Refers to: Ship-owners, Operators, Masters and Managers of PHRS certified vessels 

Effective Date: Various

Dear All, 

 

The purpose of this Newsletter is to inform all interested parties about the upcoming regulatory amendments entering into force in 2026 (January-March-July): 

 

Amendments to LSA Code – single fall and hook systems – Adopted by MSC.554 (108)

Entry into force: 1 Jan 2026

 

Lifeboats and rescue boats fitted with single-fall and hook systems present a risk of potential accidental release during recovery operations, similar to those equipped with twin-fall and hook systems. In response, the IMO has adopted amendments to ensure adequate safety standards for lifeboats and rescue boats fitted with single-fall and hook systems.

The updated requirements apply to all new installations of lifeboats and rescue boats equipped with a single-fall and hook system. The amendments stipulate that, in order to prevent accidental release during recovery, the hook shall not be capable of supporting any load unless it is completely reset. In cases where the hook is capable of releasing the lifeboat or rescue boat under load when it is not fully waterborne, the operating handle or safety pins shall not be able to return to the reset (closed) position, and any indicators shall not show that the release mechanism is reset, unless the hook is fully reset.

 

Applicability: 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

(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.

 

Amendments to the International Life-Saving Appliance (LSA) Code - Ventilation of totally enclosed lifeboats - Adopted by MSC.535(107)

Entry into force: 1 January 2026

 

Totally enclosed lifeboats shall be designed and fitted with a ventilation system capable of providing a ventilation rate of at least 5 m³/h per person, based on the maximum number of persons the lifeboat is certified to accommodate, for a continuous period of not less than 24 hours.

 

Applicability: This applies to all totally enclosed lifeboats installed on ships on or after 1 January 2029. The expression "installed on or after 1 January 2029" means:

(a) for ships for which the building contract is placed on or after 1 January 2029, or in the absence of the contract, constructed on or after 1

January 2029, any installation date on the ship; or

(b) for ships other than those ships described in (a) above, a contractual delivery date for the equipment to the ship on or after 1 January 2029 or, in the absence of a contractual delivery date, the actual delivery date of the equipment to the ship on or after 1 January 2029.

 

Amendments to the LSA Code to address the in-water performance of SOLAS adult lifejackets. - Adopted by MSC.554(108)

Entry into force: 1 January 2026

 

The minimum performance standards for SOLAS-approved adult lifejackets will be enhanced, potentially requiring modifications to existing lifejacket designs to comply with the updated requirements. The amendments ensure that lifejackets are designed and tested to turn the body of an unconscious person to a face-up position.

Lifejackets complying with the new standards will be required to be tested and approved accordingly prior to 1 January 2026. When replacing lifejackets on existing ships or procuring lifejackets for new buildings, it should be noted that the lifejackets must meet the revised performance standards and hold the appropriate approval.

 

Applicability: This will apply to new SOLAS adult lifejackets carried onboard cargo ships of S00GT and over and all passenger ships from 1 January 2026. The new requirements are applicable to new ships for which a building contract is in place or in the absence of a contract, the keel is laid or is at similar stage of construction on or after 1 January 2026. For existing ships, this will be applicable for all adult lifejackets with contractual delivery date or actual delivery date to the ship on or after 1 January 2026.

 

Amendments to SOLAS Chapter II-1|Regulation 3-13 (lifting appliances and anchor handling winches) - Adopted by MSC.532(107)

Entry into force: 1 January 2026

 

IMO has introduced new mandatory requirements addressing lifting appliances and anchor handling winches. Lifting appliances installed on or after 1 January 2026 will need to:

  • Be designed, constructed and installed in accordance with the requirements of a classification society recognized by the Administration.
  • Be 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 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.

 

Applicability: 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.

 

Amendments to SOLAS Chapter 11-2/20 - 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)

Entry into force: 1 January 2026

 

IMO has reviewed SOLAS chapter 11-2 and associated codes regarding vehicle, special category, ro-ro spaces and weather decks of new and existing ro-ro ships based on the findings of the FIRESAFE II study. It should be noted that the IMO issued the Interim guidelines for minimising the incidence and consequences of fires in ro-ro spaces and special category spaces of new and existing ro-ro passenger ships (MSC.1/ Circ.1615), pending changes to SOLAS, to address the risks related to ro -ro passenger ships.

The amendments to SOLAS chapter 11-2/20 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 stat ions and normally occupied service spaces.
  • Video monitoring on vehicle spaces, open and closed ro-ro spaces and special category spaces.
  • Fixed water-based fire-extinguishing systems to protect weather decks primarily using water monitor(s), with nozzles being acceptable for areas which monitors cannot cover. Detailed specifications for nozzles are also included as well as water supply capacity.
  • Changes to structural fi re protection of ro-ro and special category spaces including the protection from 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 stat ions 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).

 

Applicability: These amendments 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 chapter11-2/1.

 

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

  • SOLAS 11-2/20.4.1.6 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 11-2/20 paragraphs 4.1.1 to 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 Detect ion and Alarm Systems).
  • The requirements of SOLAS 11-2/20.4.1.5 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 11-2/20.4.4 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 11-2/20.5 regarding structural fi re protection and arrangement of openings: Applies to passenger ships constructed on or after 1 January

2026. Passenger ships constructed before 1 January 2026 shall comply with the previously applicable requirements of paragraph 5; and

  • SOLAS 11-2/20.6 regarding fire extinction: The requirements of paragraphs 6.2.1 and 6.2.2 regarding fixed water-based fire-extinguishing system on weather decks intended for carriage of vehicles shall apply to ro-ro passenger ships constructed on or after 1 January 2026. Passenger ships with vehicle, special category or ro-ro spaces constructed before 1 January 2026, including those constructed before 1 July 2012, shall comply with the requirements of paragraph 6.2.3 regarding fixed water-based fire-extinguishing system based on monitors not later than the first survey on or after 1 January 2028.

