Biofouling: the hull now has a border check

In brief

Common ground

IMO 2023 Biofouling Guidelines, resolution MEPC.378(80), voluntary

Ship’s documents

A biofouling management plan and a biofouling record book

New Zealand

Craft Risk Management Standard, in force since 2018

Australia

Biofouling information on arrival since 15 Jun 2022; the education period ended on 15 Dec 2023

California

State Lands Commission, Marine Invasive Species Program

Brazil

NORMAM-401/DPC: requirements apply since June 2025, penalties from 10 Jan 2028

What the guidelines ask

The IMO guidelines treat biofouling as something to manage across the ship’s life: a plan written for the ship, a record book of inspections, cleaning and coating work, and attention to the niche areas where growth starts first.

Where the rules differ

Each state checks against its own standard. Some ask for evidence of a recent clean or inspection before arrival; some limit where and how a hull may be cleaned in the water; some can direct a ship to be cleaned or to leave. The common thread is the record: a ship that cannot show its hull history is treated as a risk.

Planning for it

The time to act is before the voyage is fixed: an inspection or a clean at the load port, a docking brought forward, or the record book brought up to date while the ship is still within reach.

What to check

• The next port’s biofouling requirement, and the evidence it asks for.
• The date of the last inspection and clean in the record book.
• Whether in-water cleaning is allowed where it would be done.

Our reading at 8 Oct 2026, for planning. Not legal advice; the authority’s current text decides.

Sources

• Resolution MEPC.378(80)
• New Zealand, Craft Risk Management Standard: Biofouling
• Australia, biofouling management requirements
• California State Lands Commission, Marine Invasive Species Program
• Brazil, NORMAM-401/DPC and Ordinance No. 476/DPC/DGN/MB