintenance and inspection requirements. In such cases, the following options are available:
• The original design concept could be a mooring arrangement plan or any document that specifies mooring specifications at the time of the ship’s
construction.
• Alternatively, owners may establish the original design concept, including MBLSD (Ship Design Minimum Breaking Load) for mooring based on
the safe working load of mooring equipment provided on board.

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 • If the vessel neither has any mooring documentation nor any safe working load marking on fittings, owners are advised to check the strength of
mooring equipment and their supporting hull structure based on MSC.1/Circ.1175/Rev.1 (or rules applied at the time of construction, such as
IACS Recommendation 10). Owners should also determine MBLSD based on actual capacity of the equipment and their supporting hull structure
on board. In this case, calculations should be submitted to Lloyd’s Register (LR) for appraisal.

Application: The amended regulation II-1/3-8 applies to passenger ships regardless of size and cargo ships of 500GT or over.
The new requirements for existing ships are listed in paragraphs 4 to 6 of this regulation and apply to ships constructed (keel-laid or at a similar stage
of construction) on or after 1 January 2007.
The new requirements for new ships are listed in paragraphs 7 and 8 of this regulation and applicable for ships:
• for which the building contract is placed on or after 1 January 2024; 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 1 July 2024; or
• the delivery of which is on or after 1 January 2027.
New ships (defined in accordance with the above dates), of 3000GT and above, are subject to additional requirements regarding the design of
mooring arrangement and mooring line selection, to ensure occupational safety and safe mooring of the ship.
The maintenance and inspection procedures above are required to be confirmed on board at the time of:
• Initial surveys completed on or after 1 January 2024 for new ships;
• First Cargo Ship Safety Construction or Cargo Ship Safety survey (annual, intermediate or renewal), on or after 1 January 2024, for existing ships;
or
• Passenger Ship Safety renewal survey, on or after 1 January 2024, for existing ships.

All ships are to have their mooring equipment, including lines, inspected and maintained in a suitable condition for their intended purpose.

How LR can support

On an advisory basis, LR may also support owners carrying out calculations to determine the MBLSD for establishing the original design concept,
based on the owner’s available information. These calculations are carried out independently of any subsequent plan appraisal.

Related Instruments
• MSC.1/Circ.1619 - Guidelines on the design of mooring arrangements and the selection of appropriate mooring equipment and fitting for
safe mooring (Design guidelines)
• MSC.1/Circ.1620 - Guidelines for inspection and maintenance of mooring equipment including lines (Maintenance guidelines)
• MSC.1/Circ.1175 - Guidance on shipboard towing and mooring equipment (applicable to ships constructed on or after 1 January 2007 but
before 1 January 2024)
• MSC.1/Circ.1175/Rev.1 - Revised Guidance on Shipboard Towing and Mooring Equipment (applicable to ships constructed on or after 1
January 2024)
• MSC.1/Circ.1362/Rev.2 - Unified Interpretation of SOLAS Chapter II-1

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 366 Amendments to SOLAS Chapter II-1 concerning watertight integrity
Background: The amendments to SOLAS chapter II-1 part B and B-1 (MSC.216(82) and MSC.421(98)) introduced inconsistencies with parts B-1, B-2
Adopted by
and B-4. These arose from the different philosophies behind the probabilistic damage stability assessment and the assumptions made. The
MSC.474(102) probabilistic method does not rely on a single deck (the bulkhead deck) to provide the uppermost watertight boundary. Instead the upper boundary
of the buoyant volume may be used. In theory this does not need to be a single horizontal surface.
Entry into force
1 January 2024 Implication: Amendments to SOLAS Part B-1 and Part B-2, Part B-4 and Part D are summarised below:

Regulation 7-2 – Calculation of the factor si: the changes distinguish between cargo ships' and passenger ships' immersion line and intermediate or
final stage of flooding for the calculation of the factor si, and when to take it as zero.

Regulation 12 – Peak and machinery space bulkheads, shaft tunnels, etc.: For passenger and cargo ships constructed on or after 1 January 2024, the
collision bulkhead may be pierced below the bulkhead deck of passenger ships and the freeboard deck of cargo ships by not more than one pipe to
deal with fluid in the forepeak tank. The pipe is to be fitted with a remotely controlled valve capable of being operated from above the bulkhead deck
of passenger ships and the freeboard deck of cargo ships. Additional valve requirements are also introduced.

Regulation 13 - Openings in watertight bulkheads below the bulkhead deck in passenger ships: Terminology changes where “watertight bulkheads”
are replaced by “watertight boundaries” and general updated references.

Regulation 15 - Openings in the shell plating below the bulkhead deck of passenger ships and the freeboard deck of cargo ships: For ships for which
the building contract was placed on or after 1 January 2020 and constructed before 1 January 2024, gangway, cargo and fuelling ports fitted below
the bulkhead deck of passenger ships and the freeboard deck of cargo ships shall be watertight and in no case be so fitted as to have their lowest
point below the deepest subdivision draught.
For ships constructed on or after 1 January 2024, cargo ports and other similar openings (e.g. gangway and fuelling ports) in the side of ships below
the bulkhead deck of passenger ships and the freeboard deck of cargo ships shall be fitted with doors so designed as to ensure the same
watertightness and structural integrity as the surrounding shell plating. Unless otherwise permitted by the Administration, these openings will need
to open outwards. The number of such openings are to be the minimum compatible with the design and proper working of the ship. In no case are
these openings to be so fitted as to have their lowest point below the deepest subdivision draught.

Regulation 16 – Construction and initial tests of watertight closures: deletion of ash-chutes and rubbish-chutes from paragraph 1.1.

Regulation 17 – Internal watertight integrity of passenger ships above the bulkhead deck: The Guidance notes on the integrity of flooding boundaries
above the bulkhead deck of passenger ships for proper application of regulations II-1/8 and 20, paragraph 1, of SOLAS 1974, as amended (MSC/Circ.541)
can be used for passenger ships for which the building contract was placed on or after 1 January 2020 and constructed before 1 January 2024 when
applying paragraph 1 of this regulation.

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 For ships constructed on or after 1 January 2024, the internal watertight subdivision arrangements to limit the entry and spread of water above the
bulkhead deck is to be in accordance with the design arrangements necessary for compliance with the stability requirements in parts B-1, and B-2, if
applicable. Where pipes, scuppers, electric cables, etc. are carried through internal watertight boundaries that are immersed at any intermediate or
final stage of flooding in damage cases that contribute to the attained subdivision index A, arrangements are to be made to ensure their watertight
integrity.

For ships constructed on or after 1 January 2024, doors in internal watertight subdivision arrangements above the bulkhead deck, and also above the
worst intermediate or final stage of flooding waterlines, shall be capable of preventing the passage of water when immersed in the required range of
positive stability for any damage cases contributing to the attained subdivision index A. These doors may remain open provided they can be remotely
closed from the navigation bridge. They must always be ready to be immediately closed.

Regulation 17-1 – Integrity of the hull and superstructure, damage prevention and control on ro-ro passenger ships - All access from the ro-ro deck
that leads to spaces below the bulkhead deck are to have a lowest point which is not less than 2.5 m above the bulkhead deck. Where vehicle ramps
are installed to give access to spaces below the bulkhead deck, their openings are to be able to be closed weathertight to prevent ingress of water
below and fitted with alarms and open/close indicators on the navigation bridge. The means of closure is to be watertight if the deck is intended as a
watertight horizontal boundary under regulation 7-2.6.
Subject to SOLAS Part B-4, regulations 23.3 and 23.6, the Administration may permit the fitting of particular accesses to spaces below the bulkhead
deck provided they are necessary for the essential working of the ship, e.g. the movement of machinery and stores, and subject to such accesses
being made watertight, fitted with alarms and open/close indicators on the navigation bridge.

Various other regulations are updated (regulation 19, 21, 22, 23 and 42) regarding damage control information, inspections of watertight doors and
operational considerations around watertightness between cargo spaces before and during voyages.

Application: The amendments apply to cargo ships of 500GT and over and to all passenger ships in various ways depending upon the ship type and
construction date, although the amendments are mainly for new ships constructed on or after 1 January 2024, which in this context mean ships:
• for which the building contract is placed on or after 1 January 2024; or
• in the absence of a building contract, the keel of which is laid or which are at a similar stage of construction on or after 1 July 2024; or
• the delivery of which is on or after 1 January 2028.

Related Instruments
• MSC.429(98)/Rev.2 - Revised explanatory notes to the SOLAS chapter II-1 subdivision and damage stability regulations
• MSC.8/Circ.1 -Voluntary early implementation of the amendments to SOLAS regulation II-1/12 adopted by Resolution MSC.474(102)

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 403 Amendments to the International Code of Safety for Ships Using Gases or Other Low-flashpoint
Fuels (IGF Code) regarding the regulation for fuel preparation room fire-extinguishing systems (Part
Adopted by A-1, Ch.11 - Fire Safety)
MSC.475(102)
Background: Potential sources of ignition were identified in fuel preparation rooms. A new requirement is added for fixed fire extinguishing systems
Entry into force in fuel preparation rooms containing pumps, compressors or other potential ignition sources or other potential ignition sources for compliance with
1 January 2024 the provisions of SOLAS regulation II-2/10.4.1.1, taking into account the necessary concentrations/application rate required for extinguishing gas
fires.

Implication: Shipyards and Shipowners: will be required to meet these new requirements for fuel preparation rooms containing pumps,
compressors or other potential ignition sources.

