May. 22 2020

Class & statutory

Amendments to the IBC Code and MARPOL Annex II – Entry into force on 1 January 2021

Replacement of the existing IBC/NLS certificates - Revision of Procedures and Arrangements (P&A) Manuals

1. IBC Code 2019 amendments – replacement of the existing certificates

Amendments to the IBC Code - Resolution MEPC.318(74) & Resolution MSC.460(101)) - have been adopted by the IMO and enter into force on 1 January 2021.

IMO adopted a comprehensive set of amendments to the IBC Code, including the revised chapters 17 (Summary of minimum requirements), 18 (List of products to which the code does not apply), 19 (Index of Products Carried in Bulk) and 21 (Criteria for assigning carriage requirements for products subject to the IBC Code).

On the basis of the complete revision of the criteria for assigning carriage requirements for products (Chapter 21 of the IBC Code), the carriage requirements for products listed in Chapters 17 and 18 of the IBC Code have been reassessed and revised.

These amendments may have, inter alia, an impact on the ship type, tank type, or toxicity classification associated with the different products carried. As a result, each ship carrying dangerous chemicals or noxious liquid substances in bulk will have its list of products that it may carry amended as from 1 January 2021.

Differential list of lost and gained products

In order to facilitate the analysis of the impact of these amendments, for each product listed, BUREAU VERITAS MARINE & OFFSHORE makes available to ship owners or managers, for each chemical tanker, an indicative list of "gained" and "lost" products in relation to the entry into force of the 2019 amendments to the IBC Code. This list provides for each product listed, the regulation supporting the concerned amendment.

As of today, for each BV classed vessel, the Differential lists can be found on the VeriSTAR website ( in the REGISTER / CHEMICAL PRODUCTS tab with the prefix "DIF".

Replacement of existing certificates – Draft revised MSC-MEPC.5/Circ.7

In order to facilitate a smooth and practical implementation scheme for the worldwide fleet of Chemical / NLS tankers that might require to have revised certificates immediately upon the entry into force of the amendments to the IBC Code, issuance of the revised Certificate of Fitness for the carriage of Dangerous Chemicals in Bulk and revised Certificate for the Carriage of Noxious Liquid Substances in Bulk will be initiated in advance to the date of entry into force of the amendments (1 January 2021).

Based on the outcome of last IMO PPR subcommittee (PPR7 February 2020) who agreed to the draft revised of MSC-MEPC.5/Circ.7 (see attached file) for subsequent approval by MEPC 75 and MSC 102, as described in the below diagran, two implementation scenarios for the replacement of existing certificates on board ships before 1 January 2021 will be applied by BUREAU VERITAS MARINE & OFFSHORE.

See attached file : Appendix Draft revised MSC-MEPC.5_Circ.7.pdf

Implementation on board:

BUREAU VERITAS MARINE & OFFSHORE will implement the replacement process by issuing the revised IBC Code Certificates of Fitness and Noxious Liquid Substances Certificates and its attached revised lists of products in June 2020.

Between June 2020 and the end of December 2020, the revised Certificates will be placed onboard together with the existing Certificates at the earliest opportunity.

During this period ending 31 December 2020, the vessel will have on board an existing certificate and a revised certificate but only the existing one will be valid.

The revised Certificates and List of products will be effective and supersede the existing certificates, on the date of entry into force of the amendments to the IBC Code. This revised Certificates will be provided with the following text on the front page:

Note: This Certificate/List of Products, issued in accordance with the 2019 Amendments (resolutions MSC.460(101) and MEPC.318(74)) to the IBC Code, is effective and supersedes the existing certificate, on 1 January  2021.

Owner’s attention is also drawn to following applicable loading provisions as per draft revised MSC-MEPC.5/Circ.7:

When a cargo is loaded prior to the entry-into-force date and unloaded after the entry into-force date of the amendments to the IBC Code, the relevant provisions of the IBC Code at the time of loading should be applicable until the cargo has been unloaded.

2. MARPOL Annex II amendments – Cargo residues and tank washings of persistent floating products – Revision of Procedures and Arrangements (P&A) Manuals

Amendments to the MARPOL Annex II - Resolution MEPC.315(74) - have been adopted by the IMO and enter into force on 1 January 2021


IMO adopted amendments to MARPOL Annex II to strengthen, in specified sea areas (North West European waters, Baltic Sea area, Western European waters and Norwegian Sea), discharge requirements for cargo residues and tank washings containing persistent floating products with a high-viscosity and/or a high melting point that can solidify under certain conditions (e.g. certain vegetable oils and paraffin-like cargoes), following concerns about the environmental impact of permissible discharges. Consequential amendments to the IBC Code have been made in order to identify the products that are subject to pre-washing requirements as required by MARPOL Annex II.

The amendments add new paragraphs to MARPOL Annex II Regulation 13 – Control of discharges of residues of noxious liquid substances, to require prewash and discharge of residue/water mixture generated during the prewash to a reception facility, for specific products newly identified in chapter 17 of the IBC Code, in specified areas.

Furthermore, the amendments include revised standard format for the Procedures and Arrangements (P&A) Manual (Appendix IV of MARPOL Annex II), for the inclusion of instructions on how to deal with tank washings.

Revision and re-approval of P&A manual in due course.

P&A manuals shall be revised as appropriate to include amendments to MEPC.315(74) and re-approved in a timely manner prior to the implementation date (1 January 2021).

To enable an efficient implementation on board of tankers which are subject to these requirements, the re-approval process should be harmonized with the issuance of the revised Certificate of Fitness for the carriage of Dangerous Chemicals in Bulk when the list of products includes such persistent floating products.

Depending on the impacts of these changes, either re-approval or a simple revision of the P&A manual will be necessary.

In order to confirm which process will be applicable, ship owners and managers are invited to approach the offices connected to their ships.