 

Amendments to SOLAS chapter 11-2 - Provisions to prohibit the use of fire-fighting foams containing PFOS - Adopted by MSC.532(107)

Entry into force: 1 January 2026

 

IMO developed amendments to SOLAS chapter 11-2 and consequential amendments to other instruments to prohibit the use of firefighting foams containing perfluorooctane sulfonic acid (PFOS) due to its toxic nature. The prohibition applies to both fixed and portable systems as the intent is to prohibit the use of all extinguishing media containing PFOS that can be used in fire extinguishing systems and equipment. Amendments are also applied to the 1994 (MSC.536(107)) and 2000 (MSC.537(107)) HSC Codes. Firefighting foams containing PFOS will be banned, and any substances containing PFOS will need to go to appropriate shore reception facilities.

Equipment manufacturers are to take note and change the chemical make-up of extinguishing media.

Ship-owners and Ship managers are to comply with carriage ban and remove the PFOS containing extinguishing media from ships to reception facilities ashore.

Applicability: 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. 

 

Amendments to the IGF Code - 2026

Entry into force: 1 January 2026

 

The IGF Code amendments incorporate a number of consolidations and additional new provisions. More specifically: 

The amendments are (but not limited to):

Part A-1

  • 4.2.2 - Necessary reference addition based on the proposed change to 8.4.2 listed below.
  • 5.12.1- For ships constructed on or after 1 January 2026, clarification as to whether the requirement for “door sill” applies to the outer doors (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:
  • reliquefaction of vapours;
  • thermal oxidation of vapours;
  • pressure accumulation; or .
  • liquefied gas fuel cooling.”area).

  • 7.3.2.1 - For ships constructed on or after 1 January 2026, the formula to ca lculate the thickness of the piping has been amended to make it clearer.
  • 8.4.1 to 8.4.3 - Changes aimed at addressing the leaks during bunkering operations at the connection between the bunker system and the bunkering manifold and aligning the IGF Code to ISO standard 21593:2019 and ISO 20519:2021. This change is available for early implementation (subject to the flag Administration's approval).
  • 9.3.1 - For ships constructed on or after 1 January 2026, fuel supply systems require redundancy and segregation so a leak or failure in one system doesn't result in an unacceptable loss of power. If there is leakage or failure, Administrations may accept partial reduction in propulsion capacity from normal.
  • 9.4.7 - For ships constructed on or after 1 January 2026, automatic ventilation of the gas supply pipe between the master valve and the double block and bleed valves is required, 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 11-2/9, 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 - lnterbarrier spaces are now considered Hazardous area zone 0. Applicable to ships constructed on or after 1 January 2026.
  • 12.5.2.1 - lnterbarrier spaces are removed from Hazardous area zone 1. Applicable to ships constructed on or after 1 January 2026.
  • 15.4.1.3 - Since the requirements for the liquid level gauging in the IGF Code should be more in line with the IGC Code, additionally to 15.4.1.3.1and 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.

 

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

- for which the building contract is placed on or after 1 January 2026;

- in the absence of a building contract, the keels of which are laid or which are at a similar stage of construction on or after 1 July 2026; or

- the delivery of which is on or after 1 January 2030.

 

Amendments to SOLAS chapter XIV and Related Amendments to the Polar Code - Adopted by

MSC.532(107) and MSC.538(107)

Entry into force: 1 January 2026

 

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

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

 

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

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

 

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

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

For the purpose of this requirement, "constructed" means a ship the keel of which is laid or which is at a similar stage of construct ion.

At 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 tones or 1 % of the estimated mass of all structural material, whichever is less.

 

Amendments to SOLAS Chapter V and associated certificates - Mandatory carriage of electronic Inclinometers on container ships and bulk carriers - Adopted by MSC.532(107)

Entry into force: 1 January 2026

 

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

 

Ship-owners will need to comply with the new requirements, which apply to new bulk carriers and container ships.

The new requirements will not apply to:

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

 

Applicability: The new regulations will enter into force 1 January 2026 and will be applicable to new bulk carriers and container ships of 3.000 GT and above, constructed on or after this date. The requirements will not apply retroactively to existing container ships and bulk carriers.

 

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

MSC.556(108)

Entry into force: 1 January 2026

 

The IMDG Code has been revised to incorporate the amendments issued as Amendment 42-24, now reflected in the 2024 Edition. The revision will add new amendments to the Code and new and/or revised requirements for both new and existing substances.

Such amendments include (but are not limited to):

  • changes to the definition for "Recycled plastics 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 "Dl-2,4-DICHLOROBENZOYL PEROXIDE"
  • new entries: DIBENZOYL PEROXIDE, 2,5-DIMETHYL-2,5-Dl-(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 t hose in clinical trials, and that contain GMMOs or GMOs are not subject to this Code.
  • amendments to Chapter 3.2 - Dangerous Goods List
  • amendments to Chapter 3.3 - Special provisions applicable to certain substances, materials or articles
  • amendments to Chapter 4.1 - Use of packaging, including intermediate bulk containers (IBCs) and large packaging
  • amendments to 4.1.6 Special packing provisions for goods of class 2
  • amendments to Chapter 4.2 - Use of portable tanks and multiple-element gas containers (MEGCs)
  • amendments to Chapter 5.2 - Marking and labelling of packages including IBCs
  • amendments to Chapter 5.3 - Placarding and marking of cargo transport units and bulk containers
  • amendments to Chapter 5.5 - Special provisions
  • amendments to Chapter 6.1 - Provisions for the construction and testing of packaging (other than for class 6.2 substances)
  • amendments to Chapter 6.2 - Provisions for the construction and testing of pressure receptacles, aerosol dispensers, small receptacles

containing gas (gas cartridges) and fuel cell cartridges containing liquefied flammable gas