Application: This amendment enters into force on 1 January 2024 and is applicable to all cargo ships of 500GT and above and all passenger ships
constructed on or after 1 January 2024 that use low-flashpoint fuels (as per SOLAS II-1 Part G) and are subject to the IGF Code.
“Ships constructed on or after 1 January 2024” here means:
• ships contracted on or after 1 January 2024; or
• in the absence of a building contract, keel laid on or after 1 July 2024; or
• delivered on or after 1 January 2028.

This does not apply to ships using gas as fuel to which the IGC Code applies.

518 Amendments to MARPOL Annex VI establishing the Mediterranean Sea Emission Control Area for
sulphur oxides and particulate matter
Adopted by
MEPC.361(79) Background: The adoption of the ‘Med SOx ECA’ is intended to reduce ambient levels of air pollution in the Mediterranean Sea as a whole, and in the
Mediterranean coastal States, which will contribute toward substantial benefits to human health and the environment. The regulations include the
Mediterranean Sea as a Emission Control Area for Sulphur Oxides and Particulate Matter.
Entry into force
1 May 2024 Implication: From 1 May 2025 all ships operating in the Mediterranean SOx ECA will:
• Not be able to use fuel onboard with a sulphur content exceeding 0.10% m/m, except when sulphur abatement is also used as an equivalent
method;
• Be required to ensure the sulphur content of the fuel is documented by the supplier; and
• Be required to carry a written procedure detailing how the fuel changeover is to be carried out (only applicable if using separate fuels to comply
with the requirement).

Application: To all ships operating within the Mediterranean Sea SOx Emission Control Area from 1 May 2025.

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Part 2
Adopted IMO and ILO requirements entering into force in the future
This part includes requirements that have been adopted and have an entry into force date which has been established by the IMO or ILO but has not
yet reached that date. It also covers requirements that have been adopted but have no certain entry into force date because the conditions for
ratification have not been met.

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 ILO0006 Amendment to the Code relating to Regulation 1.4 –Recruitment and placement
Background: During the Covid-19 pandemic seafarers travelled to ships after signing the Seafarers’ Employment Agreement, but the employment
Adopted by
didn't materialise, and seafarers were left stranded with serious financial loss as they were unable to activate the insurance to receive compensation.
Amendments of This amendment requires the provision of additional information to seafarers and clarifies the steps necessary for the seafarer to access the means to
2022 to the MLC, address the compensation claim.
2006
Implication:
Entry into force Shipowners: will need to update their procedures to ensure that the seafarer is provided with suitable information on how to make a compensation
23 December 2024 claim prior to or during the process of engagement.

Application: All commercial vessels undergoing voyages outside their flag jurisdiction or outside the declared sheltered waters of their flag State to
Class News
which the MLC, 2006 applies.
No. 18/2024

ILO0008 Amendments to MLC, 2006, relating to Regulation 3.1 – Accommodation and recreational
facilities/Access to shore-based welfare facilities
Adopted by
Amendments of Background: During the Covid-19 pandemic, many seafarers were provided with free internet access to enable them to contact their families and
friends during the crew change crisis. Use of internet and social networking is far more prevalent now than it was when the Convention was drafted.
2022 to the MLC, The amendments provide seafarers with the right to use the internet with charges for the use of the service being reasonable in amount.
2006
Implication:
Entry into force Shipowners: will need to ensure where practicable that seafarers on their ships are provided with internet access, with any associated charges being
23 December 2024 reasonable in amount.

Class News Application: Applies to all commercial vessels undergoing voyages outside their flag jurisdiction or outside the declared sheltered waters of their
No. 18/2024 flag State to which the MLC, 2006 applies.

Related Instruments
• Guideline B3.1.11 – Recreational facilities, mail and ship visit arrangements
• Guideline B4.4.2 – Welfare facilities and services in ports

ILO0009 Amendments to the Code relating to Regulation 3.2 – Food and catering
Background: In the original MLC text the provision of food was provided for free of charge, but water was not. Most shipowners provide free water to
seafarers working onboard their ships, but this makes it clear that water should be provided free of charge. In addition there was concern that meals

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 Adopted by provided were not healthy in their make up.
Amendments of This requires the provision of free drinking water for seafarers and balanced meals.
2022 to the MLC,
Implication:
2006 Shipowners: will be required to provide drinking water free of charge and ensure that the onboard catering departments provide balanced meals.

Entry into force

Application: Applies to all commercial vessels undergoing voyages outside their flag jurisdiction or outside the declared sheltered waters of their
23 December 2024 flag State to which the MLC, 2006 applies.

Class News Related Instruments

No. 18/2024 • Guideline B4.1.3 - Medical care ashore

ILO0011 Amendment to the Code relating to Regulation 4.3 – Health and safety protection and accident
prevention
Adopted by
Amendments of Background: There is an issue, particularly for women seafarers, that the personal protective equipment provided is too big, which makes it difficult
to wear and has the potential to contribute to an increased risk hazard, particularly in enclosed spaces and near rotary machines.
2022 to the MLC, The amendment includes the requirement for appropriately sized personal protective equipment to be provided. This is intended to contribute to a
2006 safer environment and to provide job opportunities to a wider spectrum of people.

Entry into force Implication:

23 December 2024 Shipowners: will have to assess the size of the seafarers on their ships and ensure that there is a range of suitably sized personal protective
equipment on board.
Class News
No. 18/2024 Application: Applies to all commercial vessels undergoing voyages outside their flag jurisdiction or outside the declared sheltered waters of their
flag State to which the MLC, 2006 applies.

ILO0013 Amendments to Appendices

- Appendix A2-I – Evidence of financial security under Regulation 2.5, paragraph 2
Adopted by - Appendix A4-I – Evidence of financial security under Regulation 4.2
Amendments of
2022 to the MLC, Background: The definition of ‘shipowner’ works when considering the living and working conditions onboard a ship but does not work in the
2006 context of an insured person and the name of the shipowner on the financial security certificates. Port State control deficiencies have been issued
because the shipowner on the financial security certificate is not the party named on the Declaration of Maritime Labour Compliance.
The name of the registered owner is to be included in the evidence of financial security if it is different from the shipowner.

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 Entry into force Implication: This makes it clear to port State control officers that the ship’s financial security is compliant with the MLC, 2006, and it should also
23 December 2024 help expedite action in cases of abandonment by clarifying who is responsible.

Class News Application: Applies to all commercial vessels undergoing voyages outside their flag jurisdiction or outside the declared sheltered waters of their
No. 18/2024 flag State to which the MLC, 2006 applies.

570 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
Adopted by seafarers' certificates
MSC.540(107)
Background: As part of the continuing digitisation of the shipping industry it’s important to move certification from paper format to electronic
Entry into force format. The amendment allows seafarers’ certification to be in an electronic form provided minimum information is available to the Administration
1 January 2025 in accordance with the STCW Code.

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

Application: All seafarers.

Related Instruments
• MSC.1/Circ.1665 - Guidelines on the use of electronic certificates of seafarers

571 Amendments to part A of the Seafarers' Training, Certification and Watchkeeping (STCW) Code -
(section A-I/2) – Electronic seafarers' certificates
Adopted by
MSC.541(107) 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.
Entry into force
Implication: This allows seafarers, ship managers and ship masters to keep electronic seafarers’ certificates onboard.
1 January 2025
Application: All seafarers.

Related Instruments
• MSC.1/Circ.1665 - Guidelines on the use of electronic certificates of seafarers

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 689 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
Adopted by
MEPC.381(80) 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
Entry into force
ecological condition and to the particular character of its traffic the adoption of special mandatory methods for the prevention of sea pollution by
1 January 2025 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.
Class News
No. 21/2024
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 pump-room 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.

How LR Can Support Clients

We are authorised to act on behalf of numerous flag Administrations to verify that your vessels comply with MARPOL. Our involvement ranges from
initial plan approval and on-board surveys to annual and renewal surveys to ensure compliance is maintained.

690 Establishment of the date on which regulation 6 of MARPOL Annex V, in respect of the Red Sea
Special Area shall take effect
Adopted by
MEPC.382(80) Background: The Red Sea area was recognised as a Special Area under Annex V (regulation 1.14.4) of MARPOL.

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 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
Entry into force 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
1 January 2025 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
Class News MARPOL Annexes I and V wastes and residues, covering all the ports and terminals within the areas, the Special Area status was agreed.
No. 20/2024
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
comminuted).
• 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.

Further Information
• MARPOL
• Garbage Management guidance document
• Model garbage management plan
• Garbage management FAQ

543 Amendments to the International Ballast Water Management Convention - Amendments to Appendix
II (Form of Ballast Water Record Book)
Adopted by
MEPC.369(80) 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
Entry into force
Convention has been updated to amend the existing version of the BWRB, to include additional information on entries to be included in the BWRB
1 February 2025 and an updated BWRB page.

Class News
Implication:
No. 19/2024
Ship operators: will need to complete and maintain the newly agreed format of the BWRB from 1 February 2025.
No. 04/2024
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.

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 How LR Can Support Clients
Having a ballast water record book (BWRB) onboard is a requirement of the BWM Convention (Reg. B-2). Model BWRBs, which meet the correct
Convention format, can be found as appended to the Model BWMPs in the resources section of the LR Ballast water management pages. Useful
guidance on completion of BWRB entries can be found in BWM.2/Circ.80 - Guidance on ballast water record-keeping and reporting. The IMO
resolution MEPC.369(80) includes amendments to the BWM Convention which change the format of BWRBs, and enters into force on 1 February
2025. See Class News 19/24.

Further Information
• Ballast water management

Related Instruments
• BWM.2/Circ.80/Rev.1 - 2024 Guidance on ballast water record-keeping and reporting.

