Shipping on course for biofouling rules

Ahead of the IMO Sub-Committee on Pollution Prevention and Response (PPR 13 on 9-13 February 2026), three topics of concern were raised in the fouling submissions.

Across the submissions, the central question was not whether a mandatory regime is coming, but what form it should take and how it can be enforced without creating an unworkable burden for ships and ports.

The first cluster of concerns centred on the form of the legally binding framework: urging delegations to focus on practicality and enforceability when debating obligations.

A second cluster of concerns centred on what a future instrument should regulate: continuous management measures, inspection and recordkeeping, and how ports and port state control would apply them.

A third theme was the evidence base for in-water cleaning and what performance standards should look like, particularly for capture, filtration and post-treatment.

Industry submissions also sought to anchor the next phase in operational experience and to avoid rules that drive delay risk.

ICS, BIMCO, Intertanko and Intercargo told PPR that “practical biofouling management experience gained by industry should be considered” so the framework can “support ship operations”, and said restrictions that “may lead to a delay to ships and disruption of trade should be avoided”.

Norway’s draft provisions set out an indicative structure for regulations and supporting guidelines, including survey and certification, management measures, in-water cleaning, and anti-fouling systems, alongside forms such as an International Biofouling Management Certificate and a Biofouling Record Book.

Norway also proposed that IMO develop a guideline for testing and approval of in-water cleaning systems and a second guideline to standardise coating compatibility information, linking this to the need to address “biosecurity and chemical pollution” concerns that lead some ports to prohibit in-water cleaning and others to permit it under strict conditions.