  • amendments to Chapter 6.5 - Provisions for the construction and testing of intermediate bulk containers (IBCs)
  • amendments to Chapter 6.6 - Provisions for the construction and testing of large packaging
  • amendments to Chapter 6.7 - Provisions for the design, construction, inspection and testing of portable tanks and multiple-element gas containers (MEGCs)
  • amendments to Chapter 6.10 - Provisions for the design, construction, inspection and test ing of portable tanks with shells made of fiber reinforced plastics (FRP) materials
  • new entries in Appendix B - Glossary of terms

 

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

 

Amendments to the International Code for the Safe Carriage of Grain in Bulk (MSC.23(59}) – loading conditions - Adopted by MSC.552(108)

Entry into force: 1 January 2026

 

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

Ship-owners and operators of ships carrying grain in bulk should take note of new provisions for loading grain when dealing with "partially filled compartments" and how to calculate the total heeling moment.

 

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

 

Amendments to SOLAS V/31 and V/32, and to Protocol I of MARPOL Article V- Reporting on the loss of containers - Adopted by MEPC.384(81) and MSC.550(108)

Entry into force: 1 January 2026

 

Following the recurrent loss of containers, and in response to the danger submerged containers pose to shipping, MSC 108 adopted amendments to SOLAS Chapter V to make the reporting of lost, or the observance of lost, freight containers mandatory through a standardized procedure. In the same context, MEPC 81 also adopted amendments to Article V of Protocol I of the MARPOL Convention.

The Master of every ship involved in the loss of any number of freight containers is required to report the incident without delay to both the nearest coastal State, any ships in the vicinity and to the Flag State. The Master of every ship that observes freight container(s) drifting at sea, shall communicate the particulars of such an observation to any ships in the vicinity and to the nearest coastal State.

 

Applicability: The regulations apply to any ship carrying one or more containers or observing lost containers. 

 

Amendments to the 2011 ESP Code - Modifications to the Procedures for approval and certification of a firm engaged in thickness measurement of hull structures - Adopted by MSC.553(108)

Entry into force: 1 January 2026

 

The amendments will better specify that Administrations can exercise the right to audit a firm conducting thickness measurement of hull structures. The current text in the ESP Code was observed to be unclear on this matter. The impact of the proposed changes should be minimal and affect those Administrations which might want to certify a firm for thickness measurement.

 

Applicability: This specific amendment should affect Administrations engaged in approval of firms conducting thickness measurement of the hull structures of bulk carriers and oil tankers of S00GT and above.

 

Amendments to the International Code of Safety for High-Speed Craft, 1994 (1994 HSC Code}

Chapter 7 - Provisions to prohibit the use of fire-fighting foams containing PFOS - Adopted by

MSC.536(107)

Entry into force: 1 January 2026

 

IMO developed amendments to SOLAS chapter 11-2 and consequential amendments to other instruments to prohibit the use of firefighting foams containing perfluorooctane sulfonic acid (PFOS) due to its toxic nature. The prohibition applies to both fixed and portable systems as the intent is to prohibit the use of all extinguishing media containing PFOS that can be used in fire extinguishing systems and equipment. Amendments are also applied to the 1994 (MSC.536(107)) and 2000 (MSC.537(107)) HSC Codes. Firefighting foams containing PFOS will be banned, and any substances containing PFOS will need to go to appropriate shore reception facilities. Ship-owners and Ship operators are to comply with carriage ban and remove the PFOS containing extinguishing media from ships to reception facilities ashore.

 

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

 

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

Entry into force: 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. Shipyards and equipment manufacturers will need to comply with the new requirements.

Applicability: 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 January2026. "Ships constructed on or after 1 January 2026" mean ships, the keels of which are la id or which are at a similar stage of construction, on or after 1 January 2026.

 

Amendments to the resolution MSC.402(96) - Requirements for maintenance, thorough examination, operational testing, overhaul and repair of lifeboats and rescue boats, launching appliances and release gear - Adopted by MSC.559(108)

Entry into force: 1 January 2026

 

As a consequence of the amendments to the LSA Code and resolution MSC.81(70) with regard to new ventilation requirements for totally enclosed lifeboats, MSC 108 adopted an amendment to resolution MSC.402(96). This amendment includes the requirement for the examination and check of the 'ventilation system, where fitted' for satisfactory condition and operation on lifeboats (including free-fall lifeboats), rescue boats, and fast rescue boats.  Totally enclosed lifeboats will need to undergo satisfactory examination and check with regard to their ventilation systems as per the new requirements detailed in MSC.535(107).

 

Applicability: 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.

 

Amendments to SOLAS regulation 11-2/4 related to oil fuel parameters other than flashpoint - Adopted by MSC.550(108)

Entry into force: 1 January 2026

The amendment adds a new sub-paragraph to SOLAS 11-2/4 to ensure that oil fuel delivered to and used on board ships shall not endanger the safety of ships or adversely affect the performance of the machinery or be harmful to personnel. Oil fuel suppliers will need to comply with the new requirements. Ship managers will need to ensure that they order oil fuel that is suitable for the ship and not harmful to personnel.

Applicability: 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.

