Interferry has consultative status at the International Maritime Organization (IMO), which means it is deeply involved in helping to shape safety and environmental regulations in the global maritime industry. And in virtually every case, we do so on the basis of an unshakeable conviction that one size does not fit all.
Ferries and ferry operations have unique characteristics that demand sector-specific considerations to be taken into account when developing and implementing regulations. Happily, regulators have yet again acknowledged this following our latest representations on aspects of greenhouse gas emissions and shipboard incident response.
In autumn 2024, session 82 of the IMO Marine Environment Protection Committee met to address proposed revisions to the controversial Carbon Intensity Indicator (CII) regulation setting the allowance for fuel burned per nautical mile. The draft formula was a major concern for us because CII performance for a ferry making numerous port calls would be adversely affected by the fuel consumed during operational acceleration and manoeuvring, as well as time spent at berth. We submitted the idea of a balancing mechanism in which compliance is based on an operator’s fleet average. Our intervention, alongside concerns from other shipping segments, resulted in the measure being postponed from 2026 until at least 2030.
On the greenhouse gases front, we have also been pressing for the IMO High-Speed Craft Code to be redesignated as a High Speed and Light Craft Code. The rationale behind this is that it does not make sense to have an IMO instrument that mandates high speed in a ship, when it’s actually the lower weight that is of interest for the operator. By removing the current minimum speed requirement, orders will flow for many more low-emissions lightweight craft, in particular providing new opportunities for hybrid and electric craft.
As for safety issues, in January 2025 the eleventh annual session of the IMO ship design and construction sub-committee (SDC) considered revisions to interim explanatory notes assessing passenger ship capabilities after a fire or flooding casualty. Interferry’s main focus was on the Safe Return to Port (SRtP) provisions, which are to be finalised at SDC12 in January 2026.
The IMO’s Marine Environment Protection Committee agreed to postpone the Carbon Intensity Indicator regulation from 2026 until at least 2030 following Interferry’s intervention
We made it clear that we would not accept any retroactive application. Supported by many others, we also questioned the value of a special SRtP training and qualification regime for new ships, highlighting that SRtP drills should be formalised and subject to passenger ship safety survey. We have 15 years’ worth of SRtP experience and there is no indication that training and drills have not been good enough. It was agreed that any training/drill issues should be dealt with by the on-going review of Standards of Training, Certification and Watchkeeping.
Some elements of SRtP are clearly more relevant to very large cruise ships in deep-sea operation as opposed to ro-pax ferries providing short-sea ro-pax services, notably in regard to voyage duration and the consequent requirements on levels of provisions and crewing. The flag states were not supportive of the industry-wide relaxation of these requirements, but many did suggest this is something they could agree with operators without it being part of the legal text.
Draft revisions also define the durations of SRtP voyages in both adverse and favourable weather conditions. The time and minimum speed allowances could be limiting for current and future full-electric and hybrid-electric designs, but there was a moderate relaxation of the provision allowing lower speed to be accepted if the operator can demonstrate manoeuvrability.
Last but not least, Interferry has successfully convinced regulators about the capability of ferries to cope with fires emanating from battery electric vehicles (BEVs). Findings from our involvement in the European Union’s 2019-2023 Fire Safe project prompted our heavy engagement on IMO regulations for carrying BEVs. Our fundamental input stressed that there is no higher fire risk compared with that posed by combustion-engine vehicles. We have presented evidence that BEV fires can be controlled onboard by conventional drencher systems before SRtP for any further assistance required from professional firefighters.
Discover more insights like this in the Spring/Summer 2025 issue of Cruise & Ferry Review. Don’t miss out – subscribe for FREE and get the next issue delivered straight to your inbox.