155 Hong Kong International Convention on the Safe and Environmentally Sound Recycling of Ships,
2009
Adopted by
SR/CONF/45 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.
Entry into force
26 June 2025 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
Class News
environmentally sound manner; and the establishment of an appropriate enforcement mechanism for ship recycling, incorporating certification and
No. 11/2024
reporting requirements.
No. 13/2023
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:
• 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.
• By 26 June 2030 existing ships will have to:
- have an approved and certified Inventory of Hazardous Materials (IHM) onboard;

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 - have a ready for recycling certificate onboard; and
- only be recycled at a ship recycling facility which has a valid Document of Authorisation for Ship Recycling (DASR).

Ship Recycling Facilities:

By 26 June 2025 - ship recycling facilities will have to have a valid DASR.

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.

Further Information
• Ship recycling consultancy
• Inventory of Hazardous Materials

Related Instruments
• MEPC.196(62) - 2011 Guidelines for the Development of the Ship Recycling Plan
• MEPC.210(63) - 2012 Guidelines for Safe and Environmentally Sound Ship Recycling
• MEPC.211(63) - 2012 Guidelines for the Authorization of Ship Recycling Facilities
• MEPC.222(64) - 2012 Guidelines for the survey and certification of ships under the Hong Kong Convention
• MEPC.379(80) – 2023 Guidelines for the development of the Inventory of the Hazardous Materials

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 466 Amendments to regulation 13.2.2 of MARPOL Annex VI on a marine diesel engine replacing a steam
system
Adopted by
MEPC.385(81) 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,
Entry into force
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
1 August 2025 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 instalation 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.

Related Instruments
• MEPC.386(81) - 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
• MEPC.1/Circ.795 - Will be updated at the time the amendments enter force to interpret that for the purpose of regulation 13.2.2 (where at
the time of the replacement the standards in regulation 13 of Annex VI applicable at that time apply to the replacement engine), the
contractual delivery date of the engine to the ship or the actual delivery date (in absence of a contractual date), or if the engine is installed
and tested on or after 6 months from the date relevant to a NOx ECA this test date.

611 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
Adopted by
request the non-anonymised data for its ships to be made public as well as new obligations to report the following data:
MEPC.385(81) • Fuel consumption per consumer both when underway and not underway;

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 Entry into force • Total onshore power supplied;
1 August 2025 • 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.

Related Instruments
• MEPC.346(78) - 2022 Guidelines for the Development of a Ship Energy Efficiency Management Plan (SEEMP), as amended by MEPC.388(81)
• MEPC.348(78) - 2022 Guidelines for Administration Verification of Ship Fuel Oil Consumption Data and Operational Carbon Intensity, as
amended by MEPC.389(81)
• MEPC.1/Circ.913 - Guidance on the application of the amendments to appendix IX of MARPOL Annex VI on inclusion of data on transport
work and enhanced granularity in the IMO Ship Fuel Consumption Database (IMO DCS) as adopted by resolution MEPC.385(81)

656 Amendments to MARPOL Annex VI, regulations 2, 14, and 18 and Appendix I (Low-flashpoint fuels
and other fuel oil related issues)
Adopted by
MEPC.385(81) 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
Entry into force 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.
1 August 2025 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

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 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 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.

612 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
Adopted by
support this to ensure a harmonised approach with the MARPOL Annexes and the NOx Technical Code. To assist in harmonising the approach to
MEPC.383(81) electronic record keeping, MEPC 80 adopted Guidelines for the use of electronic record books under the Ballast Water Management Convention
(MEPC.372(80)).
Entry into force
1 October 2025 MEPC 81 adopted amendments to the BWM Convention to mandate the harmonised approach to electronic record keeping. The amendments
include:
Class News • A definition for the “Electronic Record Book” under Regulation A-1.
No. 04/2024 • Reference to the requirements for an electronic record book to be approved by the Administration, taking into account the necessary guidelines
No. 19/2024 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

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 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.

Further Information
• LR’s Ballast water management

Related Instruments
• MEPC.372(80) - Guidelines for the use of electronic record books under the BWM Convention

379 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
Adopted by
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
MSC.554(108) 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.
Entry into force
1 January 2026 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:
(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 lifeboats or rescue boats with a single fall and hook
system on board those ships; or

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 (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.

383 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
Adopted by
amendments to SOLAS and supporting guidelines.
MSC.532(107)
Implication: Lifting appliances that are installed on or after 1 January 2026 will need to:
Entry into force • Be designed, constructed and installed in accordance with the requirements of a classification society recognised by the Administration.
1 January 2026 • 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).

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 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
• Life-saving launching appliances complying with the International Life-Saving Appliance (LSA) Code.

Related Instruments
• MSC.1/Circ.1663 - Guidelines for Lifting Appliances
• MSC.1/Circ.1662 - Guidelines for Anchor Handling Winches

395 Amendments to the International Life-Saving Appliance Code - Ventilation of totally enclosed
lifeboats
Adopted by
MSC.535(107) 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.
Entry into force
1 January 2026 Implication: Totally enclosed lifeboats will need to be designed and fitted with a means of ventilation to achieve a ventilation rate of at least 5m3/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.

Related Instruments
• MSC.544(107)- Amendments to the Revised recommendation on testing of life-saving appliances (Resolution MSC.81(70))

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 406 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
Adopted by
have shown that the current requirements for the design and testing of SOLAS lifejackets do not provide consistent assurance of their in-water
MSC.554(108) performance.

Entry into force Implication: Equipment manufacturers: Minimum performance standards for SOLAS adult life jackets will be enhanced, necessitating potential
1 January 2026 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 ship yards: 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 absense 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.

409 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
Adopted by
MSC.550(108) 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
Entry into force
(MSC.1/Circ.1615), pending changes to SOLAS, to address the risks related to ro-ro passenger ships.
1 January 2026
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.

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 • 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

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 • 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.

Related Instruments
• MSC.555(108) – Amendments to the FSS Code

413 Amendments to SOLAS chapter II-2 – Provisions to prohibit the use of fire-fighting foams containing
PFOS
Adopted by
MSC.532(107) 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.
Entry into force
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
1 January 2026 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.
Equipment manufacturers: are to take note and change the chemical make up 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.

Related Instruments
• MSC.536(107) - Amendments to the International Code of Safety for High-Speed Craft, 1994 (1994 HSC Code) Chapter 7
• MSC.537(107) - Amendments to the International Code of Safety for High-Speed Craft, 2000 (2000 HSC Code) Chapter 7

431 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.

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 Adopted by Implication: The amendments are (but not limited to):
MSC.551(108)
Part A-1
Entry into force • 4.2.2 - Necessary reference addition based on the proposed change to 8.4.2 listed below.
1 January 2026 • 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 reliquefaction of vapours;
2 thermal oxidation 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 Adminsitration’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.

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 • 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 are 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.

446 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
Adopted by
of chapter 7) as a new material for construction.
MSC.524(106)
Implication: High manganese austenitic steel can now be used – subject to the required conditions specified in MSC.1/Circ.1599/Rev.3 – for the
Entry into force manufacturing of plates, sections and forgings for fuel tanks, secondary barriers and process pressure vessels on ships that comply with the IGF
1 January 2026 Code.

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

Related Instruments
• MSC.1/Circ.1599/Rev.3 - Revised guidelines on the application of high manganese austenitic steel for cryogenic service

449 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
Adopted by
MSC.520(106) 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

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 Entry into force been developed to incorporate the safety requirements for fuel. The proposed amendments to the “Definitions” in Chapter II-2 Regulation 3 do not
1 January 2026 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.

525 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
Adopted by
amendments are published as Amendment 42-24 and to are included in the 2024 Edition.
MSC.556(108)
Implication: The revisions will add new amendment to the Code and new and/or revised requirements for both new and existing substances.
Entry into force
1 January 2026 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

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 • 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 fibre-
reinforced 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.

Related Instruments
• MSC.1/Circ.1588/Rev.3 - Revised emergency response procedures for ships carrying dangerous goods (EmS Guide)

532 Amendments to SOLAS V/31 and V/32, and to Protocol I of MARPOL Article V - Reporting on the loss of
containers
Adopted by
MEPC.384(81) 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
MSC.550(108) procedure. In the same context, MEPC 81 also adopted amendments to Article V of Protocol I of the MARPOL Convention.

Entry into force

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
1 January 2026 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.

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

573 Amendments to the STCW Code - Prevention and response to violence and harassment, including
sexual harassment, bullying and sexual assault
Adopted by
MSC.560(108) 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
Entry into force
violence and harassment, including sexual harassment, bullying and sexual assault.
1 January 2026
Implication: Seafarers will need to undertake specific training to be considered as competent.

Application: All seafarers.

585 Amendments to the International Life-Saving Appliance (LSA) Code- Launching appliances using falls
and a winch
Adopted by
MSC.554(108) 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
Entry into force
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
1 January 2026 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 500GT
and over and passenger ships on or after 1 January 2026.
The expression "installed on or after 1 January 2026" means:

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 (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.

658 Amendments to the Fire Safety Systems (FSS) Code - fire safety on Ro-Ro passenger ships (Chapter 7
amendments) and all ships (Chapter 9 amendments)
Adopted by
MSC.555(108) 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),
Entry into force
pending changes to SOLAS, to address the risks related to ro-ro passenger ships.
1 January 2026
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.

Related Instruments
• MSC.550(108) – Amendments to SOLAS II-2

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 661 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
Adopted by release gear
MSC.559(108)
Background: As a consequence of the agreed amendments to the LSA Code and resolution MSC.81(70) with regard to new ventilation requirements
Entry into force for totally enclosed lifeboats, MSC 108 adopted an amendment to resolution MSC.402(96). This amendment includes the requirement for the
1 January 2026 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.

