The International Convention for the Control and Management of Ships’ Ballast Water and Sediments [BWM Convention ] will enter into force on 8 September 2017.

The implementation deadline for BWMS, according to IMO Resolution A.1088(28) and MEPC.69 is:

Keel laid

Before 8 September 2017

On or after 8 September 2017

Ballast water capacity

All vessels (*)

Implementation deadline for BWMS

By the first renewal survey associated with the IOPP Certificate after 8 September 2017

Completion date of build

(*) : Surveys and certifications are required only for vessels of 400GT or more, excluding Floating platforms, FSU and FPSO.

Exemptions from the BWM Convention​ may be possible under certain circumstances, such as:

• Ships not carrying Ballast water

• Ships trading domestically in the waters of a Party to the convention

• ships that do not mix Ballast Water or Sediments other than between the domestic ports or locations

• when the IOPP renewal survey will be done before 08 September 2017 (this practice will only postpone the compliance for 5 years up to 2022).

however, all ships must have a ship-specific Ballast Water Management Plan.

As far as concerns Panama flag, you can refer to the attached MMC-342 whereas in paragraph 3 it is mentioned that “in accordance with IMO Resolution A.1088(28), the vessel is not required to comply with regulation D-2 of the Convention until the first renewal survey of it`s International Oil Pollution Prevention Certificate (IOPP), following the date of entry into force of the BWM Convention on 8 September 2017.”

Bearing the above in mind, if the IOPP Renewal survey of a vessel is due after the date of entry into force of the BWM Convention on 8 September 2017, PMA will authorize, at owner’s request, on a case by case basis, the de-harmonization of the IOPP Certificate until the date of entry into force of the BWM Convention. That means, the IOPP renewal survey could be brought forward and carried out before 08 September 2017 while the rest Statutory renewal surveys can retain their original due date and be carried out after 08 September 2017.

Flag authorization will not be necessary if all Statutory Renewal surveys will be carried out in advance of their due date and before the date of entry into force of the BWM Convention on 8 September 2017.

We are currently preparing a Circular with detailed information on the BWM Convention and the pertinent requirements. It will be published very soon.