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Brazil has updated its regulations for controlling and managing ship’s biofouling to align with the 2023 IMO Biofouling Guidelines.
NORMAM-401: Biofouling Compliance Moves into Focus as VLI Terminals Request UWI Reports
Correspondent Rabb Carvalho brings us this update.
Recent technical discussions with the Brazilian Maritime Authority have provided further clarity on the practical application of NORMAM-401/DPC, Brazil’s regulatory framework for the management of biofouling on vessels operating in Brazilian Jurisdictional Waters.
Although the application of penalties under the relevant provisions has been postponed, the underlying compliance requirements remain in force.
At the same time, an important operational development is emerging at terminal level. VLI-managed terminals have begun requesting information concerning vessels’ latest Underwater Inspections (UWI) as part of their technical vessel acceptance procedures.
For shipowners, managers and operators, this creates two distinct but increasingly interconnected considerations: compliance with the Maritime Authority’s regulatory requirements and compliance with the individual technical acceptance criteria imposed by the destination terminal.
The practical approach currently indicated by the Maritime Authority is that compliance with NORMAM-401 will be assessed principally through the vessel’s documentation.
For vessels subject to Chapter 4, the principal documents include:
Biofouling Management Plan (BFMP);
Biofouling Record Book (BFRB); and
Hull inspection or cleaning report, where applicable.
For vessels entering Brazilian Jurisdictional Waters or navigating between different Brazilian biogeographical regions, the relevant inspection or cleaning report must contain sufficient photographic or video evidence to demonstrate the vessel’s biofouling condition in accordance with the criteria set out in Annex J of NORMAM-401.
The practical consequence is that having carried out an inspection may not, of itself, be sufficient. Owners and operators should also ensure that the resulting report contains the evidence and information required by the Brazilian rules.
As a general rule, an inspection or cleaning report may remain valid for up to 12 months, provided that the vessel continues to satisfy the conditions prescribed by NORMAM-401.
Particular attention should be paid to vessels which:
remain stationary for more than 15 consecutive days; or
operate at speeds below 10 knots for more than 15 consecutive days.
Such circumstances may affect the continuing validity of the relevant inspection or cleaning report.
The applicable documentation must also be made available through Brazil’s Porto sem Papel (PsP) system for assessment by the Brazilian Maritime Authority.
Owners and managers should therefore consider the vessel’s trading and operational history when assessing whether an existing report remains suitable for a forthcoming Brazilian call.
Postponement of penalties does not postpone compliance
The penalties and sanctions applicable under Chapter 4 have been postponed until 10 January 2028.
Importantly, however, the postponement relates to enforcement sanctions and does not suspend the substantive requirements and procedures established by NORMAM-401.
During the transitional period, the Brazilian Maritime Authority is expected to adopt a predominantly educational and advisory approach.
Owners and operators should nevertheless avoid treating the transitional period as a general exemption from compliance. The relevant plans, record books, reports and supporting evidence should remain complete, up to date and readily available for submission.
This is becoming particularly important because compliance issues may have consequences beyond regulatory enforcement.
VLI introduces UWI information into vessel acceptance procedures
Alongside the Maritime Authority’s regulatory requirements, VLI has incorporated UWI information into the technical assessment of vessels calling at certain terminals under its management.
the date of the vessel’s most recent Underwater Inspection (UWI); and
a copy of the corresponding inspection report.
An identified non-compliance with the applicable requirements may be taken into account as part of the vessel’s technical assessment.
It is important, however, to distinguish this from an automatic rejection criterion. On the information presently available, VLI’s communication does not establish that the mere absence of the requested UWI documentation will automatically result in the vessel being rejected.
The procedure presently applies to the following VLI-managed facilities:
Tubarão – TPD3 and TPD4;
TIPLAM – Santos;
BDQ/TMIB – Barra dos Coqueiros; and
TPSL – Itaqui.
Potentially, yes.
Terminal operators may establish their own technical vessel acceptance and vetting criteria independently of the procedures adopted by the Brazilian Maritime Authority.
The postponement of regulatory penalties under NORMAM-401 therefore does not prevent terminals from introducing their own documentary requirements concerning biofouling, hull inspections or UWI reports.