Related Instruments
• MSC.535(107) Amendments to the International Life-Saving Appliance Code (LSA Code)

676 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
Adopted by
jeopardise the safety of ships or adversely affect the performance of the machinery or be harmful to personnel.
MSC.550(108)
Implication:
Entry into force Oil fuel suppliers: Will need to comply with the new requirements.
1 January 2026 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.

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 770 Amendments to MARPOL Annex VI establishing the Canadian Arctic Emission Control Area (ECA) for
nitrogen oxides, sulphur oxides and particulate matter
Adopted by
MEPC.392(82) 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
Entry into force
Newfoundland and Labrador at 60.000° North, 64.160° West.
1 March 2026
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.

771 Amendments to MARPOL Annex VI establishing the Norwegian Sea Emission Control Area (ECA) for
nitrogen oxides, sulphur oxides and particulate matter
Adopted by
MEPC.392(82) 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.
Entry into force
Implication: Shipowners and operators should be aware that for ships with a building contract placed on or after 1 March 2026, keel laying or
1 March 2026 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.
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 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.

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

442 Amendments to SOLAS - New Regulation II-1/3-4.2 – Emergency towing arrangements for new ships,
other than tankers, of 20,000GT and over
Adopted by
MSC.549(108) 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.
Entry into force
1 January 2028 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.

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Part 3
IMO and ILO requirements currently under development
This part covers requirements that are under discussion and have not been adopted and have no agreed entry into force date. This section is subject
to change as discussions progress.

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 467 Draft amendments to MARPOL Annex VI and the NOx Technical Code on the use of multiple engine
operational profiles for a marine diesel engine
Predicted entry into force
1 March 2027 Background: MEPC 82 approved 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. These draft amendments are expected to be adopted in April 2025 during MEPC 83 for
entry into force in March 2027 when corresponding amendments to MARPOL Annex VI are expected to enter into force.

The amendments to the Code control the use of auxiliary control devices for new and existing engines (that undergo significant modification) and
address defeat devices' intended to circumvent the purpose of the NOx Technical Code. They also facilitate the certification of engines that are
capable of operating in multiple profiles.

The amendments will apply to any engine not certified on or after the date of entry into force.

For existing engines already certified on or after the entry into force of the regulations the amendments will not have an impact unless the engine is
subject to substantial modification on or after the entry into force date.

For existing engines this applied depending on the age of the ship the engine is installed onboard as follows:
• For engines installed on board ships constructed before 1 January 2000 the amendments apply to engines which undergo a substantial
modification.
• For installations on board ships constructed on or after 1 January 2000 the amendments apply to engines which undergo a substantial
modification if an auxiliary control device is used and/ or the engine has multiple operational profiles.

The amendments consider a substantial modification to be (for installations on ships constructed on or after 1 January 2000); any modification to an
engine that could potentially cause the engine to exceed the applicable NOx emission limit in MARPOL Annex VI regulation 13. Routine replacement
of engine components by parts specified in the technical file that do not alter emission characteristics is not considered a "substantial modification"
regardless of whether one part or many parts are replaced.

For installations on ships constructed before 1 January 2000, the amendments consider a substantial modification to be; any modification made to
an engine that increases its existing emission characteristics established by the simplified measurement method described in section 6 of the Code.
These changes include, but are not limited to, changes in its operations or in its technical parameters (e.g. changing camshafts, fuel injection
systems, air systems, combustion chamber configuration, or timing calibration of the engine). The installation of a certified approved method
pursuant to MARPOL Annex VI regulation 13.7.1.1 or certification pursuant to regulation 13.7.1.2 is not considered to be a substantial modification.

The amendments introduce the definition and control of a rational emissions control strategy which aims to ensure that the emissions values at the
individual mode points used during engine certification testing are representative of the emissions values during normal operation. Further, the
amendments require such a rational control strategy to be applied to each engine across the whole of its operating load and speed range therefore
ensuring an engine has not been designed to circumvent the intent of the NTC.

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 Implication:
Engine manufacturers: will need to be aware of the above and consider the impact any upgrades or modifications to existing engines will have on
the need to seek re-certification and the new requirements that may apply.

Shipowners and operators: will need to be aware of the implications and methods for seeking re-certification should their engine go through
substantial modification as described in these amendments.

Application: This is expected to apply to engines with power output of more than 130kW.
These amendments will apply to engines (individual engines or an engine group/family) not certified on or after the expected entry into force of the
amendments in Spring of 2027.

For engines already certified on or after the entry into force date, the draft amendments do not apply, except in the case of substantial modifications.

613 Draft Mid-Term GHG Reduction Measures.

Background: The IMO has agreed a reduction pathway for GHG emissions from the shipping industry to meet the Paris climate target to limit the
Predicted entry into force
increase in the global temperature to 1.5°C by end of the century.
1 March 2027
In this context, the IMO has agreed the 2023 IMO Strategy on Reduction of GHG Emissions from Ships which includes GHG reduction indicative
checkpoints of 20% (by 2030), 70% (by 2040) compared to 2008 levels and an overall target of reaching net-zero by around 2050.

This reduction in emissions is regulated by defined measures for the short-term, mid-term and long-term. The IMO has already adopted measures
(EEXI, CII) to encourage reduction of emissions up until 2027 as short-term GHG reduction measures and it is expected these measures will be refined
to further encourage reduction through to 2030 (See 828).

The IMO is developing mid-term GHG reduction measures to address reduction of emissions beyond 2027 which will consist of a goal based fuel
standard and an economic pricing mechanism on GHG emissions. Whilst the details of both are still being negotiated in the IMO, it has been agreed
that the fuel standard will regulate shipping's GHG intensity measured in grams of CO2 equivalent per mega joule (gCO2/MJ). It is also agreed that
both measures will consider GHG emissions on a well-to-wake basis over a fuel's lifecycle (from feedstock through to consumption on board).

During MEPC 82, a draft legal text was developed which narrows down the architecture of the goal-based fuel standard and sets out options for the
pricing mechanism to be built on in the lead up to MEPC 83 (April 2025) where the regulations are expected to be approved.

Whilst the exact emissions reduction trajectory for the fuel standard is to be agreed, it is understood that the regulations will be framed around the
levels of ambition and indicative check points agreed in the 2023 IMO Strategy on Reduction of GHG Emissions from Ships. This would mean that the
fuel standard would require ships' GHG fuel intensity to reduce by 20% (by 2030), 70% (by 2040) and close to 100% (by 2050) in comparison to 2008
levels.

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 Implication: The measures will have significant impact on both capital and operational expenditure while providing a platform encouraging the
shipping industry to develop and adopt efficient and zero-emission ships and/or fuels to enable the transition at every level of the shipping industry.

Application: Whilst the exact application of the mid-term measures is to be agreed, Early expectation is that they will apply to ships of 5000GT and
over, and at a future date ships of 400GT and over.

731 Draft amendments to the NOx Technical Code with regard to re-certification procedures of existing
engines
Predicted entry into force
1 March 2027 Background: Noting MARPOL Annex VI, regulation 13, permits substantial modifications and therefore re-certification of already installed engines,
these amendments to the NOx Technical Code set out the procedure for such a re-certification which has not previously been specified. These
amendments also capture instances where an existing engine is to be certified to a Tier to which it was not certified at the time of installation in
which case the same procedure is to be followed.

Implication:
Shipowners and operators: Should be aware that any existing marine diesel engine already installed with a power output of more than 130kW
which undergoes modification which alters the NOx parameters, or is to be certified to a NOx Tier it was not certified to at the point of instillation, is
to follow the procedure newly introduced to the NOx Technical Code.

Applicants Seeking re-certification: Should familiarise themselves with the detail of the procedure and be aware that they must prepare an Engine
Emission Test Plan to be agreed by the ship's Administration or Recognised Organisation before the testing regime is conducted. Guidance is
available on the content of the Engine Emission Test Plan which will be published by IMO at the time of the amendments to the Code entering force
(Spring 2027).

Application: This applies to any marine diesel engine with a power output of more than 130kW which undergoes a substantial modification, or is to
be certified to a NOx Tier to which it was not certified at the time of certification, therefore requiring re-certification.

750 Review of the Ballast Water Management Convention

Background: Following the approval of circular BWM.2/Circ.79 Convention Review Plan (CRP) under the experience-building phase associated with the
Predicted entry into force
BWM Convention, MEPC 81 endorsed a list of instruments which require revision and/or development as part of the review of the BWM Convention.
30 March 2027 Work is now proceeding to develop the draft text for a package of amendments to the Convention and its associated guidance. It is anticipated that
draft texts will be available at MEPC 83 in spring 2025.

