NL 341/25 | | Updated Requirements for Material Declaration (MD) of Cybutryne in Products
Refers to: Ship-owners, Operators, Masters and Managers of PHRS certified vessels
Effective Dates: 26 June 2025
This newsletter provides guidance to suppliers, shipyards, and ship-owners regarding the updated requirements for Material Declarations (MDs) confirming the presence or absence of cybutryne in products supplied for ship construction and maintenance. As of 26 June 2025, the threshold level for cybutryne has been revised to 200 mg/kg, and all declarations must follow the updated IMO-mandated format.
Cybutryne (CAS No. 28159-98-0) was added to the list of controlled substances under the International Convention on the Control of Harmful Anti-Fouling Systems on Ships (AFS Convention). The IMO has mandated that suppliers declare whether cybutryne is present in any product delivered for installation onboard ships.
The latest amendments require the use of the updated material declaration format contained in Appendix 6 of Resolution MEPC.379(80), as amended by MEPC.405(83). This format must be applied to all MDs issued after 26 June 2025. MDs submitted in the outdated format will be considered non-compliant.
Therefore, a new MD in the updated format, reflecting the 200 mg/kg threshold for cybutryne, is required when new coating is supplied after 26 June 2025.
Material Declaration (MD) in accordance with Resolution MEPC.379(80) as amended by MEPC.405(83), shall be required for submission at each International Anti-Fouling System (IAFS) renewal survey and each Inventory of Hazardous Materials (IHM) survey.
PHRS Technical Circular TC 302/25 is relevant, and available via PHRS public access point on https://eapp.phrs.gr/Home/Publications .
Additional information can be found here:
NL 340/25 | Liberia Marine Advisory: 25/2025 - Intra North Sea Ballast Water Contingency and Compliance Area
Refers to: Ship-owners, Operators, Masters and Managers of PHRS certified vessels
Effective Dates: 08 September 2025
The purpose of this Marine Advisory, issued by the Liberian Registry is to draw your attention to the OSPAR 25/14/01, Annex 10 “Intra North Sea Ballast Water Contingency and Compliance Area in accordance with BWM.2/Circ.62 and MEPC.387(81)”.
Background
In June 2025, the OSPAR Commission approved an "Intra North Sea Ballast Water Contingency Area" for ships to conduct ballast water exchange and treatment. This document was referenced as "OSPAR 25/14/01, Annex 10", wherein the North Sea States Belgium, Denmark, Germany, Norway, the Netherlands, Sweden and the United Kingdom have decided to establish an Intra North Sea Ballast Water Contingency Area for the purpose of Ballast Water Exchange plus Treatment in accordance with BWM.2/Circ.62 and MEPC.387(81). This Contingency Area became applicable on 27 June 2025 and will expire on 26 June 2030, unless extended by the aforementioned States. The map and coordinates of the Contingency Area are subject to review on a yearly basis, as appropriate.
Scope of Application
The Intra North Sea Ballast Water Contingency Area is shown on the map in Annex 1, with coordinates listed in Annex 2, of OSPAR 25/14/01, Annex 10 (reference a). Contingency measures are not allowed within 2 nautical miles of offshore structures such as windmills. Additional conditions are outlined in paragraph 9 of OSPAR 25/14/01, Annex 10.
OSPAR 25/14/01, Annex 10 applies to ships that:
- According to Regulation B-3 must comply with the standard according to Regulation D-2
- Are on a voyage between two different North Sea ports
- Are facing a contingency situation according to BWM.2/Circ.62 or are in challenging water quality according to MEPC.387(81)
- Have integrated the Interim Guidance MEPC.387(81) in their approved BWMP and implemented the procedures therein on board.
Prerequisites for the use of the Ballast Water Contingency Area in the North Sea
A ship may only use the Ballast Water Contingency Area in the North Sea for an exchange using the BWMS (Ballast Water Exchange plus Treatment) under the following conditions:
- Corrective action notification to the port state of the arrival port (BWM.2/Circ.62, paragraph 3)
- Consideration of alternative discharge (BWM.2/Circ.62, paragraph 3.2)
- Crew response to operational issues
- Alarm assessment
- Contamination minimization measures
- Pre-emptive bypass agreement
Appropriate entries shall be made in the BWRB in each individual case.
Bypassing the BWMS
After a bypass agreed with the port State, the ship should carry out a decontamination procedure within the coordinates of the Intra North Sea Ballast Water Contingency Area, as described in Appendix 1 of MEPC.387(81) within the shortest possible distance within waters under the jurisdiction of the Port State in which the BWMS was bypassed to minimize the risk of the transfer of Harmful Organisms and Pathogens.