Other terminals — particularly those operating more detailed vessel vetting or technical acceptance programmes — may consequently adopt similar procedures.
This distinction is commercially important. A vessel may satisfy the immediate requirements of the Maritime Authority but still face additional questions during the terminal’s own acceptance process.
Equally, the absence of regulatory penalties until 2028 should not be assumed to prevent a terminal from requesting evidence of compliance as a condition of its technical assessment.
Owners, managers, charterers and operators should consider NORMAM-401 compliance before the vessel arrives in Brazil, rather than addressing documentary issues only once the vessel is nominated to a terminal.
For vessels calling at VLI terminals, the latest UWI documentation should be checked at an early stage of the vessel nomination and acceptance process.
For calls at other Brazilian terminals, owners and operators should likewise confirm in advance whether any additional biofouling or underwater inspection requirements form part of the relevant terminal’s vetting procedures.
Regulatory compliance and terminal acceptance should be considered separately. The key practical point is that NORMAM-401 compliance and terminal acceptance are related, but they are not the same exercise.
A vessel calling Brazil may increasingly need to satisfy two parallel layers of scrutiny: the regulatory requirements imposed by the Brazilian Maritime Authority; and the technical and commercial acceptance criteria imposed by the individual terminal.
Early verification of both may help owners and operators identify documentary deficiencies before arrival and reduce the risk of queries, delays or difficulties during the vessel acceptance process.
Recommended you consult your ship agent before calling at a Brazilian port.
Read more on correspondent Rabb Carvalho website here.
Brazil confirms postponement of biofouling penalties to January 2028
Correspondent Rabb Carvalho Advocacia brings us this update.
The Brazilian Navy’s Directorate of Ports and Coasts has issued the official document confirming the postponement of penalties and sanctions related to Brazil’s biofouling regulation. Ordinance No. 476/DPC/DGN/MB, dated June 3, 2026, approves NORMAM-401/DPC and postpones the start of the sanctioning phase to January 10, 2028.
The measure is a significant development for the maritime sector, particularly for shipowners, operators, charterers, shipping agents, terminals and other companies involved in vessel operations in Brazil. Although the enforcement of penalties has been postponed, the regulation remains in force and the implementation process must continue.
NORMAM-401/DPC establishes the Maritime Authority Rules for the Prevention of Environmental Pollution caused by Vessels and Platforms, with a focus on preventing the transfer of invasive aquatic species through biofouling on hulls and niche areas.
Under the ordinance, the application of penalties and sanctions arising from violations listed in Chapter 4 of NORMAM-401/DPC has been postponed to January 10, 2028. The text also states that this extension is non-extendable and represents the final and definitive postponement granted before the start of the punitive phase.
Until that date, the Maritime Authority will act in an advisory capacity, promoting awareness and technical support for interested parties, with the aim of allowing full adaptation to the operational requirements established by the regulation.
Despite the postponement of penalties, the ordinance makes clear that the requirements of NORMAM-401/DPC already approved must be observed from the date the regulation enters into force, regardless of the temporary non-application of penalties. In practical terms, companies and vessels should not treat the new deadline as a suspension of the regulation, but as an additional period for implementation, document review, training and procedural adjustments.
In practical terms, shipowners and operators should continue maintaining available, whenever applicable, the Biofouling Management Plan, the Biofouling Record Book, the AFS Certificate or Declaration, hull inspection and maintenance records, as well as supporting evidence regarding the hull and niche area condition of the vessel.
Compliance assessments are expected, at least at this initial stage, to be primarily document-based. Even so, maintaining updated and consistent records will be essential to reduce operational risks, avoid questions during calls at Brazilian ports and demonstrate good-faith efforts in adapting to the regulation.
The implementation of the regulation also continues to evolve at the local level. Maritime Authorities across different regions of Brazil have been conducting meetings and technical discussions with shipping agents, shipowners, terminals, diving companies and other stakeholders in order to establish a more uniform understanding of the regulation and its practical application.
In this context, a recent technical session promoted by the Harbour Master’s Office in Rio Grande reinforced the expectation that compliance assessments will be mainly based on documentation. Additional clarification sessions are also being scheduled in other regions, including Santos, with a meeting expected on July 14.