Implication: Clients should anticipate amendments to the Ballast Water Management Convention and as a result may need to make changes to how
the requirements for compliance with the BWM Convention are met. In particular it is anticipated that amendments will be made to the following

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 sections of the Ballast Water Management Convention:

Regulation A-3 (Exceptions)

• To legally enable the use of contingency measures and challenging water guidance, taking into account the guidelines and guidance developed
by the IMO;
• To allow circumstances when the ship will discharge unmanaged or partially managed ballast water and sediments on the high seas, taking into
account the guidelines and guidance developed by the IMO, due to the ship:
- experiencing challenging water quality at uptake resulting in bypass of its BWMS; and/or
- applying contingency measures due to BWMS failure; and/or
- needing to comply with any port State requirement for ballast water exchange plus treatment.
Regulation B-1 (Ballast Water Management Plans)
• Identifying ships with BWMS that are type approved in accordance with the BWMS Code, as opposed to older versions of the Guidelines (G8);
• Reflecting any important updates made to the standard format of the BWMP (appendix to the Guidelines (G4)) to standardise and improve
consistency;
• Adding a new requirement that ships plan for contingency measures, taking into account BWM.2/Circ.62 (Guidance on contingency measures
under the BWM Convention);
• Adding a new requirement that the BWMPs include a plan for safe ballast water exchange, including partially treated and/or non-neutralised
ballast water;
• Requiring that the BWMP provides the maintenance procedures necessary to keep any BWMS installed in good working order;
• Adding a new requirement that the BWMP include a maintenance schedule that reflects the OEM manual and maintenance schedule; and
• Including the practice of temporary storage of grey water and/or treated sewage in ballast water tanks.
Regulation B-2 (Ballast Water Record Book)
• Adding a new requirement that the location of BWMS maintenance records will be recorded.
Regulation B-6 (Duties of officers and crew)
• Adding a new requirement for crew familiarisation/training with regard to the BWMS and how it should be documented/verified.
Regulation D-2 (Ballast Water Performance Standard)
• Requiring the Maximum Allowable Discharge Concentration (MADC) for BWMS that use active substances, to ensure that in-service ships regularly
discharge effectively neutralised ballast water, for BWMS utilising active substances, in line with the limit set as part of the Final Approval of the
BWMS.
Regulation D-3 (Approval Requirements for ballast water management systems)
• Creating a new requirement that any type-approved BWMS installed on a ship to meet the D-2 standard shall be maintained in good working
order; and
• Creating a new requirement that during type approval BWMS should be verified to not exceed MADC, to ensure that in-service ships regularly
discharge effectively neutralised ballast water for BWMS that use active substances.
Regulation E-1 (Surveys)
• Requiring that annual surveys confirm required maintenance has been undertaken by verifying the Ballast Water Record Book (BWRB), including
any BWMS maintenance log;
• Requiring a biological efficacy test (sampling and analysis) to be undertaken as part of intermediate and renewal surveys;

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 • Creating a new requirement to undertake annual sampling of residual active substances;
• Including testing in line with BWM.2/Circ.70/Rev.1 as part of the renewal and/or intermediate survey;
• Requiring items such as time-bound repair plans, destination State approvals, flag State approvals (dispensation), etc.
Appendix I - (Form of International Ballast Water Management Certificate)
• Amending appendix I to include a supplement with additional information in line with the approach of the IOPP Certificate.

In addition clients should also anticipate amendments to:

• MEPC.300(72) Code for Approval of Ballast Water Management Systems (BWMS Code)
• MEPC.173(58) Guidelines for ballast water sampling (G2),
• MEPC.173(58) Guidelines for ballast water sampling (G2),
• MEPC.370(80) Guidelines for ballast water management and development of Ballast Water Management Plans (G4),
• MEPC.169(57) Procedure for approval of ballast water management systems that make use of Active substances (G9),
• MEPC.252(67) Guidelines for port State control under the BWM Convention
• BWM.2/Circ.42/Rev.2 Guidance on ballast water sampling and analysis for trial use in accordance with the BWM Convention and Guidelines (G2)
• BWM.2/Circ.43/Rev.1 Guidance for Administrations on the type approval process for ballast water management systems
• BWM.2/Circ.62 Guidance on contingency measures under the BWM Convention
• BWM.2/Circ.69 Guidance on System Design Limitations of ballast water management systems and their monitoring
• BWM.2/Circ.70/Rev.1 2020 Guidance for the commissioning testing of ballast water management systems

Finally clients should also expect the development of new guidance covering:
• The operation and maintenance of the BWMS,
• A review process of type approvals for BWMS that do not use active substances,
• Type approving BWMS which have undergone modifications since receiving type approval,
• Information to be included in BWMS Operation Maintenance and Safety Manual (OMSM).and

Work is ongoing to develop the amendments to the relevant instruments of the Convention, with the expectation that the amendments should be
ready for adoption at MEPC 85 (2026) and entry into force in 2027.

Application: The Convention applies to all ships and offshore structures (i.e. vessels of any type operating in the aquatic environment, including
submersibles, floating craft, floating platforms, floating storage units (FSUs) and floating production, storage and offloading (FPSO) units) that load
and discharge ballast.

813 Draft Amendments to Appendix IX to MARPOL Annex VI to include reporting of the period
Background: The amendments to MARPOL Annex VI Appendix IX in MEPC.385(81) do not create a field for the portion of the year the report is made
Predicted entry into force for both regulations 27 (Fuel oil consumption) and regulation 28 (Carbon Intensity).
1 April 2027

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 These draft amendments correct this by introducing such date fields to Appendix IX.

Implication: There is no impact on clients expected as this is effectively a correction to ensure the portion of a year to which the data captured
relates.

Application: All ships of 5000GT and above

Related Instruments
• MEPC.385(81) - Amendments to MARPOL Annex VI - Appendix IX - Accessibility of data and inclusion of data on transport work and
enhanced granularity in the IMO Ship Fuel Consumption Database (IMO DCS)

378 Draft amendments to appendix II (Form of the IOPP certificate and Supplements) and Appendix III
(Form of Oil Record Book) of MARPOL Annex I
Predicted entry into force
1 September 2027 Background: The IMO has agreed a draft MEPC circular on Guidelines for systems for handling oily wastes in machinery spaces of ships incorporating
guidance notes for an integrated bilge water treatment system (IBTS), draft amendments to Appendix II (Form of the IOPP certificate and
Supplements) and Appendix III (Form of Oil Record Book) of MARPOL Annex I, and the draft revised MEPC circular on Guidance for the recording of
operations in the Oil Record Book Part I – machinery space operations (all ships).

At the time these instruments were considered for approval, the IMO discussed the use of forced evaporation of oily bilge water and considered if this
is an accepted means of disposal. It was agreed that such forced evaporation is, in principle, an acceptable means of disposal of oily bilge water and
invited proposals to amend MARPOL Annex I to implement this acceptance.

To date, no such proposals have been submitted to the IMO. Noting the instruments above are to be approved as a package with an amendment to
MARPOL Annex I to confirm acceptance of forced evaporation, it is unclear when this package will progress.

Implication: On completion of this work, regulatory certainty will be provided to the use of forced evaporation of oily bilge water.

The draft IBTS Guidelines are expected to give information to support the mandatory requirements applicable to handling of oily bilge water and oily
residues (sludge).

The draft revised Guidance for recording of operations in the Oil Record Book Part I – Machinery space operations (all ships) are intended to facilitate
compliance with MARPOL requirements by providing advice to crews on how to record the various operations and the amendments focus on
alternative methods of disposal.

The draft amendments to Appendix II and III of Annex I introduce the ability to record alternative methods of disposal of oily bilge water which is
expected to clarify the ability to use forced evaporation.

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 Application: All oil tankers of 150GT or above and all other ships of 400GT or above engaged on international voyages.

589 Draft amendments to Resolution MSC.402(96) - Requirements for maintenance, thorough

examination, operational testing, overhaul and repair of lifeboats and rescue boats, launching
Predicted entry into force appliances and release gear
1 January 2028
Background: Resolution MSC.402(96) was adopted in 2016 with the aim of establishing a consistent, safe, and well-documented standard for
maintaining, thoroughly examining, operationally testing, overhauling, and repairing lifeboats and rescue boats, as well as their launching
appliances and release gear. Nevertheless, challenges have been experienced in implementing the resolution, primarily due to varying
interpretations of terminologies. The IMO has now identified and categorised the issues as follows:
• Authorisation of service providers, including equipment manufacturers
• Manufacturer's established certification programme
• Clarification of the certification of personnel
• Definitions of various terms
• Other Issues such as Ambiguity in the ASP's access to tools, documents, training, etc.

The aforementioned issues will be considered when developing draft amendments to resolution MSC.402(96). The definition of "make" and "type" in
the context of resolution has been agreed as the highest priority item.

Implication: Shipowners, operators and equipment manufacturers are advised to monitor forthcoming amendments to Resolution MSC.402(96)
and remain informed about the most recent requirements.

Application: The amended version of Resolution MSC.402(96) is expected to be applicable to all passenger ships, and to all cargo ships of 500GT and
above, engaged in international voyages. The expected entry into force is 1 January 2028.

606 Draft amendments to SOLAS chapters IV and V and performance standards and guidelines to
introduce VHF Data Exchange System (VDES)
Predicted entry into force
1 January 2028 Background: The Very High Frequency (VHF) Data Exchange System (VDES) integrates the functions of terrestrial and satellite VHF data exchange,
Application Specific Message (ASM) and Automatic Identification System (AIS). VDES has additional capacity for the exchange of more digital data and
could accommodate future growth in demand for utilising digital data in maritime radiocommunications. It is proposed at the IMO that there is a
need to amend SOLAS chapters IV and V to introduce VDES, and to develop performance standards and guidelines to facilitate the widespread
adoption of VDES. NCSR 11 agreed to continue the work through an intersessional correspondence group with the expectation of the amendments to
SOLAS being finalised at NCSR 12 (expected May 2025).

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 Implication: Shipowners and operators should note proposed developments regarding VDES, a new communication tool.

Application: The new requirements relate to the development, installation and use of VDES, as a new communication tool under the GMDSS. The
IMO agreed on a voluntary implementation of the VDES as further developments take place, which will allow it to be used concurrently with an AIS.
Entry into force is not expected before 01 January 2028.

SOLAS chapter IV applies to all cargo ships of 300GT and above, and to all passenger ships.

The requirements for AIS carriage in SOLAS V/19 apply to all ships of 300GT and upwards engaged on international voyages and cargo ships of 500GT
and upwards not engaged on international voyages and passenger ships irrespective of size.

