MARPOL-certificates and marine pollution prevention equipment:

BG Verkehr / Dienststelle Schiffssicherheit
Referat Maschine
Brandstwiete 1
20457 Hamburg

Holger Steinbock
Phone: +49 40 36137-217
Fax: +49 40 36137-204

Jörg Heuckeroth
Phone: +49 40 361 37-231
Fax: +49 40 361 37-204
Mobile: +49 171 50 57 038

Administrative offences in relation to MARPOL infringements:

Bundesamt für Seeschifffahrt und Hydrographie
Sachgebiet S 41
Bernhard-Nocht-Straße 78
20359 Hamburg

Katrin Ewert
Phone: +49 40 31 90 74 10
Fax: +49 40 31 90 5000

Ship's sewage and garbage (MARPOL Annex IV-V)

No discharge of untreated ship's sewage into the sea (MARPOL Annex IV)

According to Annex IV of the MARPOL Convention, discharging ship's sewage is generally prohibited. Exceptions are only applicable in compliance with Regulation 11 of MARPOL Annex IV. In general, a differentiation is made between passenger ships and other types of ships and whether or not the ship is located in a sewage special area. For example, in principle, ships other than passenger ships may discharge ship's sewage

  • if it was previously treated in a sewage treatment plant,
  • if it was treated with a sewage comminuting and disinfecting system and the ship is not less than 3 nautical miles away from the nearest land, or
  • if it is discharged from a holding tank approved by the administration with a moderate rate of discharge and the ship is en route with a minimum speed of 4 knots and not less than 12 nautical miles from the nearest land.

Further information is given on the website of the Federal Maritime and Hydrographic Agency (BSH).

Ship's sewage includes drainage from toilets, sanitary areas or rooms with living animals (so called black water) as well as other waste waters mixed with these drainages.

Annex IV of the MARPOL Convention applies to all ships on international voyages with a size of 400 GT or more, or such ships with less than 400 GT but which are approved for more than 15 persons (crew and passengers) on board. Even though Annex IV does not apply to recreational craft, the provisions of the German "See-Umweltverhaltensverordnung", section 9 on toilet sewage, apply.

The Federal Maritime and Hydrographic Agency (BSH) inflicts penalties for infringements of the MARPOL Convention in German maritime waters as well as by German-flagged ships as administrative offences in accordance with the Federal "See-Umweltverhaltensverordnung" (ordinance on maritime environmental conduct) provided they do not come under criminal law.

The Ship Safety Division of the BG Verkehr enforces the MARPOL requirements on German-flagged ships. Its surveyors and the surveyors of classification societies inspect the ship structure, equipment and documentation on the ship in accordance with Annex IV of the Convention. If all provisions are met, the Ship Safety Division issues the "International Sewage Pollution Prevention Certificate" (ISPP).

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bild schiffsabwasser

Ship's sewage and the Baltic Sea Special Area

The Baltic Sea is a special area for the discharge of sewage into the sea in accordance with MARPOL Annex IV. In association with this, stricter discharge limits for sewage already apply since 1 June 2019 for newly built passenger ships while for existing passenger ships they will enter into force from 1 June 2021. Under certain conditions, an extended transitional period ending on 1 June 2023 for single voyages of passenger ships into Russian territorial waters east of the 28°10´ longitude and back. These stricter provisions do not apply to cargo ships traveling in the Baltic Sea.

The stricter discharge limits for the special area can be achieved with the installation of advanced waste water treatment plants (AWWTP). The discharge limits for these plants (phosphorus: max 1.0 mg/l or 80 per cent reduction, nitrogen: max 20 mg/l or 70 per cent reduction) are similar to those for land-based municipal treatment plants and significantly reduce the nutrient input into the Baltic Sea.

Passenger ships can also discharge their sewage into reception facilities in all larger Baltic Sea ports. Without this environmentally friendly discharge possibility for sewage at port reception facilities, the International Maritime Organization IMO could not have declared the Baltic Sea a special area.

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Ship's garbage (MARPOL Annex V)

The pollution of the seas and the endangerment of the marine animal world by garbage, especially plastic garbage, is a significant environmental issue. Annex V of the MARPOL Convention contains detailed regulations for the management of garbage on board. In general, ships must not discharge garbage into the sea. Exceptions are:

  • food wastes,
  • cargo residues that are classed as non-harmful to the marine environment,
  • cleaning agents and additives contained in cargo hold, deck and external wash water if they are not harmful to the marine environment.

This garbage may only be discharged under strictly defined conditions outside of special areas and Arctic waters if the ship is en route.

In special areas according to MARPOL Annex V (for example the North and Baltic Sea), in Arctic waters and for swimming platforms, stricter provisions apply. For ships with special cargo like living animals or dry bulk cargoes, Annex V and its associated guidelines contain different requirements for the discharge of e.g. cargo residues in wash water.

The IMO advises to maintain an efficient garbage management on board and, subsequently, a discharge at an appropriate reception facility in a port. In doing so, the shipping companies must also consider the applicable national and local provisions regarding garbage disposal.

Further information on the restrictions for the discharging of garbage into the sea in accordance with MARPOL Annex V are given on the website of the Federal Maritime and Hydrographic Agency (BSH).

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Directive (EU) 2019/883 on port reception facilities for the delivery of waste from ships

The new Directive (EU) 2019/883 on port reception facilities for the delivery of waste from ships (PRF Directive) replaces the previous Directive 2000/59/EC as from 28 June 2021.

The Directive applies to all seagoing ships, irrespective of their flag, calling at, or operating within, a port of a Member State of the European Union. The Directive applies to all waste from ships including cargo residues, which are covered by Annexes I, II, IV, V and VI to the MARPOL Convention, and has to be implemented as from 28 June 2021. The technical implementation of some components will, however, be carried out progressively.

The port states must ensure the availability of adequate port reception facilities and make the relevant information publicly available and easily accessible to the ship operators.

The ships are obliged to deliver all waste before leaving the port, unless there is sufficient dedicated storage capacity for all waste that has been accumulated and will be accumulated during the intended voyage of the ship to the next port of call.

A waste delivery receipt is now issued on a mandatory basis to the ship for any waste disposal; this waste delivery receipt must be available on board for at least two years. Probably as from spring 2022, the information from the waste delivery receipt must be additionally reported via the relevant reporting window (National Single Window System - NSW) established for this port together with the existing reporting for the relevant port call.

Further information can be found in the ISM Circular 04/2021

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Reporting inadequate reception facilities

Waste generated on board ships - including inter alia sludge, sewage, general garbage - are either disposed of on board e.g. by incineration or discharged to a reception facility at a port. If German-flagged ships encounter difficulties to discharge ship-generated waste under MARPOL Annexes I-VI to port reception facilities, this format should be filled in and supplemented with appropriate details and information and sent to for review and follow-up.

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