Background
Since September 2024, all ships in international trade must use type-approved Ballast Water Management Systems (BWMS) to treat ballast water and meet the D-2 discharge standard under the Ballast Water Management Convention (BWMC), preventing the spread of invasive aquatic species.
A key problematic issue is Challenging Water Quality (CWQ), which can adversely affect the performance of BWMS. Ships operating in such conditions may be forced to consider operational workarounds, such as system bypasses, ballast water exchange, or other contingency measures, even when systems are functioning as intended. The absence of designated ballast water exchange areas further limits viable alternatives, especially in enclosed or coastal waters.
In many cases, operational measures taken to navigate BWMS limitations, such as prolonged ballast operations or route deviations to perform ballast water exchange or find suitable water conditions, have direct implications not only for compliance with the D-2 standard but also for ships’ Carbon Intensity Indicator (CII) ratings.
BIMCO recommends to proactively consider BWM during voyage planning, especially for ships calling at ports with known or suspected CWQ owing to the possibility of non-compliance even when BWMS is properly installed and operated. The fragmented enforcement landscape creates legal uncertainty, exposes operators to penalties, and adds commercial risk.
BIMCO is engaged with the IMO member states to ensure that the industry’s practical experiences and perspectives are fully considered in the ongoing review of the BWMC and Code under the Experience-Building Phase (EBP). BIMCO furthermore follows the discussions at Group of Experts on the Scientific Aspects of Marine Environmental Protection’s (GESAMP) biosecurity working group.
BIMCO’s Position Statement
- BIMCO is of the view that the performance and reliability of BWMS must be improved to ensure compliance under real-world operating conditions, including in areas with challenging water quality
- BIMCO supports the objectives of the Ballast Water Management Convention (BWMC) but emphasises that any new measures should be carefully assessed to ensure they do not undermine its intended environmental benefits. For example, if a measure results in increased greenhouse gas (GHG) emissions, it should only be implemented if the overall impact remains acceptable
- BIMCO supports amendments to the BWMC and related IMO guidelines that are both practical and effective for the ship and acknowledges the need for improved transparency and consistency of enforcement practices
- BIMCO believes that port and coastal states should conduct port state control (PSC) inspections in accordance with the “Procedures for port state control” (Resolution A.1185(33)) and the “Guidelines for port state control under the BWM Convention” (Resolution MEPC.252(67)) in order not to unduly penalise compliant ships
- BIMCO promotes collaboration between ship operators and BWMS manufacturers to improve system reliability in diverse operating conditions and refine operational practices and technologies.