IMO Regulatory Update 2025

Introduction

The Club previously published an article summarising key IMO regulations that came into effect in 2023 and 2024.

The maritime sector continues to face a pivotal shift in 2025, as new regulations are set to enter into force. These regulations aim to enhance safety and environmental protection in global shipping.

As the industry increasingly commits to greener practices and responsible governance, these regulations ensure compliance with more stringent standards. The goal is to foster a safer and more sustainable future for maritime trade.

This article aims to provide an overview of the IMO regulations scheduled to take effect in 2025.

Regulations coming into force on 1 January 2025

IMSBC code amendments (07-23) – MSC.539(107)

Updates to the International Maritime Solid Bulk Cargoes (IMSBC) code, which has been applicable on a voluntary basis since 1 January 2024, will enter into force on 1 January 2025. These include, but are not limited to, the following changes:

• The shippers are now required to declare the ‘bulk density’ of cargo, as required by SOLAS regulation XII/10 (MSC.1/Circ.1664).
• The following changes have been affected in Appendix 1 (individual schedule of solid bulk cargoes):
  • New cargo entries

Bulk cargo shipping name (BCSN)	Group	Hazard
BARYTE, FLOTATION CHEMICAL GRADE	A
BROWN FUSED ALUMINA	C
CRUSHED GRANODIORITE FINES	A
DIRECT REDUCED IRON (D) (By-product fines with a moisture content of at least 2%)	A and B	MHB (WF and/or SH)
DUNITE	C
DUNITE FINES	A
ELECTRIC ARC FURNACE DUST, PELLETIZED	A and B	MHB (TX and CR)
GROUND GRANULATED BLAST FURNACE SLAG POWDER	A
MAGNESITE FINES	A
POTASSIUM NITRATE	C
SODIUM NITRATE	C
SODIUM NITRATE AND POTASSIUM NITRATE MIXTURE	C
CELESTINE CONCENTRATE (under Mineral Concentrates schedule)	A
FISH MEAL (FISH SCRAP), STABLISIZED ANTI-OXIDANT TREATED	B	MHB (SH)

• Deleted cargoes from the solid bulk cargo list:

Bulk cargo shipping name (BCSN)	Group	Hazard
FISH MEAL (FISH SCRAP), STABILIZED UN 2216 ANTI-OXIDANT TREATED	B	This cargo has effectively been reclassified from Class 9 dangerous goods to an MHB cargo. The IMSBC Code carriage requirements remain the same, but ships will no longer require a dangerous goods certificate to carry the cargo.

• The list of non-cohesive cargoes (Appendix 3 of the IMSBC Code) has been amended to include the following cargoes:
  • BARYTE, FLOTATION CHEMICAL GRADE
  • CRUSHED GRANODIORITE FINES
  • DUNITE
  • DUNITE FINES
  • ELECTRIC ARC FURNACE DUST, PELLETIZED
  • POTASSIUM NITRATE
  • SODIUM NITRATE
  • SODIUM NITRATE AND POTASSIUM NITRATE MIXTURE
  • SUPERPHOSPHATE

This means that the angle of repose for the above cargoes must be determined prior to loading so that the relevant trimming provisions under section 5 of the IMSBC Code are applied accordingly.

• The list of Solid Bulk Cargoes for which a Fixed Gas Fire Extinguishing System may be exempted has been updated to its 6th revision to include the new cargo "ELECTRIC ARC FURNACE DUST, PELLETIZED" that can be exempted from having a fixed CO2 fire-fighting installation on board ships (MSC.1/Circ.1395/Rev.6).

Members involved in transporting solid bulk cargoes are recommended to ensure compliance with the latest IMSBC Code amendments.

Amendments to the STCW Convention and Code on Electronic Seafarers’ Certificates – MSC.540(107) & MSC.541(107)

To support the global digitalisation trend, these amendments to the STCW Convention (regulations I/1 and I/2) and STCW Code (section A-I/2) allow seafarers’ certification to be issued in electronic form and specify the minimum information that must be included on these certificates.