 

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)

Entry into force: 1 March 2026

 

MEPC 82 adopted amendments to MARPOL Annex VI which will give effect to an ECA in the Canadian Arctic for NOx and SOx. This ECA is comprised of two segments starting at the Yukon mainland at 68.900° North 137.000° West; and ending at the north coast of Hans Island

at 80.83183° North 66.45667° West and continuing from the south coast of Hans Island at 80.82144° North 66.45067° West, and ending at the coast of Newfoundland and Labrador at 60.000° North, 64.160° West. Ship-owners 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 Ill engine. In addition, ship-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.

 

Applicability: NOx requirements: Ships the keels of which are laid or at a similar stage of construction on or after 1 January 2025 which have a marine diesel engine with power output of more than 130kW and operating within the ECA / SOx requirements: Ships operating in the ECA from 1 March 2027

 

Amendments to MARPOL Annex VI establishing the Norwegian Sea Emission Control Area (ECA) for nitrogen oxides, sulphur oxides and particulate matter - Adopted by MEPC.392(82)

Entry into force: 1 March 2026

 

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

Applicability: 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 construct ion on or after 1 September 2026; or • The delivery of which is on or after 1 March 2030. SOx Requirements: Ships operating in the ECA from 1 March 2027.

 

Amendment to the IGC Code - paragraph 16.9 - Alternative fuels and technologies - on the possibility to use toxic cargo as fuel if accepted by the Administration - Adopted by

MSC.566(109) 

Entry into force: 1 July 2026

 

IGC Code Chapter 16.9 - Alternative fuels and technologies has been amended to allow the use of toxic cargo as fuels, subject to approval of the ship's flag Administration. Gas carriers, to which this amendment applies, will be allowed to use toxic cargo as fuel if they are able to demonstrate an equivalent level of safety to using natural gas (methane) carried as cargo as fuel. Special agreement from the ship's flag Administration will be required to permit this from 1 July 2026.

Applicability: The amendments apply to new and, retroactively, to existing 2G/2PG ships which carry cargoes identified as toxic products in the IGC Code and are subject to the IGC Code.

 

Amendments to the NOx Technical Code with regard to certification of an engine subject to substantial modification or being certified to a Tier to which the engine was not certified at the time of its installation - Adopted by MEPC.398(83)

Entry into force: 1 September 2026

 

MARPOL Annex VI, regulation 13, permits substantial modifications and therefore re-certification of already installed engines. Therefore, 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. Ship Owners 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. 

 

Applicability: 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.

Refers to: Ship-owners, Operators, Masters and Managers of PHRS certified vessels

Effective Dates: Immediate

 

 Dear All,

 

The purpose of this Newsletter is to inform all interested parties about the Marine Advisory 42/2025 on Russia- Related Sanctions issued by the Liberian Registry.  

 

  • On October 22, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) imposed full blocking sanctions pursuant to E.O. 14024 against Russian energy companies: PJSC Lukoil Oil Company (“Lukoil”) and PJSC Rosneft Oil Company (“Rosneft”), along with subsidiaries.

https://home.treasury.gov/news/press-releases/sb0290

  • The United Kingdom’s Office of Financial Sanctions Implementation (OFSI) of the HM Treasury, on October 15, 2025, sanctioned companies including but not limited to Rosneft and Lukoil.

https://www.gov.uk/government/publications/list-of-russia-sanctions-targets-15-october-2025/list-of-russia-sanctions-targets-15-october-2025

  • The EU, on October 23, 2025, further expanded transactional bans against companies including but not limited to Rosneft and Gazprom Neft as part of the 19th sanctions package.

https://eur-lex.europa.eu/eli/reg/2025/2033/oj/eng

 

Whereas the above sanctions designations and their respective companies represent a significant portion of Russia’s oil production and output, and have extensive global operations and broad international maritime touchpoints for marine vessels—including, but not limited to, exploration, drilling, extraction, transportation, distribution, bunkering, barge activities, and port operations.

Thus, as a condition of the Liberian Flag, all vessels (1) must be in compliance with OFAC sanctions laws and regulations and (2) must be in compliance with other international sanctions jurisdictions, as applicable.

 

Any vessels deemed to be non-compliant with respective sanctions laws and regulations, will be de-flagged and their related companies annulled from the Corporate Registry.

 

Moreover, all tankers that load at a Russian port or transact with Russian-origin oil or petroleum products must submit a “Per-Voyage Attestation”/ RLM 400-02 which accounts for applicable price caps and related sanctions designations.

 

For further information regarding this Advisory, contact Compliance@liscr.com or / technical@phrs.gr .

Refers to: Ship-owners, Operators, Masters and Managers of PHRS certified vessels

Effective Dates: December 2025

 

The purpose of this Newsletter is to inform all interested parties about the issuance of Circular 328/2025 by Maritime Cook Islands. In order to simplify the correct application of MLC Regulation 2.3 – Hours of Work and Hours of Rest and to prevent non-conformities raised by external auditors or Port State Control, we strongly recommend the use of the attached MLC Work Rest Tool, which enables effective monitoring of MLC hours of work and rest.

 

We would like to highlight that in application of the MLC standards, each vessel shall take into account the danger posed by the fatigued seafarers, especially those whose duties involve navigational safety and the safe and secure operation of the ship.

 

It is therefore, in the common interest of all the parties involved, to ensure the limits fixed by Regulation 2.3 of the MLC are complied with.

The attached tool gives you a tool to monitor the hours worked on board and will help to identify immediately any inability to comply with the MLC Regulation 2.3.

 

Guidelines for the use of the MLC Work Rest Tool.

 

The file is password-protected, ensuring the formulas and layout of the tool remain intact.