Another relevant point from a market perspective is that some terminals have already started reviewing biofouling-related documentation as part of their vessel acceptance process. Therefore, even during this non-penalisation period, vessels may still be requested to provide supporting documents and evidence of compliance before or during their operations.
The regulation aims to reduce the environmental risk associated with the introduction of invasive species, a topic that has gained increasing international relevance within the International Maritime Organization. Biofouling may occur when marine organisms attach to submerged vessel surfaces and are later transported to other ecosystems. This process may cause relevant environmental, economic and operational impacts.
Owners and operators should continue preparing their vessels in accordance with NORMAM-401/DPC requirements while local procedures and implementation practices continue to be refined by the Brazilian authorities.
Correspondent Rabb Carvalho Advocacia brings us this update.
The enforcement of fines and sanctions related to non-compliance with Brazil’s biofouling rules has been officially postponed for 18 months and will now come into force in January 2028.
The decision follows the assessment of the matter by the Directorate of Ports and Coasts (DPC) during a meeting held on May 14 and marks a new stage in the implementation process of NORMAM-401/DPC, the regulation establishing requirements for the prevention of environmental pollution caused by vessels and platforms in Brazilian Jurisdictional Waters.
Although the penalties have been postponed, the regulation remains in effect and its implementation process continues. The change applies only to the beginning of fines and sanctions enforcement, allowing the maritime sector, the market and the authorities additional time to prepare for and adapt to the new requirements.
The main objective of NORMAM-401 is to reduce the risk of transferring invasive aquatic species through biofouling, in line with the guidelines of the International Maritime Organization (IMO).
In general terms, the regulation applies to vessels longer than 24 meters operating, entering or navigating within Brazilian Jurisdictional Waters, subject to the exemptions provided for in the regulation itself.
Among the key obligations, covered vessels must maintain on board a Biofouling Management Plan and a Biofouling Record Book.
These documents are an essential part of the compliance routine and must demonstrate that the vessel has adequate procedures, records and controls to prevent, monitor and manage the accumulation of organisms on the hull and other submerged structures.
Another relevant requirement is the need for a recent inspection or cleaning report to enter Brazilian Jurisdictional Waters or to navigate between the three distinct biogeographical regions of the Brazilian coast.
This report must include high-resolution photos or videos and prove that the vessel’s biofouling level is equal to or lower than 1, corresponding to microfouling.
The report will be valid for one year, provided that the vessel does not remain stationary for more than 15 consecutive days. For clearance purposes, the document must be uploaded to the Porto Sem Papel platform under the attachments field, as part of the clearance and control process carried out by the competent authorities.
If the vessel does not have an inspection or cleaning report issued at the last port before entering Brazilian Jurisdictional Waters, or before transiting between different biogeographical regions, the procedure may be carried out, on an exceptional basis, at the first port of call in national waters or within the new region.
In such cases, the responsible party must submit a justified request to the Maritime Authority Agent with jurisdiction over the location where the inspection or cleaning is intended to take place.
If the initial inspection identifies a biofouling level equal to or greater than 2, the vessel will be required to take the necessary corrective measures. This reinforces the importance of prior planning, especially for vessels operating on international routes, remaining idle for extended periods or alternating calls between different regions of the Brazilian coast.
In practical terms, the postponement of penalties reduces the immediate risk of fines or sanctions, but it does not remove the need for compliance. The period until January 2028 should be treated as a regulatory transition phase, during which shipowners, operators, shipping agents, terminals and service providers will have the opportunity to review procedures, adjust documentation routines, prepare teams and structure compliance workflows.
For the maritime sector, the key recommendation is to treat the extension as a preparation window, not as a suspension of obligations. The regulation remains in effect, and early adaptation tends to reduce operational risks, clearance delays, regularization requirements and potential commercial impacts once the sanctioning phase becomes enforceable.
Correspondent Brazil P&I brings us this update.
Growing international concern over the introduction of invasive alien species into the marine environment has led the Brazilian Navy to strengthen its regulatory framework for controlling biofouling on vessels. This resulted in the issuance of NORMAM-401/DPC, which established a comprehensive set of rules aimed at managing biological fouling on ship hulls and submerged structures.