Map of the Intra North Sea Ballast Water Contingency Area
The contingency measures described in OSPAR 25/14/01, Annex 10 may be carried out in the area depicted in green in Annex 1, if the requirements of paragraphs 3 to 8 of OSPAR 25/14/01, Annex 10 are fully met. Carrying out contingency measures outside of the green areas is not allowed. Within the green area, a biosafety distance of 2 nm from all offshore structures should be maintained when conducting BWE+BWT. In addition, the normal navigational practices should be followed and the regulations regarding areas otherwise restricted (military exercise areas, aquaculture areas etc.) and VTS should be observed with due diligence. Furthermore, Marine Protected Areas are also excluded, and therefore, contingency measures may not be carried out in these areas. The Guidance documents relative to these areas should be consulted before commencing these operations.
Please find references for the text above in the following links:
- OSPAR 25/14/01, Annex 10
- BWM.2/Circ.62 - Guidance on Contingency Measures under the BWM Convention
- Resolution MEPC.387(81) - Interim Guidance on operating in challenging water quality conditions
- Marine Notice POL-014
For more information on this Marine Advisory, 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
The Liberian Administration has issued updates to Marine Notice POL-009 on the implementation of the 2021 Revised MARPOL Annex VI. Key amendments are summarized below:
• NOx Technical Code: Section 1.29.3 updated to reflect Resolution MEPC.397(83).
• EEDI Survey & Certification: Sections 4.2.1 and 4.3 now reference MEPC.1/Circ.855 (as amended) and the 2022 EEDI Guidelines (Resolution MEPC.403(83)).
• Early Implementation: Section 12.2.24 allows early application of Resolution MEPC.398(83).
• SCR Systems: New Section 12.2.10 inserted, addressing Selective Catalytic Reduction (SCR) requirements.
• Biofuels: Section 14.2 amended to align with new instructions on biofuel use.
• Flashpoint Reporting: Section 14.9.3 revised to include Resolution MSC.520(106) obligations where oil fuel fails minimum flashpoint standards.
• SEEMP Compliance: Annex IV (SEEMP Part II) and Annex V (SEEMP Part III) revised in line with the latest SEEMP Guidelines.
Action for Ship-owners & Operators
Ensure your vessels are updated in line with these regulatory changes, particularly regarding NOx certification, SCR installations, and fuel compliance reporting.
Additional information can be found here
NL 338/25 | Maritime Cook Islands Circular 321: Implementation of Fit and Proper Person Requirements
Refers to: Ship-owners, Operators, Masters and Managers of PHRS certified vessels
Effective Dates: 1/11/2025
The Maritime Cook Islands (MCI) has announced that, effective 1 November 2025, a “Fit and Proper Person” process will be implemented for all applicants seeking Cook Islands maritime documents, in accordance with the Maritime Transport Act 2008.
This process applies to all applicants for CoCs, CoPs, Endorsement of Recognition Certificates, and Seaman’s Discharge Books.
All applications for these documents must include:
• Fully completed, signed, and dated Fit and Proper Person process
• Police Report
More details and forms are available below:
Fit and Proper Person Guidelines
Additional information can be found here.
Refers to: Ship-owners, Operators, Masters and Managers of PHRS certified vessels
Effective Dates: 5/11/2025
The Liberian Maritime Authority has issued Marine Notice SAF-020 (Rev. 10/25) to provide guidance for compliance with the new SOLAS regulation II-1/3-13, adopted through IMO Resolution MSC.532(107). The regulation, effective 1 January 2026, introduces mandatory requirements for design, construction, testing, maintenance, and certification of lifting appliances and anchor handling winches.
Applies to all lifting appliances, anchor handling winches, and associated loose gear installed on or after 1 January 2026. Existing equipment must undergo testing and examination at the first renewal survey after that date.
Liberia has delegated certification and survey responsibilities for lifting appliances and anchor handling winches to its Authorized ROs.
- New installations must be load tested and thoroughly examined before first use.
- Existing units must be tested by the first renewal survey post-2026.
- Periodic testing and thorough examination must align with HSSC survey intervals.
Owners must ensure ongoing maintenance, inspection, and operational testing in accordance with manufacturers’ recommendations, RO rules, and IMO guidelines.
Additional information is available at SAF-020.
Refers to: Ship-owners, Operators, Masters and Managers of PHRS certified vessels
Effective Dates: 28/10/2025
The Liberian Maritime Authority (LISCR) has issued Marine Advisory 32/2025 following two serious marine casualties involving crew members during tug line operations on Liberian-flagged vessels. Both incidents resulted in severe leg injuries due to improper line handling, lack of supervision, and communication failures.
Key Findings:
- Crew stood too close to tensioned lines.
- Supervising officers participated directly in line handling rather than overseeing.
- Poor communication between deck and bridge teams and with tug operators.
Recommended Actions:
- Review and Update Procedures
- Enhance Crew Training
- Improve Supervision and Communication
- Fleet-Wide Awareness
These incidents underscore the importance of procedural discipline and effective communication during tug operations.
