IMO Regulatory Update 2025
In 2025, the International Maritime Organization (IMO) will implement several important regulations that will affect shipowners, operators, and the entire maritime industry. These changes aim to improve safety, environmental protection, and efficiency. From new rules for managing ballast water and reducing emissions, to updated certification requirements and digital reporting, there’s a lot to keep track of. In this blog post, we’ll break down the key regulations coming into force in 2025 and highlight what you need to know to stay compliant and ahead of the changes.
Regulations Coming into Force on 1 January 2025
Starting 1 January 2025, several key maritime regulations will come into effect, focusing on dangerous goods transport, bulk cargo handling, seafarer certifications, and environmental protections in sensitive areas. These updates require industry stakeholders to be well-prepared for the changes.
1. IMDG Code Amendments (42-24) – MSC.556(108)
The IMDG Code amendments aim to improve the safety of transporting dangerous goods by sea. These changes align with the UN Recommendations on Dangerous Goods, effective 1 January 2025, with some optional provisions for contracting governments.
Key Changes:
- Lithium Batteries: Lithium batteries are now classified under “articles containing dangerous goods, N.O.S.,” with specific rules for damaged or defective batteries.
- New Entries for Lithium-Powered Vehicles: Two new UN numbers (3556 and 3557) for vehicles powered by lithium-ion and lithium-metal batteries are introduced.
- Stricter Charcoal and Carbon Cargo Rules: New packaging, stowage, and temperature maintenance requirements for carbon products.
- Sodium-Ion Batteries: Sodium-ion batteries are now classified under Class 9 with similar safety standards to lithium-ion batteries.
- Enhanced Packaging & Labelling: Updated provisions improve stowage plans, secure tracking devices, and clearer hazard identification.
2. IMSBC Code Amendments (07-23) – MSC.539(107)
The IMSBC Code, now mandatory as of 1 January 2025, updates the handling and documentation of bulk cargoes.
Key Changes:
- Bulk Density Declaration: Shippers must declare the bulk density of cargoes, improving safety and efficiency per SOLAS regulation XII/10.
- New Cargo Entries: New types, including baryte and brown fused alumina, require specific handling.
- Reclassification of Dangerous Goods: Some cargoes, like stabilized fish meal, have been reclassified to non-dangerous, easing certification.
- Fire-Fighting Exemptions: Cargoes like pelletized electric arc furnace dust are exempt from requiring fixed CO2 fire-fighting systems.
3. Amendments to the STCW Convention and Code on Electronic Seafarers’ Certificates – MSC.540(107) & MSC.541(107)
To support digitalization, the STCW Convention will allow electronic seafarer certificates from 1 January 2025.
Key Changes:
- Electronic Certification: Seafarers can now receive electronic certificates with the same information as paper ones.
- Guidelines for Use: The amendments ensure electronic certificates are legally recognized and accepted.
4. MARPOL Annex I Amendments – MEPC.381(80)
The Red Sea and Gulf of Aden will officially become Special Areas under MARPOL Annex I, effective 1 January 2025, with stricter discharge controls for oil and oily mixtures.
Key Changes:
- Discharge Prohibition: Ships over 400 GT are prohibited from discharging oil or oily mixtures unless processed through approved filtering equipment.
- Oil Tanker Specifics: Oil tankers cannot discharge oil or oily mixtures from cargo areas, except for clean or segregated ballast.
5. MARPOL Annex V Amendments – MEPC.382(80)
The Red Sea is also designated as a Special Area under MARPOL Annex V, which regulates the discharge of garbage from ships.
Key Changes:
- Garbage Discharge Restrictions: The discharge of garbage is prohibited in the Red Sea, except when a ship is en route and in compliance with MARPOL Annex V guidelines.
These updates reflect the maritime industry’s ongoing commitment to safety, environmental protection, and regulatory alignment with global standards. Industry members must ensure they are compliant with these new regulations to avoid penalties and enhance operational safety.
