Anti-fouling systems for ships

Anti-fouling system refers to a coating, paint, surface treatment or device used on a ship to control or prevent attachment of unwanted organisms.

The regulation applies regardless of the size of the ship (or recreational craft) or its purpose. “Use” refers to application, change or replacement of the anti-fouling system. These regulations also apply to ships flying the flags of other EU member states.

As of 1 January 2008 there is a total ban on organotin compounds which act as biocides in anti-fouling systems on ships. This means that all ships registered within the EU or which call at EU ports, regardless of size or ships’ trade must have removed such anti-fouling systems. Alternatively, they may be covered with a sealer coat that prevents organotin compounds from leaching. The total ban applies to all ships calling at Swedish ports as well as ports within the European Community.

At the moment there are only organotin compounds which act as biocides in antifouling systems which are entirely prohibited in the EU. There are other substances in anti-fouling systems which act as biocides, but there are no current prohibitions. Other substances may be prohibited in future.

Inspection, certification and declaration

The regulations on anti-fouling systems make no distinction between recreational craft and ships used for commercial purposes with regard to inspection, certification and declarations on antifouling systems. The provisions are connected to the length or length and gross tonnage of the ship.

Ships less than 24 metres

Inspection and certification are not required for ships less than 24 metres, mainly recreational craft and fishing vessels. These ships must however use coatings or anti-fouling systems that are approved under current regulations.

The above is based on the EU Council Directive 76/769/EEC of 27 July 1976 on the approximation of the laws, regulations and administrative provisions of the Member States relating to restrictions on the marketing and use of certain dangerous substances and preparations which has been incorporated into the Swedish Chemicals Inspectorate’s regulations (KIFS 2008:3). The directive is applicable to ships less than 24 metres, mainly recreational craft and fishing vessels.

Ships of 24 metres or more in length but less than 400 gross tonnage

As from 1 July 2003, a declaration on anti-fouling system for ships of 24 metres or more in length, but less than 400 gross tonnage must be carried for ships of 24 metres or more in length but less than 400 gross tonnage as proof that the ship meets requirements on application and use of organotin compounds which act as biocides. The declaration must be filled out by the ship-owner and is available for download in the column to the right. The declaration must be accompanied by appropriate documentation e.g. a receipt for paints or coatings or the contractor’s invoice.

Ships with a gross tonnage of 400 or above

As from 1 July 2004, ships with a gross tonnage of 400 or above must be surveyed and have an International Anti-fouling System Certificate. Survey and certification are issued by the Swedish Transport Agency and by recognized organizations with which the Administration has formal agreements. A request for survey must contain the information about the ships stipulated in resolution MEPC.102(48), which is available for download from the column to the right. The Anti-fouling System Certificate ceases to be valid if the antifouling system is changed or replaced with another system and upon transfer of the ship to another flag or state.


Warships, naval auxiliary and other ships owned or operated by the Swedish State are exempted from current regulations on antifouling systems. Fixed or floating platforms, floating storage units (FSUs) and floating production, storage and offloading units (FPSOs) built before 1 July 2003 and which have not been in dry dock since that date are also exempted.

Transfer of ships to the Swedish flag

Ships which are transferred to Sweden from a register of ships in a non- EU country may retain prohibited anti-fouling systems (i.e., systems containing organotin compounds) applied before 1 July 2003 until the first dry dock, when an approved anti-fouling system must be applied. If the ship has applied a prohibited antifouling system after 1 July 2003, it must be removed or sealed before the ship can fly the Swedish flag.