Black Sea MOU: Regional Specificities
The Black Sea MoU 2025 BWM CIC has ended; current priorities come from the 2026 calendar and circulars, not the past campaign.
Operational Explanation
The 2025 Ballast Water Management CIC has ended and its results are historical. BWM compliance remains permanent, but an ended campaign does not itself prove enhanced targeting in 2026.
Regulatory Reference
The Black Sea MOU coordinates regional control, targeting and reporting. Do not presume identical instrument lists or ratification in every member State. For each call distinguish applicable conventions, regional procedures and national law; the 2025 BWM campaign alone does not establish 2026 priorities.
Where the power to come on board comes from. Not from the Memorandum. A regional MoU is an administrative arrangement between Administrations: it harmonises how inspections are done, it does not create the right to inspect. That right sits in the control articles of the Conventions, which resolution A.1206(34) — Procedures for Port State Control, 2025 — lists one by one at its paragraph 1.4. For SOLAS there are four regulations, not one: I/19, IX/6.2 (ISM), XI-1/4 and XI-2/9 (ISPS). For MARPOL, Articles 5 and 6 plus one provision per Annex: reg. 11 of Annex I, reg. 16.9 of II, reg. 9 of III, reg. 14 of IV, reg. 9 of V and reg. 10 of VI. The “reg. 9 of III” surprises anyone who opens Annex III in the text adopted by res. MEPC.193(61), where port State control on operational requirements is Regulation 8: res. MEPC.246(66), in force from 1 January 2016, inserted a new Regulation 1 “Definitions” into it and provided that “the subsequent regulations are renumbered accordingly”. Since 2016 that provision has been Regulation 9, and that is the number A.1206(34) carries. Then Article 21 of the Load Lines Convention 1966 as modified by the 1988 Protocol, Article X of STCW, Article 12 of TONNAGE 1969, Article 11 of AFS 2001 and Article 9 of BWM 2004. For the MLC, an ILO and not an IMO instrument, the basis is Regulation 5.2.1 with Standard A5.2.1.
Flag membership of the MoU does not determine control powers. Check instruments in force and accepted by the port State and national bases; no-more-favourable treatment also concerns ships of non-Parties. IMO A.1206(34), §§1.2–1.5.
Attributing a 2026 CIC to this region requires its official notice, dates, scope and questionnaire. The Paris/Tokyo notice does not automatically establish other MoUs’ participation. If the regional source is unavailable, leave participation unconfirmed rather than infer it from previous campaigns.
Scope of Application
Ships calling at ports of Black Sea MOU member States, with particular relevance for commercial traffic in the Black Sea region and the approaches to the Turkish Straits.
Procedure / How to Complete It
- Check the Black Sea MoU current calendar and circulars.
- Separate permanent obligation from temporary campaign.
- Use 2025 results as history, not a current targeting notice.
- Prepare for the applicable 2026 CIC from the current notice and questionnaire.
Practical Example
Example: before a call check the competent Authority, regional profile, current notices and ship requirements. The Annual Report describes a past period: it does not replace a targeting notice or the current campaign questionnaire.
What Typically Goes Wrong
The 2025 figures previously reported here — 347 detentions, 5,117 inspections and 6.78% — remain pending direct verification against the regional annual report, which was not accessible during this review. Do not treat them as primary-source-verified figures. The figure describes period outcomes and does not by itself prove stricter inspectors or a current BWM priority.
Common Mistakes Mistake Library
| Mistake | Consequence | How to avoid it |
|---|---|---|
| Using the 2025 rate as proof of stricter inspection | A descriptive figure is converted into a cause | State year, numerator and denominator without inferring the cause of the rise |
| Presenting the 2025 BWM CIC as current priority | An ended campaign is confused with permanent duty | Check the 2026 calendar and circulars; keep BWM compliance separate |
What the PSCO Checks
Operational Tips
- Consult current Black Sea MoU Annual Report, calendar and circulars.
- Use 6.78% as a historical 2025 figure, not causal proof of stricter inspection.
- Treat BWM as permanent compliance and the 2025 CIC as ended.
Preparation checklist
- Current calendar checked
- 2025 CIC labelled historical
- BWM retained as permanent duty
- 2026 CIC checked against current source
FAQ
Related Topics
Last substantive revision of this page: 16 September 2026 · page fingerprint 399893044098