Regulations Coming into Force on 1 February 2025
Starting 1 February 2025, amendments to Appendix II of the Ballast Water Management (BWM) Convention will be implemented, bringing significant updates to the Ballast Water Record Book (BWRB). These amendments aim to address common deficiencies and improve the accuracy and clarity of ballast water reporting.
Amendments to Appendix II of the BWM Convention
The Ballast Water Management (BWM) Convention, under Regulation B-2, mandates that ships maintain a Ballast Water Record Book, which must contain specific information regarding ballast water operations. Over time, the most frequently reported deficiencies during Port State Control (PSC) inspections have been related to incomplete or inaccurate entries in the BWRB.
To address these issues and improve compliance, Appendix II of the BWM Convention has been updated to revise the format and information requirements of the Ballast Water Record Book.
Key Changes to the Ballast Water Record Book (BWRB)
- Clarification and Enhanced Information: The revised Appendix II provides clearer guidelines on the required entries in the BWRB, helping ship operators better understand what information must be recorded during ballast water operations.
- Improved Record-Keeping: The updated format of the BWRB ensures that ships maintain more accurate and comprehensive records, reducing the risk of deficiencies being flagged during inspections.
- Implementation Date: The new format for the BWRB will become mandatory for ships on 1 February 2025, requiring all vessels to comply with the revised record-keeping and reporting requirements.
Guidance and Compliance
Members are encouraged to refer to BWM.2/Circ.80 for detailed guidance on how to properly maintain the new Ballast Water Record Book and to ensure their vessels are in compliance with the updated requirements starting 1 February 2025. This will help mitigate any potential non-compliance issues and ensure smoother PSC inspections.
Regulations Coming into Force on 1 May 2025
Starting 1 May 2025, significant amendments to MARPOL Annex VI, specifically Regulation 14 and Appendix VII, will come into effect. These amendments pertain to the Mediterranean Sea’s designation as an Emission Control Area (ECA) for sulphur oxides (SOx) and particulate matter (PM), impacting vessels operating in or transiting through this region.
Mediterranean Sea ECA Designation
The Mediterranean Sea was officially designated as an ECA for SOx and PM as of 1 May 2024. However, the regulatory requirements will only become mandatory on 1 May 2025. This means that, beginning on this date, ships navigating the Mediterranean Sea must comply with stricter emissions controls to reduce the environmental impact of shipping operations in the region.
Key Requirements for Ships
From 1 May 2025, vessels operating in the Mediterranean Sea ECA must adhere to the following measures:
- Sulphur Content Limits: Ships must use fuel oil with a sulphur content not exceeding 0.10% m/m while operating within the Mediterranean Sea ECA. This low sulphur requirement aims to reduce the harmful effects of sulphur oxides on air quality and human health.
- Exhaust Gas Cleaning Systems (EGCS): Alternatively, ships may install and use an exhaust gas cleaning system (EGCS) to comply with the sulphur emissions restrictions. EGCS can be used to scrub sulphur from exhaust gases, making it possible for ships to continue using higher sulphur fuels while meeting the emissions standards.
Recommendations for Ship Operators
Ship operators involved in trade or transit through the Mediterranean Sea are strongly advised to ensure compliance with these new regulations starting 1 May 2025. It is essential for vessels to either switch to low-sulphur fuel or install an EGCS to meet the emission requirements for the region. Failure to comply could result in penalties or other enforcement actions by authorities.
New Regulation Effective 26 June 2025: Hong Kong Convention on Ship Recycling – MEPC.210(63)
On 26 June 2025, the Hong Kong Convention on Ship Recycling (HKC) will enter into force, introducing significant regulations for ship design, operation, and recycling. The Convention aims to ensure that ship recycling is carried out safely, protecting human health, safety, and the environment.