Further information: The full advisory is available at MA 32/2025
Refers to: Ship-owners, Operators, Masters and Managers of PHRS certified vessels
Effective Dates: 24/09/2025
The Turkish Ministry of Transport and Infrastructure has issued a new Port State Control (PSC) Implementation Regulation applying to all foreign-flagged ships calling at or anchoring in Turkish ports.
Detentions & Bans:
- Unauthorized departure or failure to reach repair yard → 6-month ban.
- 3 detentions in 36 months → 12-month ban; further detention → 24-month ban.
- Two bans + new detention → permanent ban.
- Regional MoU bans also apply; black-listed/substandard flags may be restricted.
Appeals:
Must be lodged within 1 month; detention remains in force during appeal.
Follow-up Inspections:
Ships may proceed to approved repair yards; urgent safety/pollution cases may allow entry of banned ships.
Inspection Fees:
Operators bear costs of repeat inspections, inspections after bans, and services outside office hours. Detentions remain until fees are paid.
For the full Regulation please click here, a draft English translation is also available here.
Refers to: Ship-owners, Operators, Masters and Managers of PHRS certified vessels
Effective Dates: 01/01/2026
Please be informed that the upcoming IMO Amendments entering into force on 1 January 2026 are listed below for your reference.
STCW Code and STCW-F Convention
- Resolutions: MSC.560(108), MSC.561(108), MSC.562(108)
- Scope: Fishing vessels and all seafarers
- Summary:
- Revised provisions on training, certification and watch keeping for fishing vessel personnel.
- New mandatory training for all seafarers addressing the prevention of violence, harassment (including sexual harassment), bullying, and assault.
Prohibition of PFOS in Fire-Fighting Foams
- Resolutions: MSC.532(107), MSC.536(107), MSC.537(107)
- Scope: All ships
- Summary:
- Prohibition of the use of fire-fighting foams containing PFOS substances on-board ships.
SOLAS II-1/3-13 – Onboard Lifting Appliances and Anchor Handling Winches (OLAW)
- Resolution: MSC.532(107)
- Scope: All ships
- Summary:
- Establishes new requirements for on-board lifting appliances and anchor handling winches to improve operational safety.
IGF and IGC Codes – Use of High-Manganese Austenitic Steel
- Resolutions: MSC.524(106), MSC.523(106)
- Scope: Ships using gases or other low-flashpoint fuels / gas carriers
- Summary:
- Allows the use of high-manganese austenitic steel as cryogenic material with minimum design temperature -165°C.
Fire Protection of Control Stations on Cargo Ships
- Resolution: MSC.550(108)
- Scope: New cargo ships
- Summary:
- Fixed fire detection and alarm systems to cover all control stations and cargo control rooms.
For existing passenger ships constructed before 1 January 2026, where applicable, compliance with retroactive requirements shall be confirmed by the attending surveyor(s) at the first survey conducted on or after 1 January 2028.
Fuel Oil Safety Measures
- Resolution: MSC.520(106)
- Scope: All ships
- Summary:
- Bunker delivery notes to include flashpoint or statement of conformity with SOLAS II-2/4.2.1.
- Non-compliant cases to be reported to IMO by the Administration.
LSA Code Amendments
- Resolution: MSC.554(108)
- Scope: All ships
- Summary:
- Enhanced in-water performance standards for lifejackets.
- New lowering speed requirements for survival craft launching appliances.
- Clarification on exemptions for single fall and hook systems.
Ventilation of Totally Enclosed Lifeboats
- Resolutions: MSC.535(107), MSC.544(107)
- Scope: New installations after 1 January 2029
- Summary:
- Minimum ventilation capacity requirement of 5 m³/hour per person.
- Limiting the duration of thermal protection tests for immersion suits using human subjects to a maximum of 15 minutes when skin temperature falls below 10°C.
IMDG Code Amendments
- Resolution: MSC.556(108)
- Scope: Ships carrying IMDG cargo
- Summary: Addition of new dangerous goods, revised provisions for battery-powered vehicles, and stricter requirements for data loggers and sensors.
2011 ESP Code
- Resolution: MSC.553(108)
- Scope: Oil tankers and bulk carriers
- Summary: Clarifies Administrations’ right to directly audit thickness measurement firms.
Grain Code Amendments
- Resolution: MSC.552(108)
- Scope: All cargo ships
- Summary: Introduces a new class of loading condition for grain carriage.
Mandatory Electronic Inclinometers
- Resolutions: MSC.532(107), MSC.533(107), MSC.534(107)
- Scope: New bulk carriers and container ships ≥ 3,000 GT
- Summary: Mandatory carriage of electronic inclinometers with new performance standards.
