The 84th Session of the IMO’s Marine Environment Committee wasn’t just about the Net Zero Framework. The Committee also advanced a series of decisions that will directly affect ship operations — from ballast water management and plastic pellet carriage to underwater radiated noise and a new Emission Control Area in the North Atlantic. These issues may be less high profile than decarbonisation, but they are moving fast and will shape what ships need to do in practice over the coming years. This article breaks down what changed, what’s coming next, and what BIMCO is doing to support members.

Outcomes of MEPC 84

If you are seeking news and updates on the Net Zero Framework, we will publish a more thorough report once we have had time to reflect on the outcomes, the key points for members and the way forward.

Amendments to the BWM Convention and revised Guidelines for ballast water management plans (BWMPs)

Ballast water management was a key topic at MEPC 84, with the Committee advancing the ongoing review of the Convention and associated instruments.

The Committee approved draft amendments to the BWM Convention. The Secretariat will now prepare the consolidated revised Annex to the BWM Convention which is expected to be adopted at MEPC 85 later in 2026.

The draft amendments to the BWM Convention focus on strengthening implementation by clarifying and enhancing existing provisions rather than introducing new regulatory concepts. In particular, the revisions address the application of contingency measures, improve the content and approval of BWMPs, and introduce more explicit expectations on crew familiarisation and system maintenance, including record-keeping. The amendments also refine survey and certification provisions and provide greater clarity on the transition from prototype (D-4) systems to full D-2 compliance. Overall, the changes aim to improve consistency, transparency and practical application of the Convention in real-world operations.

We will provide BIMCO members with a detailed overview of the amendments to the BWMC and guidance on their practical application once adopted.

In parallel, the Committee adopted the revised 2026 Guidelines for ballast water management (BWM) and development of Ballast Water Management Plans (G4), which are intended to align with the amended Convention requirements and provide clearer and more consistent direction on the development and approval of ship-specific plans. The objectives of these Guidelines are to assist Governments, appropriate authorities, ships masters, operators and owners, and port authorities, as well as other interested parties, in preventing, minimizing and ultimately eliminating the risk of introducing harmful aquatic organisms and pathogens from ships’ ballast water and associated sediments while protecting ships’ safety in applying the BWM Convention.

The revised Guidelines will apply from the date of entry into force of the Convention amendments, at which point existing Guidelines will be revoked. Until then, current Ballast Water Management Plans (BWMPs) remain compliant. However, the early adoption of the revised Guidelines is intended to provide Administrations and companies with sufficient time to review and update their BWMPs in preparation for the new requirements. BIMCO members may therefore wish to begin assessing potential updates to their plans at an early stage.

We will make the revised Guidelines on ballast water management and plans available to members once finalised by the IMO Secretariat, together with a summary of the key changes.

Work on the BWM Systems Code, including testing requirements, remains ongoing and will continue intersessionally. More broadly, discussions at the session highlighted an increasing focus on implementation challenges, including system performance in challenging conditions and the need for greater consistency in application.

At MEPC 85, the entry into force of the BWM Convention amendments will be determined and is expected to be concurrent with that of the amendments to the BWMS Code, depending on when the latter are also completed

Carriage of plastic pellets in freight containers

The carriage of plastic pellets continued to be a divisive topic with member states failing to reach a decision on under which IMO Convention (MARPOL, SOLAS or both) a code on plastic pellet carriage would be made mandatory. Nonetheless, the Committee instructed the Pollution Prevention and Response Sub-Committee (which will meet for its 14th session in early 2027) to develop the draft code noting that the text of the code is likely to be the same regardless of where it sits as well as developing potential consequential amendments to MARPOL and/or SOLAS with MEPC then making a policy decision at a future session. At BIMCO we support that any code should provide the same operational clarity and environmental protection that would be enabled by the allocation of a UN number and resulting carriage in accordance with the provisions of the International Maritime Dangerous Goods (IMDG) code- and this should happen without delay.

To inform our input into discussions at PPR we would urge any members with experience in applying the IMO Guidelines on the carriage of plastic pellets by sea in freight containers to get in touch. Underwater radiated noise (URN)

The Committee approved an extension of the Experience Building Phase on URN to 2028 which had been supported by BIMCO noting that Uptake of the 2023 revised guidelines is still at an early stage

More time is needed to gather sufficient, reliable data

Industry needs space to understand what measures are effective, feasible

In spring 2024, we launched a survey to track the number of ships that have adopted the revised guidelines. The survey, initiated by BIMCO, ICS and INTERTANKO, will help the shipping industry show progress in adapting to mitigating measures, even without mandatory IMO requirements on URN.
Source: BIMCO