Overview of the Hong Kong Convention (HKC)
The HKC applies to ships over 500 GT engaged in international voyages. It regulates ship recycling to prevent risks from hazardous materials during the dismantling process, ensuring toxic substances are managed and that workers’ health and the environment are safeguarded.
The HKC covers the following key areas:
- Design and Construction: Ships must be designed with safe recycling in mind, limiting the use of hazardous materials.
- Operation and Preparation for Recycling: Ships must be operated in a way that ensures they are ready for safe recycling at the end of their service life.
- Recycling: Ships can only be recycled at approved and compliant facilities.
Key Requirements for Ship Owners and Operators
- Inventory of Hazardous Materials (IHM):
- New Ships (post-26 June 2025): Must have an approved and certified IHM onboard, detailing hazardous substances in the ship’s structure and equipment.
- Existing Ships: Must have an IHM by 26 June 2030.
- Material Declarations (MD) and Supplier Conformity Declarations (SDoC):
- Ship owners must ensure Material Declarations and Supplier Declarations of Conformity are completed for parts or equipment supplied to the ship. These documents confirm that materials comply with the HKC’s recycling standards.
- Surveys and Certification:
- Initial Survey: Verifies the IHM to ensure all hazardous materials are documented.
- Ongoing Surveys: Verify the maintenance of the IHM throughout the ship’s operational life.
- Final Survey: Conducted before recycling to ensure proper handling of hazardous materials (MEPC.222(64)).
Ship Recycling Requirements
At the end of its life, ships under the HKC must be recycled only at HKC-compliant facilities. These facilities must meet stringent environmental and safety standards.
- Ship Recycling Plan: Recycling facilities must prepare a plan outlining how the ship will be dismantled safely. A Ready for Recycling certificate will be issued once the ship is deemed ready for recycling.
Impact on Ship Owners and Operators
Ship owners must prepare for the HKC by ensuring:
- New ships built after 26 June 2025 comply with IHM requirements.
- Existing ships have their IHM certified by 26 June 2030.
- Compliance with surveys, Material Declarations, and recycling facility requirements.
Regulations Coming into Force on 1 August 2025: Amendments to MARPOL Annex VI – MEPC.385(81)
On 1 August 2025, significant amendments to MARPOL Annex VI will come into effect. These changes address key issues related to low-flashpoint fuels, fuel oil consumption reporting, and the replacement of steam systems with marine diesel engines. Below, we explore the important changes that shipowners and operators must be aware of to remain compliant with these new regulations.
1. Low-Flashpoint Fuels and Bunker Delivery Notes (BDN)
The amendments to Regulations 2, 14, and Appendix I of MARPOL Annex VI refine the definition of gas fuels to align with the International Code of Safety for Ships Using Gases or Other Low-flashpoint Fuels (IGF Code). The revisions clarify that sampling points for in-use or onboard sampling will not apply to gas and low-flashpoint fuels.
Key Changes:
- Bunker Delivery Notes (BDN): New provisions will require that BDNs include essential information on gas and low-flashpoint fuels. This ensures transparency and accurate documentation of fuel delivery.
- Action for Shipowners: Ensure that the BDN for ships using gas or low-flashpoint fuels contains the minimum required information, as specified in the amendments.
2. Replacement of Steam Systems with Marine Diesel Engines
Amendments to Regulation 13.2.2 now categorize the replacement of a steam system with a marine diesel engine as a major conversion, rather than a minor modification. This change means that any such system replacement will need to comply with MARPOL Annex VI’s stringent emission control requirements.
Key Changes:
- Tier III vs. Tier II Engines: If the replacement requires a Tier III engine but a Tier II engine is used instead, the flag Administration must report this to the IMO.
- Action for Shipowners: Shipowners replacing steam systems with diesel engines after 1 August 2025 must ensure that they comply with Regulation 13 of MARPOL Annex VI, and report any non-Tier III engine replacements to the IMO.