In the first sheet, you can fill in the vessel and seaman details, which will be automatically reported on all subsequent pages.

 

You also have a sheet “sample” as a guideline for filling.

The hours shall be indicated with the following letters:

“w” means working hours

“r” means rest hours

“n” means neutral hours (this letter shall be used in case of more than two rest periods in one day, in application of the rule 2.3.6 “hours of rest may be divided into no more than two periods, one of which shall be at least six hours in length, and the interval between consecutive periods of rest shall not

exceed 14 hours”).

 

 

The Work Rest Tool has been updated to reflect the year 2026, but you can start using it from December 2025 to maintain continuity into the upcoming year.

Refers to: Ship-owners, Operators, Masters and Managers of PHRS certified vessels

Effective Dates:  01 January 2026

 

Dear All,

 

The purpose of this Newsletter is to inform all interested parties about Marine Advisory – 40 issued by the Liberian Registry, regarding the mandatory application of amendments to the Ship Energy Efficiency Management Plan (SEEMP) Part II and reporting of revised fuel oil consumption data commences on 1 January 2026.

 

Resolution MEPC 385(81) adopted amendments to appendix IX of revised MARPOL Annex VI specified in Attachment 4 of reference (c) providing for collection of fuel oil consumption data with an enhanced level of granularity, which entered into force on 1 August 2025.

 

Resolution MEPC 388(81) adopted amendments to the 2022 Guidelines for the development of a Ship Energy Efficiency Management Plan (SEEMP) (resolution MEPC.346(78)) to include a methodology that will be used to collect the data with the enhanced level of granularity. As a consequence, Resolution MEPC 395(82) adopted amendments to appendix 3 “The Standardized Data Reporting Format for the DCS and Operational CI to the Administration” of the 2022 Guidelines adopted as Resolution MEPC.346(78) as amended; hereafter called the 2024 Guidelines for the development of a Ship Energy Efficiency Management Plan (SEEMP). Resolution MEPC 401(83) adopted amendments to the 2024.

 

Guidelines for the development of a SEEMP providing guidance on what is considered ‘under way and not under way’.

 

Mandatory Implementation

 

It should be noted that no later than 1 January 2026, the SEEMP shall be developed taking into account guidelines in MEPC Resolution 395(82), as amended; and each ship shall collect data specified in Attachment 4 of reference (c) and report fuel oil consumption data using the standardized format specified in revised Attachment 5 of reference (c), within 3 months after the end of 2026 (i.e. from January to March 2027) for each ship of 5,000 gross tonnage and above engaged in international voyages.

 

Within 3 months after the end of each calendar year, each ship of 5,000 gross tonnage and above engaged in international voyages, which falls into one or more of the categories on the list below shall continue to report to the Verifier, the attained annual operational CII, via electronic communication and using the standardized format in revised Attachment 5 of reference (c).

 

  • Bulk Carrier (2.2.5)    
  • Combination Carrier (2.2.7)
  • Containership (2.2.9)  
  • Cruise Passenger Ship (2.2.11)          
  • Gas Carrier (2.2.14)
  • General Cargo Ship (2.2.15) 
  • LNG Carrier (2.2.16)
  • Refrigerated Cargo Carrier (2.2.22)
  • Ro-Ro Cargo Ship (2.2.26)     
  • Ro-Ro Cargo Ship (Vehicle Carrier) (2.2.27)
  • Ro-Ro Passenger (2.2.28)
  • Tanker (Oil/Chemical) (2.29)

 

Ship-owners and Operators of Liberian flagged ships with SEEMP Part II already onboard their ships, are encouraged to submit their ships’ amended SEEMP Part II as soon as possible, for review and verification to one of the authorized Verifiers listed in Appendix 1.

 

The sources mentioned in the above text are available in the links listed below.

For more information, please contact the Regulations and Standards Department at RegsandStandards@liscr.com .

We are proud to have successfully completed another training session!

The Annual Refreshing Training for GR Surveyors Network, conducted by Phoenix Register of Shipping at the Eugenides Foundation, was a great success.

Our warmest thank you to the Eugenides Foundation for their hospitality and seamless support, and to everyone who joined us and contributed with their engagement and professionalism.

Together, we remain committed to advancing safety and quality across the maritime sector. 

 

WhatsApp Image 2025 12 02 at 12.42.28 PM

 

Refers to: Ship-owners, Operators, Masters and Managers of PHRS certified vessels

Effective Dates:  N/A

 

The purpose of this NL is to inform all Ship-owners, Operators, Masters and Managers of PHRS certified vessels about the Marine Advisory: 39/2025 - Concentrated Inspection Campaign (CIC) on Machinery and Electrical Failures issued by the Liberian Register, regarding a significant increase in machinery and electrical failures among ships navigating regions characterized by dense traffic, complex tidal patterns, and challenging meteorological conditions. Such failures have resulted in serious navigational incidents, prompting expanded Port State Control (PSC) inspections and stricter enforcement measures.

These incidents have raised concerns regarding navigational safety, environmental protection, and continuity of port operations.