Members are recommended to refer to the MSC.1/Circ.1665 for guidelines on the use of electronic certificates of seafarers.

Amendments to MARPOL Annex I, Regulations 15.3, 15.5 and 34.3 to 34.5, on the establishment of the Red Sea and Gulf of Aden as Special Areas – MEPC.381(80)

Due to their significant marine ecological and environmental conditions, as well as their importance as a major route for maritime commerce, the Red Sea and Gulf of Aden regions were recognised as a ‘Special Area’ under regulation 1.11 of MARPOL Annex I. However, for the ‘Special Area’ status to take effect, adequate reception facilities had to be provided in the relevant ports of the coastal State Parties.

MEPC-80 confirmed that States in the Red Sea and Gulf of Aden areas, such as Djibouti, Egypt, Jordan, Israel, Saudi Arabia, Somalia, and Sudan, now provide adequate reception facilities and arrangements, including treatment facilities for oily wastes and residues at ports and terminals in these areas. Accordingly, the effective date for MARPOL Annex I Special Areas in the Red Sea and Gulf of Aden is set to be 1 January 2025.

Members with ships of 400 GT and above are advised that from 1 January 2025, the discharge of oil or oily mixtures into the sea will be prohibited within this region, except under the following conditions:

1. The ship is enroute.
2. The oily mixture has been processed through oil filtering equipment that meets the requirements of regulation 14.7 of Annex I.
3. The oil content of the effluent, without dilution, does not exceed 15 parts per million.
4. The oily mixture does not originate from cargo pump room bilges on oil tankers.
5. In the case of oil tankers, the oily mixture is not mixed with oil cargo residues.
   • Fuel consumption per consumer, both while underway and at anchor

Additionally, members operating oil tankers in this region are informed that from 1 January 2025, any discharge of oil or oily mixtures from the cargo area of an oil tanker will be prohibited while in the Red Sea and Gulf of Aden Special Areas. This requirement does not apply to the discharge of clean or segregated ballast.

Amendments to MARPOL Annex V, Regulation 6, on the establishment of the Red Sea as Special Areas – MEPC.382(80)

The Red Sea area was recognised as a Special Area under Annex V (regulation 1.14.4) of MARPOL. However, for the ‘Special Area’ status to be effective, adequate reception facilities had to be provided in the relevant ports of the coastal State Parties.

At MEPC-80, the special area status was confirmed based on information about the necessary reception facilities for MARPOL Annex V wastes and residues at all ports and terminals in the region.

Members with ships transiting through the Red Sea area are advised that from 1 January 2025, the discharge of garbage into the sea shall only be permitted while the ship is enroute and in accordance with Regulation 6 (Discharge of garbage within special areas) of MARPOL Annex V.

Regulation coming into force on 1 February 2025

Amendments to Appendix II of the BWM Convention concerning the revised form of the Ballast Water Record Book (BWRB) – MEPC.369(80)

Regulation B-2 of the BWM Convention requires that ships shall have a BWRB which shall at least contain the information specified in Appendix II to the Convention (Form of Ballast Water Record Book).

A report on the experience-building phase associated with the BWM Convention indicated that the most frequently reported deficiencies by PSC were related to the entries in the BWRB.

To address these issues, Appendix II of the BWM Convention has been updated to enhance and clarify the information recorded in the BWRB.

Members are recommended to refer to the BWM.2/Circ.80 for guidance on ballast water record-keeping and reporting and to ensure that their ships complete and maintain the newly agreed format of the BWRB from 1 February 2025.

Regulation coming into force on 1 May 2025

Amendment to MARPOL Annex VI, Regulation 14, and Appendix VII on Mediterranean Sea ECA – MEPC.361(79)

Since 1 May 2024, the Mediterranean Sea has been designated as an Emission Control Area (ECA) for sulphur oxides (SOx) and particular matter (PM); however, these requirements will take effect from 1 May 2025 and then onwards it will be mandatory for ships to either use fuel oil with a sulphur content of 0.10% m/m or utilize an exhaust gas cleaning system (EGCS) while sailing through the Mediterranean Sea ECA.

