Technical Circular

No.: 025/2024 Date: 25th November 2024

Subject: New IMO/ILO Requirements coming into force until 2025

Enclosed herewith please find the new IMO/ILO requirements coming in to force in 2025.

. This Technical Circular and the material contained in it is provided only for the purpose of
supplying current information to the reader and not as an advice to be relied upon by any
person.
. While we have taken utmost care to be as factual as possible, readers/ users are advised to
verify the exact text and content of the Regulation from the original source/ issuing Authority.
Whilst the utmost care has been taken in the compilation of the Technical Information, neither Indian Register of
Shipping, its affiliates and subsidiaries if any, nor any of its directors, officers, employees or agents assume any
responsibility and shall not be liable to any person for any loss, damage or expense caused in any manner
whatsoever by reliance on the information in this document.
 Summary of new IMO/ILO requirements coming into force in 2025
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1 MLC, 2006 The All All 23 All All 23 December 2022 Amendments to MLC, 2006:
International December 2024
Labour 2024 The 110th Session of the International Labour Conference held in June 2022 approved the amendments
Conference- to Maritime Labour Convention (MLC), 2006 and will enter into force from 23 December 2024.
110th session
The amendments cover seafarer welfare issues, such as:

• Social connectivity, including guidance to shipowners on providing internet access;

• Ensuring that seafarers are informed of their rights prior to engagement;
• Requirements for balanced and nutritious meals;
• Disembarkation for medical care;
• Prompt repatriation, including of the deceased; and
• Providing appropriately sized personal protective equipment.

The amendments also:

• Clarified that the required certificates of financial security can be issued in the name of the
registered owner, if different from the shipowner; and
• Require Member States to ensure seafarer fatalities are adequately investigated, recorded, and
reported to the ILO.

Ship Masters and the Company is to take note of above amendments to MLC, 2006 and are advised as
follows:

a. Review their processes to ensure they include the amended requirements no later than 23
December 2024, as the rights and obligations of the seafarers and shipowners as effected by the 2022
amendments to MLC, 2006 apply form the date of entry into force.

b. Ensure timely renewal of existing Maritime Labour Certificates and DMLC Part I & Part II in
consultation with the vessel’s Flag Administration or their RO.

Private RPS is required to establish a system of protection, by way of insurance or an equivalent

appropriate measure to compensate seafarers for monetary loss that they may incur as a result of the
failure of RPS or the relevant ship owner under the SEA to meet its obligation to them. Further, wef 23
December 2024, Seafarers are to be informed, prior to or in the process of engagement, of their
rights under above system and same is to be incorporated in the RPS procedures.

For details, refer IRS Technical Circular No. 021/2024, dated 16 September 2024.

2 IMSBC Code MSC.539(107) Ships All 1 January Ships All 1 January The amendments (07-23) to IMSBC Code includes (but is not limited to);
carrying 2025. carrying 2025.
IMSBC Administrati IMSBC Administration 1. Inclusion of definitions for “dynamic separation” and “Cargoes which may undergo dynamic
Cargo ons may Cargo s may apply it separation” (the formation of a liquid slurry (water and fine solids) above the solid material,
apply it on a on a voluntary resulting in a free surface effect which may significantly affect the ship's stability) into the forms

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voluntary basis as from 1 specifying the characteristics of the cargo and the required conditions for carriage and handling of
basis as January 2024. that cargo.
from 1
January
2024. 2. Revisions to various existing individual schedules for solid bulk cargoes.

3. Following new schedules have been added to Appendix 1 of the Code:

Cargo Group
CELESTINE CONCENTRATE A
BARYTE, FLOTATION CHEMICAL GRADE A
BROWN FUSED ALUMINA C
CRUSHED GRANODIORITE FINES A
DIRECT REDUCED IRON (D) (By-product fines with moisture content of at A&B
least 2%)
DUNITE C
DUNITE FINES A
ELECTRIC ARC FURNACE DUST, PELLETIZED A&B
FISH MEAL (FISH SCRAP), STABILIZED Anti-oxidant treated B
GROUND GRANULATED BLAST FURNACE SLAG POWDER A
MAGNESITE FINES A
POTASSIUM NITRATE C
SODIUM NITRATE C
SODIUM NITRATE AND POTASSIUM NITRATE MIXTURE C

4. Existing individual schedule - FISH MEAL (FISH SCRAP), STABILIZED UN 2216 Anti-oxidant treated is
deleted. (alignment of the stabilization requirements for fish meal with the IMDG Code, and
classification as MHB (SH) instead of class 9).

