MARPOL Annex II and the IBC code – how to prepare for the 2019 amendments

Amendments to both MARPOL Annex II and the IBC Code adopted earlier this year will enter into force on 1 January 2021. This statutory news discusses the changes, the impacts on our customers and the actions to take.

Techinacal Regulatory News 20, 2019

Relevant for owners and managers of chemical tankers and oil tankers as well as for flag states.

IBC Code amendments

To close an existing gap between how the IBC Code products have been assessed before and after 2004, the IMO decided to reassess all existing products in the IBC Code using the same criteria. This work has now been finalized and adopted as amendments to chapters 17, 18 and 21 of the IBC Code.

As the carriage requirements for most products have changed, this will impact on the Certificate of Fitness or NLS (noxious liquid substances) Certificate listing the products a tanker is certified to carry. When new amendments to chapter 17 and 18 of the IBC Code are adopted, the IMO has decided that a new Certificate of Fitness based on the new amendments shall be issued prior to the entry into force date of the amendments and kept on board with the existing certificate. The revised certificate will have the same expiry date as the existing certificate and is effective, and supersedes the existing certificate, on 1 January 2021. When cargo is loaded prior to 1 January 2021, and unloaded after this date, the relevant provisions of the IBC Code at the time of loading are applicable until the cargo has been unloaded.

The implications of this is that the range of products a ship is certified to carry will differ before and after 1 January 2021.

MARPOL amendments

Pollution of north European coastlines are assumed to be partly the result of tank cleaning residues after carriage of vegetable oils and paraffin waxes. Hence, amendments to MARPOL Annex II imposing prewash requirements in the port of unloading for certain high-viscosity or low-melting-point persistent floating products have been adopted. The stricter requirements apply within a defined area stretching from Gibraltar in the south all the way along the Norwegian coast including the Baltic Sea, as well as the UK and Ireland. As part of the amendments, the standard format of the P&A (procedures and arrangements) manual, which is required to be approved Amendments to both MARPOL Annex II and the IBC Code adopted earlier this year will enter into force on 1 January 2021. This statutory news discusses the changes, the impacts on our customers and the actions to take. on behalf of the flag administration, has been revised. This further calls for an update and re-approval of the P&A manual.

Certificate issuance and P&A manual approval

Both the IBC Code and the MARPOL amendments are related in the way that they affect tankers trading with substances subject to both the IBC Code and the MARPOL Annex II. The entry into force dates (1 January 2021) are therefore aligned. To accommodate an efficient approval process and re-issuance of certificates, a solution for requesting the new certificate and P&A manual approval has been set up in the DNV GL Veracity portal.

To request the new certificate and the approval, please send a survey request through Veracity and choose “MARPOL/IBC Code 2019 Amendments” under “Occasional surveys/audits”. Further instructions can be found in the Owner’s Preparation Note, which will become available when placing the request. An RR (Retroactive Requirement) has also been issued to formally inform each vessel.

Both the existing (IBC Code and MARPOL) certificate and the new certificate, including the respective cargo lists, will be shown in the Veracity portal, and the certificate in force will be tagged as valid. If for any reason the certificate must be re-issued at a later date before 1 January 2021, both certificates will be re-issued.


For DNV GL to manage a timely delivery – and also because the range of products which may be carried after 2021 is defined by the new Certificate of Fitness and possible obligations towards charterers – we recommend an early, rather than last-minute, request.


  • MEPC.315(74) – Amendments to MARPOL Annex II
  • MEPC.318(74) – 2019 Amendments to the IBC Code
  • MSC.460(101) – 2019 Amendments to the IBC Code
  • MSC-MEPC.5/Circ.7 – Guidance on replacement of IBC Code Certificates


  • For customers:
    DATE – Direct Access to Technical Experts via My Services on Veracity.
  • Otherwise:
    Use our office locator to find the nearest DNV GL office.
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