IGF Code Amendments
- Resolution: MSC.551(108)
- Scope: New ships (retroactive provisions apply to some existing ships)
- Summary: Updates and enhancements to safety requirements under the IGF Code.
Maintenance and Testing of Survival Craft and Rescue Boats
- Resolutions: MSC.402(96), MSC.559(108)
- Scope: All ships
- Summary: Ventilation systems of totally enclosed lifeboats included in annual examination and operational testing by approved service suppliers.
Refers to: Ship-owners, Operators, Masters and Managers of PHRS certified vessels.
Panama Maritime Authority (PMA) has published Merchant Marine Circular MMC-404, with updated measures aiming to reduce detentions and ensure better performance under PSC regimes.
This new circular unifies MMC-381, MMC-393, MMC-398, MMC-402, which from now on are considered obsolete.
Panama flag stakeholders shall be informed of updated measures aimed at improving the performance and compliance of Panamanian-flagged vessels during Port State Control (PSC) inspections of ships calling ports under USCG, Paris MoU, AMSA, or China MSA jurisdiction.
Key Updates
- A dedicated Pre-Arrival Checklist has been developed to help identify weak areas that may result in PSC deficiencies or detentions. This tool is mandatory and intended for use by Ship-owners, Operators, DPAs, Technical Managers, and Masters
- Mandatory for ships calling ports under USCG, Paris MoU, AMSA, or China MSA jurisdiction.
- Must be sent to: prearrival@amp.gob.pa
- 120 hours before arrival at any of the specified ports
- If the voyage is shorter than 96 hours, send at least 24 hours before arrival
Purpose of Checklist
- Improve fleet performance in PSC inspections
- Reduce risk of detentions
- Identify and correct potential deficiencies before port arrival
Any outstanding deficiencies, including equipment failures, must be immediately notified to the RO, Segumar, and port state authorities, along with the corrective action plan agreed.
Pre-Arrival Checklist for Panamanian Flagged vessels is available here.
The complete circular is available here.
Our organization remains available to support companies in the implementation of this new requirement, ensuring proper understanding and compliance with the checklist submission process and PSC preparedness.
NL 332/25 | Upcoming Changes to IMO Fuel Oil Consumption Reporting – MARPOL Annex VI Appendix IX
Refers to: Ship-owners, Operators, Masters and Managers of PHRS certified vessels
Amendments enter into force: 1 August 2025
Existing ships must comply: from 1 January 2026
New ships delivered after 1 August 2025: compliance from entry into service
IMO has updated the Data Collection System (DCS) under MARPOL Annex VI to improve the accuracy and granularity of fuel consumption and efficiency data. Key changes include:
Detailed Fuel Reporting
- Fuel consumption must now be recorded per consumer type (main engines, auxiliary engines, boilers, etc.) and per fuel type.
- Fuel used while the ship is not under way (e.g., at berth, drifting, or during ship-to-ship operations) must also be included.
- Onshore power usage, installation of energy-saving technologies, and total transport work must also be reported.
Voyage-Based Reporting
- Distance travelled and hours under way are only recorded when the ship is “under way” (FAOP → EOSP).
- Fuel consumption while not under way is reported as a total for that period, without distance or hours.
- This replaces traditional daily reporting to improve accuracy and simplify submissions.
SEEMP Part II Updates
The Ship Energy Efficiency Management Plan (SEEMP) Part II must be updated and reviewed by the flag Administration or Recognized Organization.
- Existing ships: review before 1 January 2026
- New ships delivered after 1 August 2025: review before entering service
Methods for Data Collection
- Primary methods: flow meters and bunker tank monitoring (recommended for accuracy)
- Secondary methods: subtraction or estimation (require justification and approval)
Why These Changes Were Made
- To improve accuracy of fuel consumption and emissions reporting.
- To incentivize ships to reduce idle fuel consumption at ports or during anchoring.
- To align reporting with Carbon Intensity Indicator (CII) and IMO decarbonization goals.
Implications for Shipowners and Managers
- Ensure equipment and procedures for fuel monitoring are in place.
- Update SEEMP Part II and submit for review before the deadlines.
- Transition to voyage-based reporting, separating “under way” and “not under way” fuel consumption.
- Train crews and shore staff on new definitions and reporting methods.
Key Dates to Remember
Deadline for SEEMP Update & Data Collection for existing ships: 1 January 2026
Deadline for SEEMP Update & Data Collection for new ships: Before entry into service (after 1 Aug 2025)
In Summary:
From 2026, all ships will report more granular fuel consumption and energy efficiency data. Fuel used at berth or during idle operations still counts, but distance travelled and hours are only reported when underway. Voyage-based reporting ensures clarity, consistency, and compliance with IMO’s latest guidelines.
For further guidance or support with SEEMP updates and data collection systems contact us at mes@phrs.gr.