 

Sudden failures such as main engine breakdowns, steering gear malfunctions, or power blackouts may lead to:

  • Collisions, groundings, or contact incidents
  • Blockage of major fairways disrupting traffic flow
  • Environmental pollution from oil or cargo spills
  • Endangerment of crew and vessel integrity

 

PSC Enforcement Actions

 

Any vessel experiencing mechanical or electrical failure within PSC navigable waters can be subject to an expanded PSC inspection. Focus areas may include:

 

  • Maintenance and testing records of propulsion and electrical systems
  • Crew familiarity with emergency and machinery-handling procedures
  • ISM Code compliance and verification of maintenance programs
  • Vessel’s past deficiencies and corrective actions

 

Vessels found with concealed or unresolved deficiencies risk:

 

  • Detention and PSC fines
  • Repair delays and financial losses (demurrage, off-hire)
  • Reputational harm to the owner/operator
  • Possible suspension of the Document of Compliance (DOC) or SMC

 

Preventive Measures for Ship Operators

 

   1.Pre-Departure and Pre-Entry Checks

  • Ensure comprehensive checks of:
  • Main and auxiliary engines
  • Steering gear, rudder control, and automation systems
  • Power generation and distribution systems
  • Emergency generator and backup circuits
  • Bilge, ballast, and firefighting systems

   2. Critical Operational Controls

  • Emphasize strict adherence to procedures during:
  • Fuel oil changeover
  • Generator load transfers and parallel operations
  • High-consumption equipment usage (e.g., bow thrusters)
  • Ballast/de-ballasting and blackout recovery drills 

  3. Maintenance and Training

  • Enforce proactive PMS-based maintenance routines
  • Conduct frequent emergency drills and familiarization
  • Ensure engineers are competent in troubleshooting and PMS usage

 

Mandatory Deficiency Reporting

 

Any machinery or electrical defect must be reported immediately to:

  • Port State Control
  • Flag Administration (Liberia)
  • Recognized Organization (Class Society)

 

Concealment of defects can be treated as violations of SOLAS, MARPOL, and the ISM Code, potentially resulting in detention and legal proceedings.

 

Immediate Actions Recommended

 

All owners, operators, and masters are advised to:

  • Reinforce onboard and shore-based safety cultures
  • Verify system readiness before port entry
  • Promote transparent defect reporting and continuous improvement
  • Engage Class and LISCR Fleet Prevention Department for advisory support

 

References:

  • SOLAS Ch. II-1, III & IX
  • MARPOL Annex I
  • ISM Code Sections 10 & 11

Shanghai MSA Circular on Machinery and Electrical Failures (2025)

 

For the complete text please find attached Marine Advisory 39/2025.

Also, find attached Questionnaire for the 2025 CIC on Machinery and Electrical Failures.

Refers to: Ship-owners, Operators, Masters and Managers of PHRS certified vessels

Effective Dates:  N/A

 

EMSA has released a new set of video tutorials designed specifically to help shipping companies meet the requirements of the FuelEU Maritime regulation and navigate the THETIS-MRV platform with ease.

The following three step-by-step videos are now available:

  • Report Voyage and Port Emissions

Guidance on correctly reporting voyage data and associated port emissions.

 

  • Split Voyages

Instructions on how to manage and report voyages that need to be divided within the system.

 

  • FuelEU Maritime Report Creation and Submission

A comprehensive walkthrough on preparing and submitting the annual FuelEU Maritime report.

 

These tutorials can be accessed directly through the dedicated THETIS-MRV tutorial page for companies and form part of EMSA’s ongoing efforts to support shipping companies in fulfilling their reporting obligations efficiently and accurately.

 

In addition, EMSA — in collaboration with the European Commission’s Directorate-General for Mobility and Transport — has produced a series of FuelEU Maritime webinars, which are available for replay on EMSA’s YouTube channel. These webinars offer further insights into the regulation and its implementation.

 

These new resources provide shipping companies with practical, user-friendly guidance to support compliance and streamline reporting processes.

Refers to: Ship-owners, Operators, Masters and Managers of PHRS certified vessels

Effective Dates:  N/A

 

The purpose of this NL is to inform all interested parties about Liberia’s Marine Advisory 36/2025 (available here) aiming to alert Ship-owners, Operators, Masters and Engine department personnel of very serious marine casualties involving Liberian-flagged vessels, specifically related to improper securing of heavy engine spares and inadequate engine room heavy weather preparedness.

 

Objectives:

  • Raise Awareness of the hazards and failures that contributed to these incidents.

  • Promote Accountability by emphasizing the responsibility of companies to investigate all casualties, incidents, and near misses thoroughly and implement corrective and preventive measures fleet-wide.

  • Ensure Compliance with Liberian Maritime Law (RLM-107), Regulations (RLM-108), and IMO requirements, including the ISM Code and MSC-MEPC.2/Circ.3 guidelines.

  • Guide Investigations by directing companies to follow international standards and best practices for casualty investigation and hazard mitigation.

  • Set Expectations for Reporting by clarifying that formal reports must include all evidence, statements, supporting documentation, and conclusions.

  • Encourage Cooperation with the Liberian Administration’s investigation process to ensure transparency and timely corrective action.
  • Prevent Future Casualties by fostering a proactive safety culture, improving operational discipline, and enforcing robust securing of heavy engine spares and heavy weather protocols across the fleet.

 

Marine Casualties Summaries - Background:

The Administration has identified two very serious marine casualties involving unsecured cylinder heads under the same Company:

 

A. First Case - Fatal Injury:

 

A crew member died from excessive bleeding after being struck by a cylinder head in the engine room during rough weather. Emergency medical assistance was coordinated, but the crew members were unable to provide effective first aid.

 

B. Second Case - Vessel Grounding and Total Loss:

 

A blackout occurred when a cylinder head in the engine room struck the generator’s fuel system. Three crew members sustained injuries. The vessel team was unable to restore the power. The vessel lost propulsion, grounded with cargo and consumables onboard, and was declared a total loss due to hull damage.