5. The amendments (07-23) also expressly identified “bulk density (as required by SOLAS regulation
XII/10)” as one of the cargo information which needs to be provided by shippers to ships before
loading.

6. MSC.1/Circ.1395/Rev.6 was adopted – Lists of solid bulk cargoes for which a fixed gas fire
extinguishing system may be exempted or for which a fixed gas fire extinguishing system is
ineffective.

Following new cargo is added in MSC.1/Circ.1395/Rev.6

• ELECTRIC ARC FURNACE DUST, PELLETIZED

Where a vessel intends to carry any of above cargo(es) and seeks exemption from a fixed gas fire
extinguishing system, IRS may be contacted for issuance of necessary exemption certificate in

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concurrence with the Flag Administration.

For details, refer IRS Technical Circular No. 037/2023, dated 06 November 2023.

3 BWM MEPC 369 (80) All All 01 February All All 01 February Amendments to the format of Ballast Water Record Book (BWRB):
Convention, 2025 2025
Appendix II Amendments to the form used for BWRB set out in Appendix II of the Ballast Water Management
Convention and a guidance providing sample entries of an amended BWRB were adopted.

On or after the effective date, the amended BWRB is to be used to record ballast water management
in accordance with this guidance. Same will be verified by the Surveyors at the first periodical survey
for the Ballast Water Management Convention on or after the effective date (01 February 2025).

The BWRB is to be maintained on board the ship for a minimum period of two years after the last entry
has been made and to remain thereafter in the Company's control for a minimum period of three
years.

4 MARPOL MEPC. 385(81) All 5,000 GT 1 August All 5,000 GT 1 August 2025 Amendments to MARPOL Annex VI on IMO Ship Fuel Consumption Database (IMO DCS):
Annex VI, MEPC.1/Circ. and above 2025 and above Administration
Reg. 27, 913 Administrati s may apply it 1. The IMO vide Resolution MEPC.385(81), adopted amendments to Appendix IX of MARPOL Annex VI
Appendix IX ons may on a voluntary – “Information to be submitted to the IMO Ship Fuel Oil Consumption Database (Regulation 27)”
apply it on a basis as from 1 introducing increased data granularity requirements.
voluntary January 2025.
basis as 2. These amendments make mandatory the reporting of the:
from 1
January • Fuel oil consumption per consumer type (Main engine(s), Auxiliary engine(s), Oil-fired boilers, and
2025. Others)
• Total amount of onshore power supplied expressed in kWh
• Fuel oil consumption per consumer type (Main engine(s), Auxiliary engine(s), Oil-fired boilers, and
Others) when the ship is not underway.

3. In addition, there is a new entry to report the laden distance travelled – on a voluntary basis - and
the installation of any innovative technology according to the 2021 Guidance on treatment of
innovative energy efficiency technologies for calculation and verification of the attained EEDI and
EEXI (MEPC.1/Circ.896).

4. Ships to which Regulation 28 of MARPOL Annex VI applies, shall also report the transport work using
tonne-mile, TEU-Mile and/or passenger-mile data, whereas container ships especially must report
both tonne-mile and TEU-mile data.

5. The amendments will enter into force on 1 August 2025.

6. Noting the fact that the aforementioned amendments are entering into force in the middle of a

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calendar year, which would result in two distinct levels of granularity for the data gathered in that
calendar year, MEPC 82 approved a Unified Interpretation vide MEPC.1/Circ.913 regarding the
application of these amendments.

7. Based on the above interpretation, ship owners and managers are advised as follows:

• For ships flying the flag of the Administration that implements the amendments on the entry-
into-force date (1 August 2025), the SEEMP is to be revised and verified prior to 1 January
2026 and data to be collected with existing level of granularity for the entire year of 2025, and
with increased granularity from 1 January 2026. Those planning to retrofit flow meters or
employ other methodologies should complete these actions within the same time frame.

