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ICS Driving Practical Ballast Water Outcomes for Global Shipping

The International Maritime Organization’s (IMO) review of the Ballast Water Management (BWM) Convention is currently one of the most significant regulatory works taking place. Expected to conclude by Autumn 2028, the BWM Convention review will result in amendments to both mandatory instruments (the BWM Convention and BWMS Code) and non-mandatory instruments (Guidelines and Guidance associated with the BWM Convention). Once these amendments enter into force (currently anticipated to be Autumn 2028), the current Experience-Building Phase (EBP) will end, and a stricter compliance and enforcement regime will begin.

Since the Convention entered into force in 2017, operational experience has shown that Ballast Water (BW) compliance is not always straightforward. Whilst ballast water management systems (BWMS) are essential for preventing the spread of invasive aquatic species, they can become temporarily unavailable in challenging water quality (CWQ) conditions. The International Chamber of Shipping (ICS) has therefore focused on ensuring that future regulatory requirements reflect operational realities and do not impose disproportionate burdens on ships without delivering additional environmental benefits.

At the IMO Marine Environment Protection Committee (MEPC 84) in April 2026, important progress was made with the approval of amendments to the mandatory instruments of the BWM Convention, addressing around forty review objectives. These amendments represent a significant step towards a more balanced regulatory framework that recognises the operational challenges associated with BWMS performance in CWQ conditions.

However, substantial work remains. Around fifty review objectives are still under discussion, covering a wide range of Guidelines and Guidance associated with the BWM Convention. As the BWM Convention review progresses, shipping companies should pay close attention to ballast water sampling and analysis requirements used to verify BW compliance with the D-2 standard of the BWM Convention. Following the anticipated end of the EBP in Autumn 2028, ships found non-compliant with the D-2 standard are expected to face enforcement action including potential penalties.

A key area of ongoing discussion is the application of the Convention to ships operating in ports with CWQ conditions. Existing interim guidance on CWQ, adopted as MEPC.387(81), has proven difficult to implement in practice and does not fully address the operational challenges experienced by ships. Industry proposals to revise the interim CWQ guidance were not approved at MEPC 84, meaning that the current guidance remains unchanged. ICS is therefore actively participating intersessionally with Member States and other industry associations, to develop a revised and more practical CWQ Guidance before the end of the EBP. Ensuring that the CWQ guidance is practical and effective to meet the environmental objectives remains a key priority for ICS.

The practicality of ballast water contingency measures also remains a critical issue. Ships may be unable to achieve D-2 compliance for reasons beyond their control, including CWQ conditions or long term non-availability of critical spare parts. In such cases, practical contingency measures are essential to support both environmental protection and the continuity of global trade. Ships are currently expected to follow the procedures set out in BWM.2/Circ.62. ICS continues to advocate that ships should not be required to use external treatment options, such as port reception or treatment facilities, and maintains that ballast water exchange plus treatment (BWE+T) remains the only practical method for restoring D-2 compliance.

The availability of ballast water exchange areas is therefore increasingly important. Without designated ballast water exchange areas, ships may be forced to undertake lengthy deviations, increasing voyage times, fuel consumption and emissions. The recent establishment of the Intra North Sea Ballast Water Exchange and Treatment Area demonstrates how practical regional solutions can support compliance whilst minimising operational and environmental impacts.

Looking ahead, the review of the Convention’s non-mandatory instruments will continue from Autumn 2026 to Autumn 2028, including revisions to existing Guidelines and the development of new ones. ICS will continue to lead industry engagement throughout this process, working to ensure that ballast water regulation evolves in a manner that is both environmentally effective and operationally practical for global shipping.