3. Enhanced Fuel Consumption Data and Reporting
Amendments to Regulation 27 of MARPOL Annex VI allow the IMO to share fuel consumption data with analytical consultancies and research entities, subject to the company’s consent and under strict confidentiality. This new data-sharing initiative will aid in the analysis and development of environmental policies.
Key Changes:
- New Reporting Obligations: Additional data, including total onshore power supplied, total transport work, the installation of innovative technologies, and laden distance travelled (on a voluntary basis), must be reported under Appendix IX of MARPOL Annex VI.
- Action for Shipowners: Ships of 5,000 GT and above must ensure their Ship Energy Efficiency Management Plan (SEEMP) Part II is updated to accommodate these new reporting requirements.
4. Impact on Shipowners and Operators
With these amendments taking effect on 1 August 2025, shipowners and operators must take proactive measures to ensure compliance. This includes updating the BDN for ships using gas or low-flashpoint fuels, ensuring proper reporting of fuel consumption data, and modifying the SEEMP Part II as necessary.
Action Steps:
- Review and update the BDN for low-flashpoint fuel shipments.
- Ensure that all fuel consumption data is accurately recorded and reported.
- Modify the SEEMP Part II to incorporate the new data collection and reporting requirements.
Regulations Coming into Force on 1 October 2025: Amendments to the BWM Convention – MEPC.383(81)
On 1 October 2025, significant amendments to the Ballast Water Management (BWM) Convention will come into effect. These changes introduce the use of electronic Ballast Water Record Books (BWRBs), streamlining compliance and aligning with international maritime regulations such as MARPOL Annexes and the NOx Technical Code.
1. Electronic Ballast Water Record Books (BWRBs)
The amendments to regulations A-1 and B-2 of the BWM Convention authorize the use of electronic record books for ballast water management. This move aims to enhance operational efficiency and ensure a more unified approach across maritime conventions and codes.
Key Changes:
- Electronic Record Keeping: Shipowners will now have the option to maintain their Ballast Water Record Book electronically rather than in paper form, providing more flexibility and ease of compliance.
- Harmonization: These amendments align the BWRB requirements with other international standards, such as MARPOL Annexes and the NOx Technical Code, ensuring consistency across regulations.
2. Guidelines for Electronic Record Books
To assist shipowners and operators in transitioning to electronic record books, the IMO has provided guidelines under MEPC.372(80). These guidelines outline best practices and technical specifications for implementing electronic BWRBs under the BWM Convention.
Action for Shipowners:
- Adopt Electronic Record Books: Shipowners who choose to use electronic record books should familiarize themselves with the guidelines provided in MEPC.372(80) to ensure they meet all necessary requirements.
- Ensure Compliance: Review and update ballast water management systems to integrate electronic record-keeping as required by the amendments.
3. Impact on Shipowners and Operators
The amendments to the BWM Convention represent a significant step toward digitalization in maritime compliance. By allowing electronic BWRBs, the changes simplify ballast water management reporting, reduce paperwork, and ensure better alignment with other international maritime conventions.
Action Steps:
- Assess the feasibility of using electronic record books on board.
- Review the IMO’s guidelines to ensure the electronic system meets all regulatory requirements.
- Implement necessary updates to the ship’s ballast water management system and ensure crew training on the new process.
Conclusion: Staying Ahead of 2025 IMO Regulations
2025 will bring significant changes to the maritime industry with key IMO regulations coming into force. From stricter ballast water management protocols and emissions control areas to new requirements for ship recycling and digitalized reporting, ship operators and owners will face a dynamic regulatory landscape.
To stay ahead, it’s essential for industry stakeholders to begin preparations now. Early adoption, thorough understanding, and proactive compliance with these changes will ensure smoother transitions and avoid operational disruptions. By acting early, shipowners and operators can navigate these regulations confidently, safeguarding their vessels, reducing environmental impact, and maintaining regulatory compliance across the board.
