IMO CCC 12: Key Maritime Regulatory Developments and Future Changes
The IMO Sub-Committee on Carriage of Cargoes and Containers (CCC)
progressed important maritime safety and operational topics,
including alternative marine fuels, onboard carbon capture,
amendments to the IMSBC and IMDG Codes, and lashing software for
containership cargo securing. This technical brief reviews the
developments and planned milestones that shipowners, operators,
technical managers and cargo stakeholders should monitor.
Overview of the CCC 12 Regulatory Developments
The International Maritime Organization’s Sub-Committee on
Carriage of Cargoes and Containers (CCC) addressed a range of
maritime safety, cargo transport and operational issues during
its latest session. The work covers both the development of new
guidance and the preparation of future amendments to existing
international maritime instruments.
Key areas include the revised interim guidelines for ships using
methyl or ethyl alcohol as fuel, the development of safety
guidelines for Onboard Carbon Capture and Storage (OCCS) systems,
proposed IMSBC and IMDG Code changes, and interim performance
guidance for lashing software used alongside the Cargo Securing
Manual.
These developments have different regulatory statuses. Some work
has been finalized at Sub-Committee level for submission to the
Maritime Safety Committee, while other items remain under
development or are scheduled for further consideration.
Stakeholders should distinguish completed technical work from
formal approval, adoption and entry into force.
Regulatory status: Dates stated in this
article are the targets described in the supplied CCC 12
briefing. A planned approval, adoption or entry-into-force
date does not, by itself, make a proposed requirement
currently mandatory. Confirm the latest IMO decisions and
applicable instruments before making compliance decisions.
Key Regulatory Updates
The following cards summarize the six main areas highlighted in
the CCC 12 briefing. Each topic has its own technical and
operational implications for the maritime industry.
Interim Guidelines for Methyl and Ethyl Alcohol-Fueled Ships
The Sub-Committee finalized the revision of the Interim
Guidelines for the safety of ships using methyl or ethyl
alcohol as fuel, associated with MSC.1/Circ.1621.
Next milestone: The revised guidelines
are to be submitted to MSC 113, scheduled for June 2027,
for formal approval.
Industry focus: Shipowners and technical
managers considering alcohol-fueled vessels should
monitor the approval process and assess the implications
for vessel design, fuel arrangements and safety procedures
as the revised guidance progresses.
Onboard Carbon Capture and Storage Safety
CCC initiated the drafting of interim guidelines for the
safety of ships using an Onboard Carbon Capture and
Storage (OCCS) system. The work addresses the need for
safety guidance as these systems are developed for
maritime applications.
Planned milestones: Completion is
targeted for CCC 14 in 2028, with formal adoption
scheduled for MSC 116 in 2029, according to the supplied
briefing.
Industry focus: Owners and project teams
evaluating OCCS installations should follow the
development of the guidelines and consider future safety
and integration requirements during project planning.
IMSBC Code Amendments and New Bulk Cargoes
The briefing reports that nine new solid bulk cargoes,
including Contaminated Soil and Direct Shipping Ore
Spodumene, are progressing toward IMSBC Code Amendment
09-27. Polymetallic Nodules were deferred to CCC 13 while
testing issues are resolved.
Documentation focus: Shippers should
prepare for expanded cargo declarations that explicitly
address subsidiary hazards and Material Hazardous Only
in Bulk (MHB) notations, where applicable.
Additional development: The briefing
identifies a voluntary Bulk Cargo Number system rollout
in 2028. Stakeholders should monitor the final provisions
and implementation arrangements.
IMDG Code Amendments and Lithium Battery Safety
The briefing identifies proposed IMDG Code developments
targeting entry into force in 2030. These include
Special Provision SP980 for consignor safety checks for
electric and hybrid vehicle shipments, alongside changes
to general exemptions.
Work is also progressing on container-level energy
thresholds intended to address safety concerns involving
large quantities of small lithium batteries shipped
under Special Provision SP188. The proposals aim to
address when full dangerous-goods documentation may be
required.
Other topic: The briefing also identifies
updates to meter-based segregation provisions for
Class 7 radioactive materials.
Industry focus: Monitor the formal
amendment text and its eventual implementation. The
proposed container-level energy threshold should not be
treated as an already adopted universal requirement.
Lashing Software and the Cargo Securing Manual
CCC finalized interim guidelines establishing a
two-module performance standard for lashing software.
The guidance permits such software to supplement, but
not replace, an approved containership Cargo Securing
Manual.
The guidelines are described in the briefing as a
non-mandatory circular. Their interim status allows
future refinement as operational experience develops.
Potential future developments: The
briefing identifies real-time motion sensors and
automated weather data integration as examples of
capabilities that may inform future developments.
Industry focus: Operators should
maintain the distinction between the approved Cargo
Securing Manual and supplementary software, and review
the applicable guidance before changing onboard
operational procedures.
Interim Guidelines for Low-Flashpoint Fuel Oils
The Sub-Committee further developed draft Interim
Guidelines for ships using low-flashpoint fuel oils.
The work remains ongoing and will continue through an
intersessional Correspondence Group.
Next steps: The Maritime Safety
Committee is to be invited to re-establish the
Intersessional Working Group on Alternative Fuels
(ISWG-AF 4) to continue developing the guidelines.
Industry focus: Shipowners, technical
managers and project teams should follow the continued
development of the guidance and assess relevant
implications for fuel-system design, operational safety
and onboard procedures as the work progresses.
What Shipowners and Operators Should Prepare For
The regulatory work spans alternative fuels, emerging carbon
capture technology, solid bulk cargo declarations, dangerous
goods, and digital cargo-securing tools. Early preparation can
help stakeholders identify where future changes may affect
vessel operations, cargo documentation, procurement and
compliance processes.