 

Key Safety Failures Identified:

  • Both incidents demonstrate a failure to investigate and implement corrective and preventive actions after the first casualty, leading to reoccurrence.
  • Improper securing heavy spares using belts/ropes instead of permanent arrangements.
  • Absence of engine room heavy weather checklist; risk assessments not accounting for unsecured spares.
  • Inadequate emergency preparedness and poor communication between the bridge and the engine room.

 

Requirements:

1.Reporting

 

  • Submit reports to the Administration along with the completed forms RLM-109 and RLM 109-1 according to the Liberian Regulations, Law, and the Marine Operations Notes requirements.
  • The formal investigation reports submitted by companies must include, but not be limited to:

  1. All evidence, including photographs, logs, and technical data.
  2. Statements from crew members, witnesses, and relevant personnel.
  3. Supporting documents, such as medical logs, maintenance records, and training certificates.
  4. A clear conclusion based on analysis of the facts and identification of root causes.
  5. Include corrective and preventive actions taken or planned to prevent reoccurrence.

 

2. Cooperation

 

  • Provide timely access to vessel records, crew interviews, and voyage data.
  • Fully cooperate with Liberian Administration investigations .

 

3. Timely Investigation:

 

  • Conduct a thorough internal investigation into marine casualties, incidents, and any related near misses.
  • Identify root causes, contributing factors, and systemic failures, IMO Guidelines – Appendix 7 of MSC-MEPC.2/Circ.3.

 

4. Review and Amend Safety Procedures:

 

  • Enforce robust securing arrangements for heavy spares (steel bars, welded brackets, chains).
  • Update SMS to include engine room heavy weather checklist and blackout mitigation protocols.

 

5. Enhance Crew Training:

 

  • Train engine department team on proper securing techniques and hazard identification.
  • Conduct drills for emergency coordination between bridge and engine room.

 

6. Improve Supervisory Oversight:

 

  • Require verification of securing arrangements by Chief Engineer and Master before heavy weather.
  • Implement superintendent audits for compliance.

 

7. Strengthening Communication Protocols:

 

  • Establish clear reporting lines between vessel(s) and the Company during adverse conditions.

 

8. Fleet-wide Awareness:

 

  • Issue safety alerts referencing the referred casualties.
  • Include lessons learned in pre-joining safety briefings and Company training platforms.
  • Conduct fleet-wide audits of securing arrangements and heavy weather preparedness.

 

The Administration emphasizes the importance of investigating marine casualties and implementing corrective and preventive measures, which are core responsibilities of every Company operating under the Liberian Flag.

The sources mentioned in the above text are available in the links listed below.

 

For more information, please contact the Investigations Department at investigations@liscr.com.

 

Refers to: Ship-owners, Operators, Masters and Managers of PHRS certified vessels

Effective Dates:  N/A

 

The purpose of this Marine Advisory is to draw the attention of ship-owners, operators, inspectors, masters and crew to the most common MARPOL Annex VI deficiencies raised during Port State Control (PSC) inspections of Liberian flagged vessels.

From the PSC reports, the Administration has compiled a list of most common MARPOL Annex VI deficiencies and has included in the table below Guidance to avoid these deficiencies:

 

Technical files and if applicable, monitoring manual

(MARPOL Annex VI/Reg. 13)

  • Each diesel engine which is certified to NOx Tier I, II or III must be issued an Engine International Air Pollution Prevention (EIAPP) Certificate and a NOx Technical File approved by the vessel’s RO on behalf of the Administration.  The EIAPP and TF are to be maintained on board the vessel.

  • The lMO ID number of fuel injection nozzles and other spare parts are to match those in the NOx technical file,

  • If an engine uses the Direct Measurement and Monitoring method, this is to be documented in an Onboard Monitoring Manual, approved by the vessel’s RO on behalf of the Administration.

  • Refer to Liberia MN POL-009/Applicability, Section 7.0 and 12.2.13.

 

Record book of engine parameters

(MARPOL Annex VI/Reg. 13 and NOx Technical Code/6.2.2.7))

A ship equipped with a marine diesel engine required to undergo an Engine Parameter Check method shall maintain on board:

1. A Record Book of Engine Parameters;

2. An engine parameter list of an engine’s designated components and settings and/or the documentation of an engine’s load-dependent operating values approved by the Administration; and

3. Technical documentation of engine component modification when such a modification is made to any of the engine’s designated engine components.

 

Record book of engine parameters (NOx Technical Code/6.2.2.8)

  • A record of the component identification numbers of engine parts that affect NOx emissions shall be made in the "Record book of engine parameters" and ensure they match the official "NOx Technical File" and "EIAPP Certificate". Key components include fuel injectors, pumps, camshafts, charge air coolers, pistons, and turbochargers, all of which need to be logged with their original and replacement ID numbers when a change is made.

 

Approved method

(MARPOL Annex VI/Reg. 13.7.1 to 13.7.5)

  • A marine diesel engine with a power output of more than 5,000 kW and a per cylinder displacement at or 90 L installed on a ship constructed on or after 1 January 1990 but prior to 1 January 2000 shall comply with the Tier I emission limits standards, provided that an approved method for the engine has been certified by an Administration of a Party and notification of such certification has been made to IMO. Section 2.2.1 of a vessel’s IAPP Supplement is to be completed appropriate depending of the ship-specific application of this regulation.

Refer to Liberia MN POL-009/12.2.6 to 12.2.8.

 

Exhaust Gas Recirculation (EGR)

(MARPOL Annex VI/Reg. 13)

 

Ships equipped with EGR to comply with NOx levels shall:

1. Meet the EGR bleed-off water discharge standards

2. Have on board a manual for EGR bleed-off discharge system and EGR Record Book approved by the RO on behalf of the Administration

3. Have on board certificates of type approval and operating and maintenance manuals of oil content meters (15 ppm alarm)

Refer to Liberia MN POL-009/12.2.9.

