Brazil’s New Biofouling Rules: What You Need to Know (and Do)

Tue, 12 Aug 2025 23:13:04 GMT

Here’s what you need to know, before Feb 2026!

The rules are already in effect (since 17 June 2025), but full enforcement starts February 1st 2026.

In vessel maintenance terms, that’s tomorrow.

Unfortunately, invasive species don’t usually find enough natural predators in new environments to keep them in check… which is why these rules exist in the first place.

1. Hull Condition: Rating 1 or Lower...

Please don’t shoot the messenger on this one, but you can't have barnacles or “hard growth,” only light slime and we know that’s extremely challenging...

Quick Tip: Assign one crew member to check the waterline and niche areas in port or at anchor. If it’s more than light slime, note it in the record book and arrange an in-water clean before it progresses any further. A wipe-down now is far easier (and cheaper) than scraping later. And to make things more complex, scraping can ruin your coatings, which then just adds another bill to the pile.

Figure 1: Rating scale to assess the extent of fouling. Source: IMO MEPC 80/17/Add.1 / NORMAM-401/DPC

2. In-water cleaning is allowed, but...

You'll need 10+ days’ approval before arrival
You'll need waste capture — meaning Brazil wants it collected, filtered, and disposed of properly...
Find out port-specific rules checked in advance, you can use our FREE email template to help remove some back and forth.

3. Two Documents You Must Have (NORMAM-401/DPC)

Biofouling Management Plan (BFMP) – vessel-specific, 2023 IMO format
Biofouling Record Book (BFRB) – log all inspections, cleanings, and fouling assessments.

If your BFMP is following the 2011 IMO template, not the 2023 version, copied from another vessel, or hasn’t been touched in years, update it now — not in January. And yes, we might just know someone who can help you with this ��.

Figure 2: Brazilian maritime biogeographic regions. Source: NORMAM-401/DPCscale to assess the extent of fouling. Source: IMO MEPC 80/17/Add.1 / NORMAM-401/DPC

4. You might be exempt?

There's a small chance that you can ignore this whole post IF you're a Navy vessel OR operate a vessel that hasn't left Brazilian waters since last dry-docking OR certain oil and gas units. But even then, you still need to avoid harmful discharges. No true free passes here.

5 . The Fines...

If you’re heading to Brazil, don’t wait. Domestic and foreign vessels alike are in scope. Non-compliance can mean fines from BRL 500 up to BRL 50 million, plus delays, cleaning orders, or denied entry.

6. Our Take!

We get that biofouling control is just one of dozens of things on your radar — right up there with schedules, crew changes, and the coffee machine breaking at the worst possible time. But it’s also one of the few that can literally delay operations if ignored.

We wish we had better news, but the upside is we can at least take part of this off your plate. We can set you up with an automated BFMP and Record Book that stays up to date in automatically — so it’s one less thing to manage, and a little more time back in your day.

Bottom line: February’s coming fast.

Biofouling Rules Are Changing — This New Research Shows How

Wed, 06 Aug 2025 21:47:38 GMT

The conversation around biofouling compliance is changing — and fast.

In this review — “Past, present and (possible) future of biofouling regulatory instruments within the international marine environmental protection framework” — published by a multidisciplinary team of marine scientists, and environmental policy researchers to explore what’s working, and what isn’t, when it comes to regulating biofouling.

This paper lands at a pivotal moment for the maritime industry. We’re entering a new regulatory era — one where inconsistent documentation, overlooked niche areas, and reactive compliance simply won’t be enough.

As countries and ports begin to take stronger action on aquatic invasive species, vessel operators are being asked to show more than just intent — they must provide clear, structured proof that they’re managing biofouling proactively and responsibly.

The Message Is Clear: Things Are Shifting

1. The Biggest Gap Right Now Is the Lack of a Global Mandatory Standard

Everyone agrees biofouling should be managed — but not for the same reasons.

Ship operators focus on efficiency and cost savings.
Regulators and environmental bodies prioritize biosecurity and ecosystem protection.

That mismatch leads to a patchwork of rules, uneven enforcement, and missed expectations. The paper recommends:

" A tiered compliance framework is recommended...adjusting requirements based on vessel type or risk profile,
instead of one-size-fits-all plans" — Santos-Simón et al., 2025, pg. 13

2. Plans Must Reflect Vessel-Specific Risks — Not Just General Templates

While the paper doesn’t directly call out niche areas like sea chests or thrusters, it makes a strong case that biofouling strategies need to be vessel-specific and risk-based.

As the authors write:

“A roadmap to guide users in the decision-making process… [should consider]multiple factors, such as
the vessel operational profile, maintenance, boat area, and environmental conditions (e.g., salinity, water temperature).”
— Santos-Simón et al., 2025, pg. 15

This directly challenges the use of static, one-size-fits-all Biofouling Management Plans. It also aligns with how New Zealand’s Craft Risk Management Standard (CRMS) has evolved.

For example the CRMS Schedule 3 – MPI New Zealand includes a vessel checklist for a biofouling scoring
system where vessels must provide evidence of inspecting not just the bow thruster for example, but include
photos and details about each of its sub-components — including the tunnel, blades, boss cone, rope guard, and grating.

This level of specificity highlights why generic BFMPs — especially those without niche-level tracking — increasingly fall short in regulated ports.

3. Biofouling Management Is Following the Same Trajectory as Ballast Water Management

One of the most compelling insights in the paper is the comparison between biofouling and ballast water regulation:

“The Biofouling Convention is expected to be someday the sibling Convention of the BWM Convention.”
— Santos-Simón et al., 2025, pg. 11

We’ve seen this before with ballast water — what began as guidance became law. Biofouling is now on the same path.
So it’s not a matter of if, but when.

4. Mandatory International Regulation Is Coming

At MEPC 83 (April 2025) , the IMO formally agreed they will shift biofouling management from voluntary guidelines to enforceable international regulations.

The PPR Sub‑Committee has been assigned a 4-year window (2026–2029) to write it.
The goal: enforceable requirements that go beyond general guidelines — similar to how MARPOL or BWM rules work today.

For fleet managers, this is the moment to move from passive compliance to proactive readiness — to shift from simply having a plan to having a plan that works anywhere, and holds up to scrutiny.

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