Compliance Requirements Under NORMAM-401 (Effective 2025–2026)
In June 2025, the Directorate of Ports and Coasts (DPC) of the Brazilian Navy issued Ordinance DPC/DGN/MB No. 180/25 approving the first revision of the Maritime Authority Standards for the Prevention of Environmental Pollution Caused by Vessels and Platforms (NORMAM-401).
The revised regulation introduces Chapter 4, establishing a comprehensive framework for biofouling management aligned with the International Maritime Organization Biofouling Guidelines (Resolution MEPC.378(80)).
Applicability
Under NORMAM-401, all vessels exceeding 24 meters in length intending to enter Brazilian Jurisdictional Waters (AJB) must:
✔ Maintain a Biofouling Management Plan
✔ Maintain a Biofouling Record Book
✔ Ensure hull condition does not exceed Biofouling Level 1 (microfouling) upon entry into AJB
Minimum plan and record book contents are specified in Annex H of NORMAM-401.
Biofouling Control & Cleaning Requirements
Where Biofouling Level 2 or above is identified, recommended actions include:
- Cleaning with capture of residues
- Increased inspection frequency
- Dry-docking if antifouling coating deterioration is observed
⚠ Important:
Vessels intending to conduct in-water cleaning must obtain prior authorization from the competent Maritime Authority agent — preferably at least 10 days in advance.
The biofouling level scale and cleaning standards are detailed in Annex J.
Coastal Bioregions & Operational Considerations
Annex I divides the Brazilian coastline into three marine biogeographical regions:
- North
- Northeast
- South/Southeast
Vessels navigating between these regions must ensure continued compliance with biofouling control requirements.
Enforcement Timeline
As per Ordinance DPC/DGN/MB No. 193/25 (18 December 2025):
- Penalties become effective from 10 June 2026
- Non-compliance may result in:
- Warnings
- Fines
- Operational restrictions
Enforcement procedures will follow Law No. 9,605/1998 and NORMAM-401.
However, the requirement for prior authorization for in-water cleaning has been effective since June 2025.
Recommended Actions for Shipowners & Operators
Maritime Sutra Consultancy Services strongly recommends:
✔ Immediate review and update of Biofouling Management Plans
✔ Ensure Biofouling Record Books are complete and current
✔ Conduct inspections to maintain fouling at or below Level 1
✔ Coordinate early with local Brazilian agents
✔ Maintain full supporting documentation onboard
Need Assistance?
Maritime Sutra Consultancy Services provides:
- Biofouling Management Plan development
- Record Book structuring
- Compliance gap analysis
- Technical advisory for Brazilian operations
- Pre-arrival compliance audits
📧 info@maritimesutra.com
📞 +91 8340494654