Environmental

AIR EMISSIONS
BALLAST WATER
BIOFOULING
MISC. ENVIRONMENTAL
SHIP RECYCLING
OPS

INTERCARGO monitors and contributes to regulatory and technical developments related to air emissions beyond CO₂, with a focus on their impact on dry bulk shipping.

This includes requirements stemming from the global sulphur cap and associated controls on sulphur oxides (SOₓ) and particulate matter (PM) emissions, as well as regulations addressing other air pollutants such as nitrogen oxides (NOₓ) and black carbon. INTERCARGO also follows developments related to Emission Control Areas (ECAs) and Sulphur Emission Control Areas (SECAs), including their designation, expansion, and operational implications for bulk carriers.

With the purpose of preventing the spread of invasive species, the International Maritime Organization adoptedThe International Convention for the Control and Management of Ships’ Ballast Water and Sediments (Ballast Water Convention) which entered into force on 8^th September 2017.

Vessels constructed on or after 8^th September 2017 have been required to install a Ballast Water Treatment System to comply with the Conventions discharge requirements. For vessels constructed prior to this date, compliance with the Convention’s D-2 depended on the vessel’s IOPP survey cycle with the final deadline being 8^th September 2024.

The relatively recent entry into force of the Convention, involving new regulations and the fitting and operation of equipment that had previously not been used on ships has led, unsurprisingly, to a number of challenges.

The implementation challenges of the Convention especially relate to the performance of ballast water treatment systems, the operating conditions and locations of vessels, and the global coverage of technical support for the systems involved. It is important to note that while ships are certified for global trade, many of the available systems are not certified or able to perform in all locations and conditions that vessels may trade in, and this is particularly true for the bulk carrier fleet.

A holistic approach to regulations is also important. Shipping is trying to decarbonise which in the short to mid-term will mean finding efficiencies and ultimately using less power. However, regulations such as the Ballast Water Management Convention effectively require vessels to use more power and thus produce more emissions, leading to a situation where one environmental regulation potentially has a negative effect on another environmental regulation. Regulators should recognise the consequences of all regulations and how they may impact each other.

INTERCARGO is engaged in a range of environmental topics that fall outside the core air-emissions framework but are increasingly relevant to dry bulk shipping. These include underwater radiated noise, , waste management, , and other emerging environmental requirements affecting vessel design and operation.

Underwater Noise

The reduction of underwater radiated noise (URN) from ships is an emerging focus in international maritime regulation, as underwater noise can have adverse impacts on marine life. The IMO has developed voluntary guidelines for the reduction of underwater noise from commercial shipping, and is currently reviewing and updating these guidelines, with discussions on making some measures mandatory in the future. Recent work includes the launch of the Global Partnership for Mitigation of Underwater Noise from Shipping (GloNoise Partnership) and the establishment of an experience-building phase to gather data and assess the effectiveness of noise reduction measures.

INTERCARGO monitors these regulatory developments and participates in industry and IMO discussions on underwater noise, ensuring that the interests and operational realities of dry bulk carriers are considered. While not a primary focus of INTERCARGO’s work programme, the association keeps its members informed of ongoing discussions, the potential impact of energy efficiency measures on underwater noise, and best practice guidance as the regulatory landscape evolves.

Liability and Compensation for Alternative Fuels
As the industry transitions to low- and zero-carbon fuels, new questions are arising around liability and compensation frameworks for alternative fuels. Regulatory bodies are working to clarify responsibilities and ensure adequate protection for shipowners, operators, and other stakeholders in the event of incidents involving new fuel types.
INTERCARGO monitors these regulatory changes and participates in relevant discussions to ensure that the interests and operational realities of dry bulk shipowners are considered. The association provides feedback on proposed frameworks and keeps members informed of evolving requirements.

INTERCARGO is actively engaged in the latest international developments on biofouling management, representing the interests of the dry bulk sector at the International Maritime Organization (IMO) and across the wider shipping industry.

With the IMO moving towards a legally binding framework to control ships’ biofouling and minimize the transfer of invasive aquatic species, INTERCARGO has established a dedicated Biofouling Working Group and is chairing a Joint Industry Working Group to ensure that practical operational experience and the unique needs of bulk carriers are reflected in future regulations. Our Association works closely with industry partners to promote effective, pragmatic, and environmentally responsible biofouling management solutions for the global dry bulk fleet.

In addition, INTERCARGO is closely monitoring regional biofouling requirements and developments in key jurisdictions such as New Zealand, Australia, Brazil, and the United States, ensuring that our members are kept informed and well-prepared for both global and local compliance challenges.

Recent years have seen significant regulatory developments in ship recycling, most notably the entry into force of the EU Ship Recycling Regulation (EU SRR) and ongoing efforts to bring the IMO Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (HKC) into force globally. The EU SRR sets strict requirements for EU-flagged ships and recycling facilities, including the creation of a European List of approved recycling yards and the management of hazardous materials. Legal uncertainties remain regarding the inclusion of non-OECD facilities on the EU list, and the interplay between the EU SRR, the Basel Convention, and the HKC continues to be a topic of industry and regulatory discussion.

INTERCARGO is actively engaged in these developments, representing dry bulk shipowners in international and regional forums. The association participates in working groups and industry alliances (such as ECSA and BIMCO) to address regulatory challenges, provide technical input, and advocate for a clear, globally harmonized legal framework for ship recycling. INTERCARGO has co-developed position papers on practical issues such as Material Declarations (MDs) and Suppliers Declarations of Conformity (SDoCs), and regularly updates its members on compliance requirements, best practices, and the status of regulatory changes. The association also hosts webinars and participates in expert panels to keep the sector informed and to promote safe, environmentally sound, and practical ship recycling solutions.

INTERCARGO is leading global efforts to ensure that shore power (OPS) for bulk carriers is developed through a harmonised, safety-driven, and sector-specific framework that reflects the operational realities of the world’s largest shipping segment. With more than 25,000 bulk carriers and around 5,000 relevant terminals worldwide, the risk of fragmented and incompatible shore power installations is significant if standards are not properly aligned. Through active engagement at IMO and IEC level, including the submission of MEPC 83/INF.30, INTERCARGO has secured the development of a dedicated Bulk Carrier Annex under the IEC/IEEE 80005-1 standard, recognising bulk carriers’ unique power profiles, cargo operations, draft variability, and terminal interfaces, and promoting a flexible, ship-shore agreed approach to cable management. At the same time, INTERCARGO is closely monitoring emerging Chinese national shore electricity requirements, which may diverge from the IEC standard, to identify potential gaps and avoid regional misalignment that could impose additional technical or compliance burdens on operators. Complementing the technical work, INTERCARGO is developing operational best-practice guidance based on real-world case studies to address safety, responsibility allocation, and multi-stakeholder coordination, supporting safe, efficient, and globally consistent shore power deployment with immediate emissions-reduction benefits.