• For ships flying the flag of the Administration that implements the amendments early (1
January 2025), the SEEMP is to be revised and verified prior to 1 January 2025 and data to be
collected with increased granularity throughout the entire year of 2025 and beyond. Those
planning to retrofit flow meters or employ other methodologies should complete these
actions within the same time frame.

• For ships delivered on or after 1 August 2025 data, SEEMP is to be developed to include a
description of data collection methodology and the data is to be collected at the enhanced
level of granularity from the date of delivery and onwards.

For details, refer IRS Technical Circular No. 024/2024, dated 18 November 2024.

5 MARPOL MEPC. 385(81) All All 1 August All All 1 August 2025 Amendments to MARPOL Annex VI related to low-flashpoint fuels and gas fuels:
Annex VI, 2025
Reg. 2, 14, 1. The IMO adopted Resolution MEPC.385(81) - Amendments to MARPOL Annex VI concerning low-
18, Appendix flashpoint fuels and other fuel oil related issues, marine diesel engine replacing steam system,
I accessibility of data and inclusion of data on transport work and enhanced granularity in the IMO
Ship Fuel Consumption Database (IMO DCS), introducing amendments to Regulations 2, 13, 14, 18,
27 and Appendix I of MARPOL Annex VI.

• In Regulation 2, the definition of fuel oil is revised as “any fuel delivered to and intended for use on
board a ship”. Additionally, an additional paragraph 1.33 is added for the definition of gas fuel,
aligned with the definition of ‘gas’ in IGF Code, to read “Gas fuel means a fuel oil with a vapor
pressure exceeding 0.28 MPa absolute at a temperature of 37.8˚C”.

• Paragraph 2.2 of Regulation 13 is revised to clarify that the installation of a marine diesel engine
replacing a steam system shall be also considered a replacement engine while also introducing a
footnote referring to the 2024 Guidelines as required by regulation 13.2.2 of MARPOL Annex VI in
respect of non-identical replacement engines not required to meet the Tier III limit (Resolution
MEPC.386(81)).

• Revision of Paragraph 12 in Regulation 14, states that the in-use/onboard sampling points

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requirements in Paragraphs 10 and 11 shall not apply to gas/low-flashpoint fuels.

• Furthermore, Regulation 18 is amended, and a new paragraph 5.2 is added, to apply BDN
requirements with minimum content to gas/low-flashpoint fuels. The BDN shall at least contain
the information specified in items 1 to 6 of Appendix V of Annex VI, the density determined by a
test method appropriate to the fuel type along with the associated temperature along and a
signed and certified declaration that the fuel oil conforms with the fuel oil quality requirements of
paragraph 3, Regulation 18.

Low-flashpoint/gas fuels in principle have very low sulphur content, however it was agreed that
this information shall still be documented in the BDN by the supplier either in terms of actual
value determined by a suitable test method or with the agreement of the appropriate authority at
the port of supply that the sulphur content is less than 0.001 percent m/m.

• In Regulation 27, Collection and Reporting of ship fuel oil consumption data, two new paragraphs
are added. These state that the Secretary-General of the Organization, under strict confidentiality,
may share data with analytical consultancies and research entities and, on the request of a
company, shall grant access to the fuel oil consumption reports of the company’s owned ship(s) in
a non-anonymized form.

• In addition, Paragraph 2.3.5, in Appendix I, Form of International Air Pollution Prevention (IAPP)
Certificate (Reg. 8) is modified to provide that the requirement for fitting or designating sampling
point(s) is not applicable for a fuel oil service system used for a low-flashpoint fuel or a gas fuel.

Ship owners are advised to take note of above requirements and are advised to ensure that the
Bunker Delivery Note includes information specified in Appendix V of MARPOL Annex VI for all the
fuel carried onboard including for gas fuel.

Revised IAPP Certificate a/with Supplement will be issued to the ship at the first renewal IAPP survey
on or after 1 August 2025.

