The recent meetings of the International Oil Pollution Compensation (IOPC) Funds in London, where BIMCO holds observer status, focused on key issues shaping the international liability and compensation regime for oil pollution damage. The November 2025 session addressed several pressing topics, notably maritime safety and regulatory developments.
Parallel fleet risks
A topic of discussion was the increasing threat posed by the parallel fleet – vessels engaged in unsafe or uninsured operations, often linked to the transport of sanctioned oil. Delegations expressed deep concern about the financial and safety risks these ships pose to the IOPC Funds and the wider regime.
Several delegations outlined national measures, including adjustments to sanctions enforcement and registry oversight. There was broad consensus on the need for transparency, accountability and coordinated multilateral action to mitigate these risks.
Definition of “Ship” under the 1992 Civil Liability Convention
The Assembly adopted guidance clarifying when a vessel ceases to qualify as a “ship” under the 1992 Civil Liability Convention (CLC). This follows questions raised by the Bow Jubail incident regarding product tankers designed to carry both persistent oil and chemicals.
The guidance specifies that residues of persistent oil cargo representing a material pollution risk must be removed through tank cleaning in accordance with Annex I, Chapter 4 of MARPOL 73/78.
Progress on the 2010 HNS Convention
Encouraging progress was reported on the 2010 Protocol to the International Convention on Liability and Compensation for Damage in Connection with the Carriage of Hazardous and Noxious Substances by Sea (HNS Convention). As of 31 August 2025, eight states have ratified the convention, including Canada, Denmark, France, and Türkiye. Ratifications by Belgium, Germany, the Netherlands and Sweden are expected soon, which would trigger entry into force.
Once in force, compulsory insurance certificates will be required for applicable ships, creating administrative challenges for States and industry. BIMCO supports the HNS Convention and, together with other associations, stands ready to assist in its implementation.
See more information about the IOPC Funds and the 4 to 7 November meetings.