 

EGR or Selective Catalytic Reduction (SCR)

(MARPOL Annex VI/Reg. 13)

  • Ships installed with EGR or SCR and unable to comply with relevant NOx Tier III levels prior to entering a NOx ECA shall immediately notify the relevant coastal State(s) and the Administration.

Refer to Liberia MN POL-009/12.2.9 and 12.2.10.

 

Diesel engine air pollution control (MARPOL Annex VI/reg. 13.6)

  • The tier and on/off status of marine diesel engines installed on board a ship which are certified to both Tier II and Tier III or which are certified to Tier II only shall be recorded in the engineering log book or electronic record book approved by the Administration, suitable for that purpose at entry into and exit from an emission control area designated under regulation 13.6 of MARPOL Annex VI, or when the on/off status changes within such an area, together with the date, time and position of the ship.

Refer to MN POL-009/12.2.5.

 

Fuel Sulphur Content and Fuel Oil change-over procedure and SOx Records

(MARPOL Annex VI/Reg. 14)

  • The Sulphur content of any fuel oil carried for use on board a ship when operating outside a designated Sox ECA shall not exceed 0.50% m/m.

  • The Sulphur content of any fuel oil used on board ships when operating within a designated Sox ECA shall not exceed 0.10% m/m.  Current ECA’s are North American, United States Caribbean Sea, the Baltic Sea, the North Sea, and the Mediterranean Sea, and on 01 March 2026, the Canadian Arctic and the Norwegian Sea.

  • The maximum Sulphur content of marine fuels for use while at berth in EU ports is 0.10% m/m.

  • Vessels using separate fuel oils when entering or leaving an ECA must carry a written procedure showing how the fuel oil change-over procedure will be done, allowing sufficient time for the fuel oil service system to be fully flushed of all fuel oils exceeding the applicable Sulphur content prior to entry into an ECA.  The use of a “fuel oil change over calculator” is one way of ensuring the change-over is done in time. Refer to Liberia MN POL-009/12.3.8.

  • The volume of low Sulphur fuel oils in each tank as well as the date, time, and position of the ship when any fuel-oil-change-over operation is completed prior to the entry into an ECA or commenced after exit from such an area, shall be recorded in the engineering log book or in a record book or log book in electronic format (electronic record book) approved by the Administration. (The Administration’s Marine Sulphur Record Book may also be used for this purpose.)

 

Alternative arrangements (SOx) - EGCS

(MARPOL Annex VI/Reg. 14)

  • An exhaust gas cleaning system (EGCS) used as an equivalent or alternative arrangement to achieve the relevant Sulphur limit must be approved by the Administration. Refer to POL-009/12.3.9 and 12.3.10.

  • Ships operating with an EGCS shall have on board an EGCS record book approved by the vessel’s RO on behalf of the Administration.

 

Incinerator, including operations and operating manual

(MARPOL Annex VI/Reg. 16)

  • Shipboard incinerators are to be approved by the vessel’s RO on behalf of the Administration and issued a Type Approval certificate. Refer to Liberia MN POL-009/12.3.8.

  • Incinerators are to be provided with a manufacturer’s operating manual which is to be retained on board the vessel and which specifies how to operate the incinerator within its applicable limits.

 

It is recommended that shipowners, operators, masters and crew inspect their vessels to ensure that these deficiencies are not present on board their vessels and if it is found that one or more exist, to resolve this as quickly as possible, using the noted references and other guidance.

For more information, please refer to the links below.

 

If you have any questions or concerns, please contact the Regulations and Standards Department at RegsAndStandards@liscr.com.

Refers to: Ship-owners, Operators, Masters and Managers of PHRS certified vessels

Effective Dates:  N/A

 

As the reporting cycle for 2025 emissions approaches, it is essential for all operators to prepare for the upcoming verification milestones. To support timely compliance and ensure that PHRS can complete verification activities without delay, please review the key actions and deadlines outlined below.

This update covers requirements under:

 

  • FuelEU Maritime (FuelEU)
  • EU Monitoring, Reporting and Verification (EU MRV)
  • EU Emissions Trading System (EU ETS)
  • IMO Data Collection System (DCS) & Carbon Intensity Indicator (CII)

 

Key Submission Deadlines

 

FuelEU

  • 31 January 2026 – Submission of the ship-specific FuelEU report to the accredited verifier.
  • 31 March 2026 – Completion of verification.
  • 30 April 2026 – Verified FuelEU data must be confirmed in THETIS, including any applicable flexibility mechanism records.

Refer to the FuelEU Timetable for a complete overview of compliance milestones, including issuance of the Document of Compliance and payment of any penalties.

 

EU MRV

  • 31 March 2026 – Ship-level and company-level emissions data must be submitted to THETIS and verified.

Note: Some Administering Authorities may request verified data earlier, but not before 28 February 2026.

 

EU ETS

  • 31 March 2026 – Verified company emissions data (as reported in THETIS under EU MRV) must be entered into the Union Registry via the Maritime Operator Holding Account (MOHA) and validated by the Administering Authority.
  • If data is not submitted by 1 April 2026, the MOHA will be blocked.

If a company no longer falls within EU ETS scope (e.g., no EU/EEA port calls in the reporting year), it may request that its MOHA be designated as “excluded.”

 

IMO DCS & CII

  • 31 March 2026 – Submission of annual emissions data.
  • 31 May 2026 – Verification completed and Statement of Compliance issued on behalf of the Administration.
  • 30 June 2026 – Verified data submitted to the IMO GISIS system by the verifier.