Alternative Fuels and OCCS
Monitor the development and formal approval of the
relevant interim guidelines. Consider the potential
implications for vessel projects, fuel-system safety
reviews, equipment selection and operating procedures.
Bulk Cargo Declarations
Review existing cargo declaration workflows and prepare
to address applicable subsidiary hazards and MHB
notations as revised IMSBC Code provisions are confirmed.
Verify the requirements that apply to each cargo.
Dangerous Goods and Battery Shipments
Follow the formal IMDG amendment process, including
developments involving electric and hybrid vehicles and
lithium battery shipments. Do not implement proposed
thresholds as mandatory rules before their status is
confirmed.
Cargo Securing Software
Assess how supplementary lashing software is used onboard
and maintain the required distinction between software
support and the approved Cargo Securing Manual. Review
the relevant circular and applicable shipboard procedures.
Tracking Approval, Adoption and Implementation
The CCC 12 developments are at different stages of progress.
Finalization of draft guidelines at Sub-Committee level does not
necessarily mean that formal approval or adoption has already
occurred. Similarly, a target amendment year should not be
interpreted as confirmation that every provision will enter
into force on that date without further decisions.
For compliance planning, maritime stakeholders should confirm
the latest status of each instrument, identify the relevant
MSC decisions and circulars, and review the applicable edition
of the IMSBC or IMDG Code. Where a change remains under
development, planning should account for uncertainty until the
final text and implementation arrangements are established.
Practical reminder: This article is a
technical overview based on the supplied CCC 12 briefing.
It is not a substitute for the final IMO resolutions,
circulars, amendment texts, flag Administration instructions
or other applicable statutory requirements.
Conclusion: Early Awareness of Emerging Maritime Requirements
The CCC 12 work programme highlights continuing developments
across alternative marine fuels, onboard carbon capture,
solid bulk cargo requirements, dangerous-goods transport and
digital support for cargo securing. These topics may have
implications for ship design, cargo declarations, technical
documentation and operational readiness as the relevant
instruments progress.
Shipowners, ship operators, technical managers, shippers and
other maritime stakeholders should continue monitoring formal
IMO decisions and assess each change against their particular
vessels, cargoes and operations. Early review can support
orderly planning while ensuring that compliance decisions are
based on requirements that have actually been adopted and
become applicable.
Frequently Asked Questions
What was the main focus of the IMO CCC 12 session?
The session progressed work on alternative-fuel safety,
Onboard Carbon Capture and Storage systems, IMSBC and IMDG
Code developments, lashing software for cargo securing,
and low-flashpoint fuel oils. The items have different
statuses, ranging from finalized draft guidance to work
continuing in intersessional groups.
When are the revised alcohol-fuel ship guidelines expected to be considered?
According to the supplied briefing, the revised Interim
Guidelines for ships using methyl or ethyl alcohol as fuel
are to be submitted to MSC 113 in June 2027 for formal
approval. The planned date should be checked against the
latest IMO meeting outcomes.
When are the OCCS safety guidelines expected to be completed?
The supplied briefing identifies CCC 14 in 2028 as the
target for completing the Interim Guidelines for ships
using an Onboard Carbon Capture and Storage system, with
formal adoption scheduled for MSC 116 in 2029. These are
planned milestones, subject to the formal IMO process.
What IMSBC Code changes should shippers monitor?
The briefing reports that nine new solid bulk cargoes,
including Contaminated Soil and Direct Shipping Ore
Spodumene, are progressing toward Amendment 09-27.
Polymetallic Nodules were deferred to CCC 13 to resolve
testing issues. Shippers should also monitor developments
concerning subsidiary hazards, MHB notations and the
voluntary Bulk Cargo Number system.
What is the proposed IMDG Code change concerning SP188?
The briefing describes ongoing work on container-level
lithium battery energy thresholds, intended to address
safety concerns with large quantities of small batteries
shipped under Special Provision SP188. The proposed
approach includes consideration of full dangerous-goods
documentation above a specified threshold. The final
provisions and regulatory status must be confirmed from
official IMO outputs.
Will lashing software replace the Cargo Securing Manual?
No. As described in the briefing, the interim performance
guidelines permit lashing software to supplement, but not
replace, an approved containership Cargo Securing Manual.
Operators should consult the applicable circular and
maintain the approved manual as required.
Are all the CCC 12 developments already mandatory?
No. The briefing covers a mixture of finalized draft
guidance, ongoing drafting, proposed code amendments and
future approval or adoption targets. Stakeholders should
verify the final text, formal IMO decisions and applicable
implementation dates before treating a development as a
binding requirement.
How can shipowners prepare for future regulatory changes?
Shipowners and operators can monitor official IMO decisions,
review cargo declaration and dangerous-goods procedures,
assess implications for vessel projects and onboard
documentation, and identify which proposed developments
could affect their fleets. Compliance actions should be
based on the requirements applicable to each vessel and
operation.
PAMS Pacific Admiralty Maritime Services
PAMS Pacific Admiralty Maritime Services is an independent
marine technical consultancy based in Manila, Philippines,
providing marine surveying, engineering support, inspection,
audit and maritime regulatory compliance consultancy.
Its technical focus includes vessel condition and damage
assessments, technical inspections, engineering and project
support, and regulatory frameworks relevant to ship operations,
including ISM, ISPS, MLC, RightShip RISQ 3.2, OCIMF SIRE 2.0
and TMSA.
Regulatory developments should always be assessed against the
applicable IMO instruments, flag Administration requirements
and the operational circumstances of the vessel or cargo.
PAMS provides independent technical consultancy and does not
replace the statutory role of the relevant Administration or
Recognized Organization.