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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.

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