
Loss Prevention
Published: September 16, 2025
The guidance issued under Marine Notice 2025/04 supersedes Marine Notice 2022/12, and should be read in conjunction with MARPOL Annex VI and its associated guidelines, relevant Acts and Marine Orders.
1. Application
The guidance is intended to provide awareness for maritime stakeholders on the requirements of vessels with installed EGCS when in Australian waters.
2. Requirements
AMSA reiterates that for compliance in Australian waters, the EGCS should be:
- approved by the vessel’s Flag State Administration, or a Recognised Organisation appointed by the Flag State.
- operated in accordance with International Maritime Organization (IMO) requirements, including the MEPC.340(77) - 2021 GUIDELINES FOR EXHAUST GAS CLEANING SYSTEMS.
In addition, the key elements of the guidelines are summarised for the understanding of our Members.
- While all EGCS types (Open-loop, Closed-loop and Hybrid) can be operated and release discharge water in Australian waters, all discharges must meet the discharge water quality criteria indicated in the relevant IMO guidelines.
- EGCS sludge and residues should be disposed of at reception facilities and must not be discharged at sea or incinerated on board.
- Operational requirements are crew familiarity, equipment functionality, timely maintenance, and recordkeeping.
- EGCS malfunctions are to be attended and addressed immediately.
- If the malfunction occurred once and was resolved within 1 hour, there is no requirement to report it.
- If the malfunction lasts for more than one hour or occurs repeatedly, the vessel should switch to a compliant fuel and report the incident to the vessel’s Flag State Administration and the Competent Authority of the Port State of the vessel’s destination.
- If a malfunction occurs and the vessel does not have sufficient compliant fuel, report the situation to the vessel’s Flag State Administration and the Competent Authority of the Port State of the vessel’s destination, outlining the vessel’s proposed course of action for their agreement. This might include bunkering compliant fuel at the next port or carrying out repairs.
3. Recommendations
It is recommended that vessels operating EGCS in Australian waters ensure that:
- The requirements in Australian waters are included in the SOx Emissions Compliance Plan (SECP).
- The operational records are maintained in the EGCS Record Book along with supporting evidence, where relevant.
- The operational requirements of crew familiarity, equipment functionality and maintenance are ensured and documentary evidence retained.
- Malfunction of EGCS and non-availability of compliant fuel is promptly reported to the relevant authorities.
Members are advised to incorporate these requirements in the SOx Emissions Compliance Plan (SECP) or similar document to ensure compliance, avoid potential penalties, and prevent operational disruptions to the vessel.
Supportive Information
For further information on this or other Loss Prevention topics please contact the Loss Prevention Department, Steamship Insurance Management Services Ltd.
Tel: +44 20 7247 5490 Email: [email protected]
Information Notice 24