Members with ships trading or transiting the Mediterranean Sea region are recommended to take note of these requirements and comply accordingly.

Regulation coming into force on 26 June 2025

Hong Kong Convention on Ship Recycling – MEPC.210(63)

The Hong Kong Convention (HKC) applies to ships over 500 GT engaged in international voyages. It aims to ensure that ship recycling does not pose unnecessary risks to human health, safety, or the environment. The regulations outlined in the Convention cover the design, construction, operation, and preparation of ships for safe and environmentally sound recycling.

After its entry into force, new ships (built on or after 26 June 2025) will be required to have an approved and certified Inventory of Hazardous Materials (IHM) onboard. By 26 June 2030, existing ships must also have an approved and certified IHM onboard.

Additionally, Members will need to ensure that they complete and compile the necessary Material Declarations (MD) and Supplier Declarations of Conformity (SDoC) for any items supplied to the ship that are part of the ship’s structure or fitted equipment.

An initial survey will be required to verify the inventory of hazardous materials. Additional surveys will be required during the ship’s operational life, as well as a final survey before recycling (MEPC.222(64)).

At the end of its life, the ships to which this Convention applies can only be recycled at HKC-compliant ship recycling facilities (MEPC.211(63)).

Ship recycling facilities will have to prepare a Ship Recycling Plan specifying how each ship will be recycled, basis which a Ready for Recycling certificate will be issued.

For further information, Members are recommended to refer to the Club’s Risk Focus: Inventory of Hazardous Materials (IHM) – 2nd Edition.

Regulations coming into force on 1 August 2025

Amendments to MARPOL Annex VI (Low-Flashpoint Fuels and Other Fuel Oil Related Issues, Marine Diesel Engine Replacing Steam System, Accessibility and Inclusion of Data on Transport Work and Enhanced Granularity in the IMO Ship Fuel Consumption Database (IMO DCS)) – MEPC.385(81)

Amendments to Regulations 2, 14 and Appendix I of MARPOL Annex VI revise the definition of gas fuels to align with the IGF Code and clarify that the in-use/onboard sampling points shall not apply to gas/low-flashpoint fuels. Furthermore, Regulation 18 is amended to apply bunker delivery note (BDN) requirements to gas/low-flashpoint fuels. Members with ships using gas or low-flashpoint fuels are recommended to ensure that the minimum information is included in the BDN.

Amendments to Regulation 13.2.2 of MARPOL Annex VI clarify that replacing a steam system with a diesel engine is considered a major conversion, rather than a minor modification. Where a Tier III engine would be required and a Tier II engine is permitted for installation as the replacement, the flag Administration must report this to the IMO. Members need to be aware that any replacement of a steam system with a marine diesel engine after these amendments take effect on 1 August 2025, will require compliance with Regulation 13 of MARPOL Annex VI, and any amendments thereof.

Amendments to Regulation 27 of MARPOL Annex VI allow IMO to share ship’s fuel oil consumption data with analytical consultancies and research entities, under strict confidentiality and with the company’s consent, in a non-anonymized form. Additionally, under the Appendix IX of MARPOL Annex VI, there are new obligations to report the following data:

• Total onshore power supplied
• Total transport work
• Installation of innovative technology
• Laden distance travelled (on a voluntary basis)

Before the entry into force date, members with ships of 5,000 GT and above are recommended to ensure that their SEEMP Part II is modified as necessary to incorporate the collection of this newly required data.

Regulations coming into force on 1 October 2025

Amendments to regulations A-1 and B-2 of the BWM Convention on the use of electronic record books – MEPC.383(81)

These amendments allow the Ballast Water Record Book to be electronic and ensure a harmonised approach with the MARPOL Annexes and the NOx Technical Code. Members opting to use electronic record books to comply with the ballast water management convention are recommended to refer to the Guidelines for the use of electronic record books under the BWM Convention (MEPC.372(80)).