642 Draft amendments to SOLAS regulation V/23, Draft MSC resolution on Performance standards and
Consequential draft amendments to the 1994 and 2000 HSC Codes and the 2008 SPS Code, to
Predicted entry into force improve the safety of pilot transfer arrangements
1 January 2028
Background: Accidents involving the tragic loss of pilots continue to happen worldwide despite previous efforts to improve pilot safety though
amendments to SOLAS regulation V/23 (resolution MSC.308(88)) and standards for pilot transfers (resolution A.1045(27)). Statistics published by the
International Maritime Pilots Association (IMPA) over the past few years show that an unacceptably high rate of non-compliant pilot transfer
arrangements installed on all types of ships, together with the improper use of pilot ladders and a lack of regular and effective maintenance and
inspection, are major contributing factors.

In response to the above, the IMO has now finalised amendments to SOLAS regulation V/23 to make the Performance standards on pilot transfer
arrangements mandatory under the SOLAS Convention. A draft MSC resolution Performance standards on pilot transfer arrangements has been
finalised too, which contains detailed requirements for design, manufacture, construction, inspection, maintenance, replacement, rigging and
training. There will be consequential draft amendments to the 1994 and 2000 HSC Codes and the 2008 SPS Code as well. The draft amendments to
the regulations are expected to be approved by MSC 109, for adoption at MSC 110 (May 2025).

The IMO via a draft MSC circular has also agreed to encourage interested Administrations to voluntarily implement the above amendments prior to
the entry into force. The draft circular is expected to be approved at MSC 109 (December 2024).

Implication:
Shipowners/Operators: will need to comply with the new requirements. Specifically:
• Regardless of installation date, all pilot transfer arrangements would be required to undergo inspection, stowage, maintenance, replacement,
and familiarisation in accordance with parts D and E of the performance standards.
• Accommodation ladders, together with any associated fittings intended for use in accordance with the performance standards shall meet the
requirements for the means of embarkation on and disembarkation from ships as required by SOLAS regulation II-1/3-9. This includes those
installed prior to 1 January 2010 which do not currently need to comply with SOLAS regulation II-1/3-9.

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 • Regardless of date of installation, maintenance and inspection of accommodation ladders used in the combination arrangement shall be carried
out in accordance with SOLAS regulation II-1/3-9.3.

Equipment manufacturers: The design, manufacture, and construction of pilot transfer arrangements must comply with detailed requirements and
be approved in accordance with Part F of the performance standards.

Application: Entry into force of the new requirements is expected to be 1 January 2028. A detailed applications details are as follows:
• All new and existing ships on which pilots may be employed shall be provided with pilot transfer arrangements.
• Pilot transfer arrangements installed on or after 1 January 2028, shall be designed, manufactured, constructed, secured and installed in
accordance with parts A, B and C of the performance standards.
“Installed on or after 1 January 2028” means:
- a contractual delivery date for the pilot transfer arrangement to the ship; or,
- in the absence of a contractual delivery date, the actual delivery date of the arrangement to the ship on or after 1 January 2028.
• Pilot transfer arrangements installed before 1 January 2028 on ships to which SOLAS chapter I applies (i.e. all ships engaged on international
voyages unless expressly provided otherwise), are to be designed, manufactured, constructed, secured and installed in accordance with parts A,
B and C of the performance standards, not later than the first annual, periodical or renewal safety equipment survey after 1 January 2029, as
referred to in MSC.1/Circ.1290.
• Pilot transfer arrangements installed before 1 January 2028 on ships to which SOLAS Chapter I does not apply, are to be designed,
manufactured, constructed, secured and installed in accordance with parts A, B and C of the performance standards, no later than 1 January
2030.

708 Draft amendments to the IGF Code - 2028

Background: The IGF Code is reviewed regularly. These amendments incorporate a number of consolidations and additional new provisions based
Predicted entry into force
on the industry’s experience.
1 January 2028 Implication: Owners and operators of ships using natural gas as fuel should be aware that from 1 January 2028:
• Vessels are permitted to have a suction well installed in fuel tanks protruding below the fuel tank without the well being considered part of the
fuel tank in the context of damage requirements below the fuel tank.
• Fuel tanks must be segregated from cargo in accordance with the requirements of the IMDG Code where fuel tanks are regarded as bulk
packaging, and a fuel tank on the open deck will be considered as a class 2.1 package in the context of the IMDG Code.

Designers of ships intending to use natural gas as fuel constructed on or after 1 January 2028, and potential owners of the same, should be aware of
the following:
• Pressure relief valves discharging liquid or gas from piping systems must discharge into fuel tanks whenever the tank maximum allowable relief
valve setting pressure is lower than the setting of the pressure relief valves fitted at fuel tank inlets and shall be designed to ensure that the
required discharge capacity is met. Alternatively, they may discharge to the vent mast, if means are provided to detect and dispose of any liquid
that may flow into the vent system.

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 • Fuel tank inlets from safety relief valve discharge lines, protecting the piping system shall be provided with non-return valves in lieu of valves
that are automatically operated when the safety system is activated. Safe means for tank isolation during maintenance shall be available without
affecting proper operation of safety relief valves.
• For the purposes of SOLAS regulation II-2/9 machinery spaces will be considered as fuel preparation rooms as opposed to any space containing
equipment for the fuel preparation.
• An Administration may allow a non-A-60 boundary to be installed facing the fuel tank on the open deck which is separated by a minimum
distance through heat analysis to provide protection equivalent to an A-60 class division as well as intermediate structures providing heat
protection will be accepted.
• For oil tankers and chemical tankers, A-60 insulation, required by SOLAS regulation II-2/9.2.4.2.5, will be considered to meet the requirements
regarding A-60 boundary provisions provided that the fuel tank is located in the cargo area forward of accommodation spaces, service spaces,
control stations, escape routes and machinery spaces. Consideration for the protection of accommodation block sides may be necessary.
• Notwithstanding the requirements for A-60 boundaries in the Code, where no source of gas release from the fuel containment system is
considered possible, e.g. a type C tank in which tank connections are in a tank connection space, A-60 class shielding is not required.
• The existing provision for the fuel storage hold space surrounding a type C tank to be considered a cofferdam in the context of protecting the fuel
containment system from machinery spaces or other rooms with high fire risk are changed so that the hold space can only be considered a
cofferdam when the minimum distance to the A-60 boundary from the outer surface of the insulation system of type C tank or the boundary of
the tank connection space, if any, is not less than 900mm. In this context, for the vacuum insulated type C tank, outer surface of the insulation
system means outer surface of the outer shell.
• Hazardous areas zone 1 will not include fuel preparation room ventilation outlets and instead include ventilation outlets from zone 1 spaces.
• The following area will be designated as a Hazardous area zone 1, areas on open deck, or semi-enclosed spaces on open deck above and in the
vicinity of fuel tank vent mast outlet within a vertical cylinder of unlimited height and 6m radius centred upon the centre of the outlet, and within
a hemisphere of 6m radius below the outlet. Where due to the size and layout of the vessel it is not possible to maintain the above distances, a
reduced zone can be accepted based on a dispersion analysis, based on 50% LEL criteria. The zone dimensions shall never be less than 3m, and
Application shall include a surrounding zone 2 hazardous area of 1.5m.
• In lieu of areas within 1.5m surrounding open of semi-enclosed spaces , Hazardous area zone 2 includes spaces 4m beyond the cylinder and 4m
beyond the hemisphere defined in the above hazardous area zone 1 area surrounding fuel tank vent masts on open or semi enclosed deck
spaces.
• Where the ventilation ducts serving hazardous spaces pass through less hazardous spaces, the ducts shall be gas-tight and have under-pressure
relative to less hazardous or non-hazardous spaces. Ventilation pipes serving hazardous spaces that pass through non-hazardous spaces, and
that are fully welded and designed in accordance with the requirements for materials section of the Code, are acceptable without the need for
under-pressure.

Application: To ships of 500GT and above and to all passenger ships using low-flashpoint fuels which are not gas carriers, constructed on or after 1
January 2028. “Constructed on or after 1 January 2028” in this context means:
• For which the building contract is placed on or after 1 January 2028; 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 1 July 2028; or
• The delivery of which is on or after 1 January 2032.

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 721 Draft amendments to SOLAS chapters II-1 (part C) and V - traditional and non-traditional propulsion
and steering systems' requirements
Predicted entry into force
1 January 2028 Background: Steering systems have evolved radically since current SOLAS regulations were adopted. Many modern systems are a combination of
propulsion and steering. Current SOLAS requirements do not adequately consider these non-traditional propulsion/steering systems.
Until now, this issue was addressed by means of unified interpretations (MSC.1/Circ.1416/Rev.1), however a review is considered necessary in order
to reflect modern propulsion/steering systems in the IMO's regulatory framework.

Draft amendments now include:

• A new SOLAS regulation II-1/28-1 – Means of going astern and stopping. This regulation is expanded to include the stopping ability of the ship,
with a goal to prevent casualties arising from malfunction or insufficient performance of astern propulsion to control or stop the ship.
• A new SOLAS regulation II-1/29-1 – Steering. This is to address the steering function and steering performance of the ship, as well as
requirements for the steering system(s) and power supply, with a goal to prevent casualties arising from malfunction or insufficient performance
or incorrect use of steering systems.