6 Ballast Water MEPC. 383(81) All All 1 October All All 1 October Amendments to BWM Convention on Electronic Record Book Format:
Management 2025 2025
Convention 1. The IMO vide MEPC Resolution MEPC.383(81), adopted Amendments to the International
Convention for the Control and Management of Ship’s Ballast Water and Sediments, 2004 (Use of
Electronic Record Books), amending the International Convention for the Control and management
of Ship’s Ballast Water and Sediments, 2004, Appendix II (Form of Ballast Water Record Book).

2. Regulation A-1 - Definitions is amended to insert a new paragraph 9, which defines an Electronic
Record book as “a device or system, approved by the Administration, used to electronically record
the entries for each ballast water operation as required under this Convention in lieu of a hard copy
record book."

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3. Further, Regulation B-2 Ballast Water Record Book is amended to allow the Ballast Water Record
Book to be an electronic record book which shall at least contain the information specified in
Appendix II and It also provides that in case the record book entries are in electronic form, each
group of electronic entries is to be verified by the master in a timely manner.

4. The use of electronic record keeping systems for Ballast Water Record Books is permitted subject to
Administration’s / Recognized Organization’s approval and is based on the software confirming with
IMO Resolution MEPC. 372 (80).

5. When approved, a “Declaration of BWM Convention Electronic Record Book” will be issued by the
Administration / Recognized Organization which is to be kept onboard.

Ship owners/ managers intending to use electronic BWRB are advised to be guided by above and
may contact IRS HO for further guidance in this regard.

7 Hong Kong SR/CONF/45 All 5,00 GT and Ships for All 5,00 GT From 26 June Hong Kong International Convention for the Safe and Environmentally sound Recycling of Ships,
International above which the and above 2025 till 26 2009:
Convention building June 2030; or
for the Safe contract is before going The Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships
and placed on or for recycling (HKC) will enter into force on 26 June 2025.
Environment after 26 whichever is
ally sound June 2025; earlier This Convention shall apply to:
Recycling of OR
Ships, 2009 in the (i) Ships of 500 GT and above, and
absence of a (ii) Ship recycling facilities.
building
contract, The Convention shall not apply to the following:
the keel of
which is (i) Ships of less than 500 GT
laid, or (ii) ships operating throughout their life only in waters subject to the sovereignty or jurisdiction of
which is at a the State whose flag the ship is entitled to fly.
similar stage
of Accordingly, From 26 June 2025, all new ships will be required to be delivered with an approved
construction Inventory of Hazardous Materials (IHM) (Part I) and corresponding Certificate.
on or after
26 Existing Ships - No later than 25 June 2030 (or before going for recycling if this is earlier), all existing
December ships will be required to have an approved IHM (Part I), developed and hold a corresponding valid
2025; OR Certificate on board.
ships the
delivery of Ships to which Convention applies are to be recycled in a ship recycling facility holding valid Document
which is on of Authorization to Conduct Ship Recycling (DASR) from 26th June 2025 onwards.
or after 26
December Ship builders, Ship Owners/ Managers and Ship Recycling Companies are advised to take note of above.
2027

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For details, refer IRS Technical Circular No. 032/2023, dated 09 October 2023.

8 IMDG Code MSC.556(108) Ships All 1 January Ships All 1 January Amendments to the IMDG Code:
carrying 2026 carrying 2026
IMDG Administrati IMDG Administration The IMDG Code is regularly reviewed to take into account new requirements for existing substances or
Cargo ons may Cargo s may apply it new substances.
apply it on a on a voluntary
voluntary basis as from 1 In addition to the regular updates to classification, segregation, packing and markings of dangerous
basis as January 2025. goods, Amendment 42-24 includes;
from 1
January • Segregation requirements for alcoholates.
2025. • Amendments to SG 53 and SG 48 regarding liquid organic substances.
• Amendments to UN 1362 PG II and UN 1362 to clarify the differences between carbon-related
substances particularly with regard to charcoal.
• A new special provision and handling code for medical waste.
• Amendments have also been made to the footnotes in the IMDG Code. Several footnotes in the
IMDG Code were found to use mandatory language. These have now been included in the main
body of the Code.

The amendments are pertaining to operational requirements and are to be complied with when
carrying dangerous goods.

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