New MARPOL Environmental Regulations: Key Changes for the Shipping Industry Starting August 1, 2025

These amendments, adopted at the 81st session of the IMO Marine Environment Protection Committee (MEPC) through Resolution MEPC.385(81), cover:

1. Low-flashpoint fuel and gas fuel

The updated regulations clarify that shipboard gas fuel supply systems are exempt fr om the requirement to have an onboard fuel sampling point. This revision has also been reflected in the updated form of the International Air Pollution Prevention Certificate (IAPPC).

The Bunker Delivery Note for ships supplied with low-flashpoint or gas fuels on or after August 1, 2025, must include, at a minimum, the following information:

• Name and IMO Number of ship;
• Port wh ere fuel is received;
• Date of fuel delivery;
• Name, address and telephone number of fuel supplier;
• Product name;
• Quantity of fuel in metric tons;
• Density determined by a method appropriate for the fuel;
• The Sulphur content as tested by an appropriate test method or a statement that when tested by such a method the sulphur content is less than 0.001% m/m.
• Declaration signed by the supplier that the fuel meets the requirements of MARPOL Annex VI Regulation 18 “Fuel Oil Availability and Quality”.

2. Replacement of a steam system with a diesel engine

In accordance with Regulation 13.2.2 “Nitrogen Oxides (NOx)” of MARPOL Annex VI, the installation of a marine diesel engine with an output exceeding 130 kW in place of a steam system is considered an engine replacement, not a new installation.

If the replacement engine cannot meet TIER III standards, it must comply with TIER II standards taking into account the guidelines developed by IMO (MEPC.386(81)).

3. Submission of ship fuel consumption data

MARPOL Annex VI now requires to collect and report fuel consumption data with enhanced granularity to a ship’s Flag Administration (or recognized organization) for annual verification before its submission to IMO under MARPOL Annex VI requirements for operational carbon intensity.

Additional mandatory reporting items for fuel consumption include:

• total fuel consumption and consumption when the ship is not underway, broken down by consumer type (main engines, auxiliary engines, boilers);
• amount of onshore power supplied, if applicable;
• total transport work (the product of the ship’s capacity and the distance traveled during the calendar year);
• use of innovative energy-saving technologies, if applicable.

Prior to initiating fuel consumption data collection under MARPOL Annex VI, amendments must be made to Part II of the Ship Energy Efficiency Management Plan (SEEMP), with subsequent approval by the Flag Administration or a recognized organization.

In accordance with IMO recommendations (Guidance on the application of the amendments to appendix IX of MARPOL Annex VI on inclusion of data on transport work and enhanced granularity in the IMO Ship Fuel Consumption Database, circular MEPC.1/Circ.913), collection of the enhanced dataset should begin with a new calendar year.

Thus, ships that have already implemented the expanded SEEMP-approved data collection from January 1, 2025, should report this full-year data in their 2025 submission. If an existing ship’s SEEMP is scheduled for revision and approval after August 1 and before the end of 2025, enhanced granularity data collection shall begin from January 1, 2026. Any new ship built on or after August 1, 2025, shall begin collecting the expanded dataset from the date it enters service.

Additional information:

Founded in 1913, Russian Maritime Register of Shipping (RS) is a world-renowned classification society that operates within all spheres of the maritime industry with the goal of improving the operational and environmental safety of marine transportation. RS reviews technical documentation, surveys ships and offshore facilities under construction and in service, certifies vessels and companies for compliance with international conventions, recognizes and certifies industrial products and manufacturers, certifies quality management systems for compliance with international and national standards.

Today, RS is actively implementing the concept "More than class" by expanding its scope of services in the field of engineering and consulting, the development of technical documentation for vessels in service, marine warranty surveys and certification. In addition, RS surveys all container types, including tank containers and offshore containers, confirms compliance of packaging for dangerous goods, as well as renders services on the declaration and certification of dangerous goods and bulk cargoes.