Future development could include amendments to the following sections of SOLAS:

• Expected Performance Standards in SOLAS regulations II-1/28 to 30
• SOLAS regulation II-1/30 - Additional requirements for electric and electrohydraulic steering gears
• SOLAS regulation II-1/42 - Emergency Source of Electrical Power in Passenger Ships
• SOLAS regulation II-1/43 - Emergency Source of Electrical Power in Cargo Ships
• SOLAS regulation V/25 - Operation of steering gear
• SOLAS regulation V/26 - Steering gear: Testing and drills

Amendments to the Resolutions and Circulars:

• MSC.1/Circ.1536 – Unified Interpretation of SOLAS regulations II-1/29.3 and 29.4
• Resolution A.467(XII) – Guidelines for acceptance of non-duplicated rudder actuators for tankers, chemical tankers and gas carriers of 10,000 tons
gross tonnage and above but less than 100,000 tonnes deadweight
• Resolution MSC.137(76) – Standards for Ship Manoeuvrability
• MSC/Circ.1053 – Explanatory Notes to the Standards for ship manoeuvrability
• Resolution A.601(15) – Provision and Display of Manoeuvring Information on board Ships
• Possible revocation of resolutions A.415(XI) and A.416(XI), MSC.1/Circ.1398 and MSC.1/Circ.1416/Rev.1.

Implication: These amendments are expected to provide designers with a framework and supporting guidance to safely include alternative
propulsion and steering systems on ships.

Application: It is expected that all new passenger ships and all cargo ships of 500GT and above, which are contracted for construction on or after 1
January 2028 will need to comply with the new provisions.

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 728 Draft amendment to the 1988 Load Line Protocol, regulation 25 - protection of the crew - setting of
guard rails on the deck structure
Predicted entry into force
1 January 2028 Background: It has been observed that when ships are subject to intense weather conditions, the crew that operate on open decks are likely to fall
through the gaps of guard rails. The proposed draft amendments to regulation 25 of the 1988 Load Line Protocol have the objective to ensure the
safety of crew is enhanced to avoid such accidents.

Implication: New amendments will require that all guard rails or bulwarks which are located on exposed decks and are accessible to crews during
navigation meet the same standard as those on exposed superstructure or freeboard decks:
• will have at least three courses;
• the opening below the lowest course of the guard rails shall not exceed 230 mm; and
• the other courses shall be not more than 380 mm apart.

Application: This regulation will apply to new ships of 24m in length and over with guard rails for the protection of crews on exposed decks.

807 Draft amendments to the International Maritime Dangerous Goods (IMDG) Code (Amendment 43-26)
Background: The IMDG Code is regularly reviewed to take into account new requirements for existing substances, or add new substances.
Predicted entry into force
1 January 2028 Implication: The latest set of draft amendments (43-26) include inter alia the following amendments:
• Stowage and handling for SILENE (UN 2203) changed from compatibility category E to compatibility category D.
• Amendments to align the provision in paragraph 4.2.1.9.2 on the maximum degree of filling in portable tanks for liquid marine pollutants under
generic or NOS (not otherwise specified) entries with UN Model Regulations.
• To clarify the requirements in table 7.1.4.5.18 - CLASS 7 – Radioactive material Segregation table for persons for segregation distances between
radioactive material and passengers and crew.
• Editorial modifications to 7.6.3.5.2 - Segregation table in order to fully align the tables in the IMSBC Code and the IMDG Code.
The above mentioned list of draft amendments will be considered by E&T42 with the view of providing advice to CCC 11 with any additional
proposals.

Application: The IMDG Code applies to all ships to which SOLAS, as amended, applies and which are carrying any of the substances, materials and
articles covered by the IMDG Code (dangerous goods as defined in SOLAS chapter VII part A regulation 1). Amendment 43-26 is expected to come into
force 1 January 2028.

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 808 Draft amendments to Transport Provisions for Vehicles within the IMDG Code (Special Provision 961,
Special Provision 962)
Predicted entry into force
1 January 2028 Background: Following the fire aboard the roll-on/roll-off vehicle carrier Höegh Xiamen, and to address the rising hazards associated with the
shipment of vehicles using alternative energy sources, work to further develop the provisions on the transport of vehicles (special provisions (SP) 961
& 962 of the IMDG Code) has been taking place.

SP 961 states which conditions - if met - will allow the transport of vehicles by sea so that the IMDG Code may not be applied. These include, for
example, vehicles if stored in ro-ro spaces, or on the weather deck of a ro-ro ship, or a cargo space designated by the Administration in accordance
with SOLAS, chapter II-2/20.

SP 962 complements SP 961 by stating the requirements that vehicles which are outside the scope of SP 961 will need to comply with when being
transported by sea.

Implication: To date the following have been developed and agreed:

• Initial draft of new definitions to be used when SP 961 and SP 962 are applied (new, used, in-use, damaged, prototype vehicles).
• Criteria to apply to Electric Vehicles (EV) and Hybrid Electric Vehicles (HEV).

The following areas are also likely to be considered as part of this work, subject to proposals being submitted.
• Non-consumer vehicles
• Packaged vehicles
• Charging EVs and Hybrids while underway
• Special provision for RO-PAX vessels
• State of charge
• State of health (battery)
• Fuel Flashpoint
• Fuel Quantity
• Provisions for hybrid
• Inspections
• Damage from the weather (seawater versus freshwater)
• General damageRefrigerated vehiclesProtype components/vehicles

Application: These changes will apply to all those ships that have to comply with SOLAS and the IMDG Code and are engaged in the transport of
vehicles in accordance with special provisions (SP) 961 and/or 962 of the IMDG Code.

The work is ongoing and it is anticipated that a possible entry into force for the updated provisions could be in 2028.

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 828 Review of the Short-Term Reduction Measure (CII and EEXI)
Background: MARPOL Annex VI regulation 28.11 requires a review of the CII framework and possible additional EEXI requirements to be conducted
Predicted entry into force
by 1 January 2026.
1 March 2028
This work has begun and MEPC 82 agreed to conduct this work in two phases. The First Phase is to focus on:
• CII allowing individual ship-based assessment of energy efficiency performance.
• CII reduction factors between 2027 and 2030.
• Review of potential penalties CII imposes for idle time and port waiting time*.
• Review of potential penalties CII imposes for short voyages*.
• CII calculation potentially penalising cruise passenger ships with significant time in ports*.
• CII enforcement mechanisms needing to incentivise behaviour change*.
• CII potentially needing to incentivise port call efficiency and solutions such as just-in-time (JIT) arrival of ships*.
• CII ratings and DCS data not being accessible for analysis beyond Parties to MARPOL Annex VI needing consideration*.
The first phase is to conclude before 2026. * These items are expected to be continued in Phase 2 of the work

The Second Phase is to focus on:

• CII calculation potentially penalising self-unloading bulk carriers.
• CII calculation potentially penalising geared bulk carriers.
• CII calculation potentially penalising ships navigating in adverse weather.
• CII calculation potentially penalising ships using bow thrusters.
• CII calculation potentially penalising ballast voyages.
• CII potentially penalising ships carrying refrigerated cargo below deck.
• CII calculation potentially penalising steam driven LNG carriers compared to engine driven LNG carriers.
• CII calculation potentially penalising ro-ro cargo and ro-ro passenger ships.
• CII reference lines not accurately reflecting smaller LNG carriers.
• The fact that CII might overlap with the development of the basket of mid-term GHG reduction measures.
• CII does not address fuel emissions on their full life cycle only CO2 Tank-to-Wake emissions.
• CII does not allow for pooling with other ships.
This second phase will go beyond 2026.

The work product from this package of work will result in amendments to various Guidance used to support the CII regulations as well as potential
MARPOL Annex VI amendments. Amendments to Guidance would take effect after their approval whereas it is anticipated that MARPOL Annex VI
amendments will not come into force until 2028 at the earliest.

Implication: Shipowners and Operators should be aware of the review and be aware of any amendments to guidelines which could affect the way
in which CII is calculated.

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 Application: To ships of 5000GT and over falling into one of the following categories:
• Bulk Carrier
• Combination Carrier
• Container Ship
• Cruise Passenger Ship
• Gas Carrier
• General Cargo Ship
• LNG Carrier
• Refrigerated Cargo Carrier
• Ro-ro Cargo Ship
• Ro-ro Cargo ship (vehicle carrier)
• Ro-ro Passenger Ship
• Tanker

How LR Can Support Clients

LR will continue to keep clients up to date on developments of the short-term GHG measure review and any actions that need to be taken including
when the method for calculating CII may change or where new correction factors are introduced etc.

572 Comprehensive review of the 1978 STCW Convention and Code

Background: The STCW Convention and Code are reviewed from time to time to ensure their currency with the latest technology, ship types,
Predicted entry into force operational practices and training standards. It has been agreed that a comprehensive review of the STCW Convention and Code is required. The
1 March 2029 following areas will considered as part of the review:
• Emerging technologies on ships and ship operations
• Digitalisation of documentation, including certificates issued under STCW
• Emerging technologies in education and training
• Facilitation, flexibility and quality of onboard, shore-based and workshop skills training, including use of simulators
• Flexibility and efficiency in implementation of new training requirements and reduction of administrative burdens
• Requirements for sea time or practical experience in relation to new and emerging technologies including the use of simulation
• Psychological safety, bullying and harassment, including SASH, gender diversity and gender sensitisation
• Mental health
• Twenty-first century and interpersonal skills
• Addressing inconsistencies
• Addressing different interpretations
• Addressing taxonomy and terminologies
• Flexibility in revalidation of certificates and endorsements
• Overview of the implementation of the Convention, in particular the need to update the STCW "White List"

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 • Lessons learned
• Flexibility
• Alternative certification under chapter VII
• Watchkeeping arrangements and principles to be observed (chapter VIII)
• Alignment of STCW with requirements placed on ships, seafarers, and shipowners by other IMO and relevant international instruments
• Cybersecurity
• Implementation and transitional provisions
• Addressing outdated training requirements

Implication: It is expected that seafarers will need to be trained and competent in accordnace with the new requirements of the Convention.

Application: This is expected to apply to all seafarers following expected adoption in Autumn 2027.

