IMO to enforce changes to liquid cargo from 2021


The International Maritime Organization (IMO) has made changes to regulation of liquid cargo and, as a result, revised Certificate of Fitness requirements.

In response to years of extensive pollution of the coastlines in north Europe as a result of cleaning residues after carriage of vegoils and waxes (so-called persistent floaters), the IMO has amended the IBC Code and MARPOL Annex II.

As a result, the IMO has decided that when persistent floaters have been unloaded in north-west Europe, the cargo tanks must be prewashed and the resulting water must be discharged to reception facilities before the vessel leaves the port of unloading.

Another reason for the amendments to the IBC Code is that the classification of the substances listed in the IBC Code chapter 17 and 18 has been “harmonized”, so that substances assessed before and after 2004 are now using the same criteria.

One of the most striking changes to the IBC Code and MARPOL Annex II is that so-called persistent floaters*) (typical vegoils) and waxes of pollution category Y, will, in most cases, require mandatory prewash when unloaded inside certain regional areas**), according to new regulation in MARPOL Annex II. These products will be identified in Chapter 17 of the IBC Code with a new paragraph 16.2.7 in column “o”.

In addition, a great number of substances will have their Pollution Category and/or requirement to Ship Type changed. Furthermore, there will be several changes to handling and safety requirements for many products listed in IBC code chapter 17.

Revised Certificate of Fitness to be issued prior to 1 January 2021

The changes will impact the Certificate of Fitness or the NLS certificate that list which products a tanker is certified to carry. Therefore, the IMO has decided that a revised Certificate of Fitness, based on the new amendments, shall be issued prior to 1 January 2021 and kept on board with the existing certificate. The revised certificate supersedes the existing certificate on 1 January 2021, and will have the same expiry date as the existing certificate.

BIMCO Liquid Cargo Database

As a consequence of the amendments to MARPOL Annex II and the IBC Code, BIMCO’s Liquid Cargo Database will be updated with the relevant details during 2020, in order to keep the Database up to date on 1 January 2021, when the amended IBC Code becomes effective.


*) From MARPOL Annex II Regulation 1 paragraph 23:

Persistent floater means a slick forming substance with the following properties:

  • Density: ≤ sea water (1025 kg/m3 at 20°C);
  • Vapour pressure: ≤ 0.3 kPa;
  • Solubility: ≤ 0.1% (for liquids) ≤ 10% (for solids); and
  • Kinematic viscosity: > 10 cSt at 20°C

**) The areas to which MARPOL Annex II regulation applies are detailed in MARPOL Annex II regulation 13 paragraph 9. The areas are described as North West European waters; Baltic Sea area; Western European waters and the Norwegian Sea. (This area includes in fact all ports in north-west Europe - from north of Gibraltar and up and around the northern tip of Norway including Ireland and United Kingdom).


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Peter Lundahl Rasmussen
in Copenhagen, DK


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