With NORMAM-401/DPC, the country has made the guidelines of the International Maritime Organization (IMO) mandatory for vessels longer than 24 meters, applying them to both domestic and foreign ships operating in Brazilian jurisdictional waters, including those under Authorization for Traffic in Brazilian Jurisdictional Waters (AIT). Although formal procedures for requesting authorisations began in June 2025, the full enforcement for administrative penalties related to biofouling is schedules to come fully into effect on June 10, 2026.
The Maritime Authority, through the Directorate of Ports and Coasts (DPC), responds to questions from the National Center for Transatlantic Navigation (Centronave) on the subject.
Read the questions and answers on the new rules for ships in Brazil in the circular here.
Correspondent Brazmar brings us this update.
In June 2025, the Directorate of Ports and Coasts (“DPC”), which is part of the Brazilian Navy, issued Ordinance DPC/DGN/MB No. 180/25 (Annex 1), approving the first revision of the Maritime Authority Standards for the Prevention of Environmental Pollution Caused by Vessels and Platforms (“NORMAM-401”).
Brazmar’s circular summarises the new requirements for vessels over 24 metres, including the carriage and implementation of a Biofouling Management Plan and Record Book. It outlines acceptable biofouling levels, inspection and cleaning expectations, regional considerations along the Brazilian coastline, and procedures for in-water cleaning authorisation. Enforcement timelines, potential penalties, and practical compliance considerations based on discussions with the Brazilian Maritime Authority, supporting operators in managing regulatory risk and preparing for full enforcement from 2026 are also discussed.
Read the circular here.
Annex 1 – here
Annex 2 – here
Correspondent Cranston Marine P&I Consultants brings us this update.
New Brazilian regulations on Biofouling Management were recently enacted by the Maritime Authority under Chapter 4 of NORMAM-401/DPC. These provisions establish a national framework for the control and management of hull fouling on vessels operating in Brazilian Jurisdictional Waters (Águas Jurisdicionais Brasileiras – AJB). Their main objective is to minimise the introduction and spread of non-indigenous aquatic species through vessels’ submerged surfaces, in line with the IMO’s Biofouling Guidelines (MEPC.207(62) and MEPC.378(80)).
The regulation applies to vessels exceeding 24 meters in length overall that either enter Brazilian waters or navigate between the country’s three designated marine biogeographic regions (North, Northeast, and Southeast/South). This regional division aims to prevent not only international introductions but also the domestic transfer of invasive species between Brazilian zones.
The regulation entered into force on 17 June 2025. However, item 4.5.1 of the NORMAM-401/DPC provides that the period until 1 February 2026 shall be used for adaptation by the maritime community. During this transition, the Maritime Authority is applying the rule under an educational or “soft enforcement” approach. After that date, penalties and sanctions will become applicable for non-compliance.
However, there remains a degree of uncertainty about how enforcement will be exercised after the transition period. At present, the regulation is still in its implementation phase. For now, we advise Members to treat this as a transitional compliance period, ensuring the new standards are met to avoid future liability once the enforcement phase begins on 1 February 2026.
There has been an increase in regulatory activity in biofouling regulations in two key regions, Brazil and Norway. These new requirements have an emphasis on cleaning with capture when macrofouling is present, however there are some differences between the two which are provided in Intertanko’s Environmental Bulletin.
Read more here.
Correspondent Proinde brings us this update.
The Brazilian Navy has updated its regulations for controlling and managing ship’s biofouling to align with the 2023 IMO Biofouling Guidelines. All affected ships must comply promptly, and full enforcement, along with penalties for non-compliance, will come into effect on 1 Feb 2026.
Under NORMAM-401/DPC, all ships over 24 metres in length, whether they are underway, anchored, or laid up with Brazilian jurisdictional waters, must adhere to the IMO biofouling regulations and guidelines.
These ships are required to maintain a Biofouling Management Plan (BFMP) and a Biofouling Record Book (BFRB) on board. They must document their compliance with the routines and procedures outlines in the BFMP, including inspections, dry docking, and in-water cleaning, as specified in the plan. Both the BFMP and the BFRB must be readily available for verification by the relevant local authorities.
More on exceptions, requirements, prohibitions, and recommendations can be found in Proinde’s circular here.