637 Draft amendments to MARPOL Annex IV for the Prevention of Pollution by Sewage from Ships
Background: It has been noted that 97% of ships tested did not meet sewage effluent discharge standards despite using approved Sewage
Predicted entry into force
Treatment Plants (STP), with poor performance or failure being common causes. It is anticipated that regular maintenance of STP, monitoring of STP
1 June 2031 effluent and strengthening the STP type approval test process can help reduce such poor performance and failures.

Implication: Possible revised standards for the maintenance of STPs and monitoring of effluent.

Application: Ships of 400GT and above, and ships of less than 400GT certified to carry more than 15 persons.

Related Instruments
• MEPC.227(64) - 2012 Guidelines on implementation of effluent standards and performance tests for sewage treatment plants

497 Draft Code for Maritime Autonomous Surface Ships (Mandatory)

Background: The IMO completed the Regulatory Scoping Exercise (RSE) in relation to the use of Maritime Autonomous Surface Ships (MASS) aimed
Predicted entry into force
to establish a set of common gaps and themes and identify the most appropriate way of addressing MASS operations within such instruments.
1 January 2032 For the purpose of the RSE, MASS was defined as a ship, which to a varying degree can operate independently of human interaction.
Four ‘degrees of autonomy’ for the RSE’s purpose were identified as:
• Degree One: Ship with automated processes and decision support
• Degree Two: Remotely controlled ship with seafarers on board
• Degree Three: Remotely controlled ship without seafarers on board
• Degree Four: Fully autonomous ship

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 The outcome of the RSE can be found in detail in:
• MSC.1/Circ.1638 Outcome of the Regulatory Scoping Exercise for the use of Maritime Autonomous Surface Ships (MASS);
• LEG.1/Circ.11 Outcome of the Regulatory Scoping Exercise and Gap Analysis of Conventions emanating from the Legal Committee with respect to
MASS; and
• FAL.5/Circ.49 Outcome of the regulatory scoping exercise and gap analysis of the FAL Convention with respect to MASS.

As a result, the IMO has been working on the following tasks:

• To develop a non-mandatory goal-based MASS Code, which is expected to be effective from MSC 110 (2025) as an interim measure prior to the
adoption of a mandatory MASS Code.The mandatory MASS Code is expected to enter into force 1 January 2032.
• While the scope of application is yet to be formally agreed, it is expected to initially be limited in application to cargo vessels only and exclude
application to passenger ships. Discussion on the complexities of extending the application to passenger ships will take place at a later stage.
• It is intended that the mandatory Code will be a new instrument, however, SOLAS and associated instruments will need to be amended to ensure
coherent implementation.
• Discussions through Inter-sessional Working Groups and Correspondence Groups are currently on-going at the IMO, dividing the draft Codes into
focused reviews based on sections (through splinter groups) to maximise output. New definitions and terminology are under development by
various industry stakeholders. The original ‘degrees of autonomy’ quoted above were only for the regulatory scoping exercise’s purposes and are
expected to be reframed away from ‘ship-wide’ definitions of autonomy and refer to more specific ship systems or functions/capabilities.

Implication:
Shipping regulators: will have to determine the applicability of the requirements of the newly developed non-mandatory and subsequent
mandatory MASS code to MASS assets under development, and also interpret the goal-based measures for proving system integrity, verifications &
validation, and certification.

Shipyards, Ship operators, port/vessel traffic controls service providers, equipment manufacturers, seafarer training centres, national
maritime authorities and certification bodies: will get a view of MASS requirements as the industry heads towards this new aspect of shipping’s
future.

Application: Maritime Autonomous Surface Ships (currently under discussion at the IMO). The Code is expected to be applicable to cargo ships to
which SOLAS chapter I applies which have functions that enable autonomous or remote operations including any associated ROC(s) when the
Administration deems that compliance with base instruments is not practicable.

This Code will not apply to:

• cargo high speed craft to which SOLAS chapter X applies; and
• warships, naval auxiliaries, and other ships owned or operated by a Contracting Government and used only on Government non-commercial
service.

Related Instruments
• MSC.1/Circ.1638 Outcome of the Regulatory Scoping Exercise for the use of Maritime Autonomous Surface Ships (MASS)

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 • LEG.1/Circ.11 Outcome of the Regulatory Scoping Exercise and Gap Analysis of Conventions emanating from the Legal Committee with
respect to MASS
• FAL.5/Circ.49 Outcome of the regulatory scoping exercise and gap analysis of the FAL Convention with respect to MASS

586 Draft revision of SOLAS chapter III and the LSA Code
Background: The IMO has developed a draft roadmap for revising SOLAS Chapter III and the LSA Code, aimed at eliminating gaps, inconsistencies,
Predicted entry into force
and ambiguities, and restructuring the requirements into a goal-based format. Currently, the IMO is in the process of drafting functional
1 January 2032 requirements and expected performance criteria for SOLAS Chapter III and the LSA Code, based on identified goals and high-level hazards, such as
transferring a rescued person (ship-to-ship or ship-to-helicopter).

Implication: Shipowners, shipyards, designers, and equipment manufacturers should stay informed about the outcomes from the IMO, which
may lead to the updated SOLAS Chapter III and the LSA Code and some consequential amendments.

Application: The revised SOLAS Chapter III and the LSA Code, once approved and adopted, is expected to apply to ships in the same manner as
before. Specifically, this includes cargo ships of 500GT or more and all passenger ships.

823 Development of a safety regulatory framework to support the reduction of GHG emissions from
ships using new technologies and alternative fuels
Background: The IMO is conducting what is effectively a scoping exercise of fuels and technologies being considered by the industry and the risks
associated with the deployment of those fuels and technologies, the technology readiness, and the regulatory framework already in existence. The
goal is then to agree a work plan of further regulatory and guidance development to facilitate the safe deployment of those fuels and technologies at
the scale needed.

Implication: Shipowners and operators considering new fuels and technologies should follow the work to understand the regulatory framework
that will be developed specific to the fuel and/ or technologies being considered.

Application: The application will be decided based upon the fuel or technology being considered.

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Part 4
Proposed IMO and ILO work
This part covers potential requirements due to be considered at the IMO and ILO.

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 566 Proposed amendments to SOLAS chapter XV and the IP Code - Second phase
Background: The IMO agreed the need for future expansion of SOLAS chapter XV and the IP Code, and has agreed to a second phase of work to address industrial
personal (IP) being transported by passenger ships or high-speed passenger craft, as well as any outstanding matters from the first phase, subject to any proposals
being submitted.

Implication: The updates should clarify the interaction between the IP and SPS Codes, as well as consider those ship types that might be engaging in IP transfers.
Any proposals for new requirements are expected to be considered in January 2025.

Application: The new developments on the IP Code will introduce provisions for passenger ships and high-speed craft carrying industrial personnel.

Related Instruments
• MSC.521(106) - Amendments to the International Convention for the Safety of Life at Sea, 1974 (Chapter XV)
• MSC.527(106) - International Code of Safety for Ships Carrying Industrial Personnel (IP Code)

608 Proposed amendments to SOLAS chapter III and chapter IV of the LSA Code to require the carriage of self-
righting or canopied reversible liferafts for new ships
Background: The IMO considered a proposal to equip all passenger and cargo ships with automatically self-righting or canopied reversible liferafts (except for
liferafts with a capacity of no more than six persons) and, consequentially, to amend regulations 21, 26 and 31 of SOLAS chapter III and paragraphs 4.2 and 4.3 of
chapter IV of the LSA Code.

After consideration of the above there was not a consensus on the scope of application and further proposals are now expected providing relevant justification for
or against the different scope of application on this matter.

Implication:
Equipment manufacturers: will need to be aware that the construction and testing standards for liferafts will be updated so their products will need to meet the
new requirements.
Shipowners and Operators: will need to be aware that the equipment carriage requirements on their ships may change with this amendment.

Application: It is currently unclear whether the proposal would apply to liferafts replaced on existing ships, but it would most likely apply to new ships.

There is broad agreement that the new requirements should apply to passenger ships. An exemption could be supported for liferafts designed for 25 people or
fewer on these vessels. Additionally, liferafts used with launching appliances, such as marine evacuation systems commonly installed on passenger ships, could
also be exempted.

For cargo ships, the IMO could not agree on justification for the new requirements and has invited further proposals to be discussed at SSE 11 in February 2025.

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 610 Proposed revision of the 2010 FTP Code to allow for new fire protection systems and materials
Background: MSC 103 approved a new output to review and amend the 2010 FTP Code. The agenda item's scope includes allowing for new fire protection
systems and materials, updating the FTP Code to include existing unified interpretations and updating references to the most recent ISO fire test standards.

The IMO has considered documents identifying ambiguities within the FTP Code and proposing new materials and new construction techniques to be addressed in
development of the revision to the FTP Code, including the following:
• Evaluate the thermodynamic implications of the air gap between rated bulkheads in modular construction and the appropriateness of single-sided testing of
these divisions;
• Identify appropriate test methods to allow new materials to be adequately evaluated under the current FTP Code, considering their unique physical properties
and fire risk; and
• Identify the factors which should be noted on the approvals to limit the scope of an approval or determine worst-case configurations for testing.

Following discussion, the IMO concluded that, in general, there was support for the proposals stated above and invited proposals to SSE 11 for amending the 2010
FTP Code to allow for new fire protection systems and materials.

Implication:
Designers, Shipbuilders and testing laboratories: will need to take account of the revised FTP Code allowing for new fire protection systems and materials.

Application: If approved and adopted by June 2026, the draft amendments will enter into force from 1 January 2028.
The FTP Code is applicable for products which are required to be tested, evaluated and approved in accordance with the Fire Test Procedures Code as referenced
in SOLAS, which is applicable to cargo ships of 500GT and above and passenger ships.

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