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Technical Notices
Ban on use of Anti-Fouling Systems that contains Cybutryne
IMO adopted amendments to the AFS Convention vide Resolution MEPC 331 (76) to include controls on Cybutryne and an operative paragraph with respect to issuance of the new International Anti-fouling System Certificate.
The amendments will enter into force on 1 January 2023.
In addition to the already prohibited organotin compounds which act as biocides (try butyl tin, TBT) in anti-fouling systems, the ingredient cybutryne (CAS No. 28159-98-0) will be prohibited as per the amendments to the AFS Convention. The affected ship types and effective dates are listed in the table below:
Anti-fouling system | Control measures | Application | Effective date |
Cybutryne CAS No. 28159-98-0 | Ships shall not apply or re-apply antifouling systems containing | All ships | 1 January 2023 |
Cybutryne CAS No. 28159-98-0 | Ships bearing an anti-fouling system that contains this substance in the external coating layer of their hulls or external parts or surfaces on 1 January 2023 shall either:
1) remove the antifouling system; or 2) apply a coating that forms a barrier to this substance leaching from the underlying noncompliant anti-fouling system. |
All ships except:
1) fixed and floating platforms, FSUs, and FPSOs that have been constructed prior to 1 January 2023 and that have not been in drydock on or after 1 January 2023; 2) ships not engaged in international voyages; and 3) ships of less than 400 gross tonnage engaged in international voyages, if accepted by the Coastal State(s). |
At the next scheduled renewal of the anti-fouling system after 1 January 2023, but no later than 60 months following the last application to the ship of an anti-fouling system containing Cybutryne |
Further, the amended Annex 4 of the AFS Convention provides a revised model form of the International Antifouling System (IAFS) Certificate. Based on verification of compliance to amended requirements, an updated IAFS Certificate will be issued reflecting the compliance options for controlled anti-fouling systems on the ship.
The International AFS certificate will change as of 1 January 2023 to include extra cybutryne tick boxes for the compliance options on controlled anti-fouling systems.
Ships in operation will need to comply with the requirement within the first anti-fouling renewal survey after 1 January 2023 and will be issued a new International AFS certificate which includes cybutryne-free compliance.
Ships under construction, which will be delivered after 1 January 2023, will need to be delivered as both TBT and cybutryne-free, and will be issued with an AFS certificate at the initial survey.
Ship owners/ managers and masters are advised to take note of above requirements and accordingly ensure that necessary planning is done while procuring anti-fouling paints so that it does not contain Cybutryne. In case of ships where anti-fouling system already contains Cybutryne (CAS No. 28159-98-0) as on 1 January 2023, planning will be required for either the removal of such anti-fouling paint or for application of a sealing coating in consultation with the paint manufacturer in order to comply with the amended requirements.