Three areas of uncertainty exist concerning the implementation of the International Ballast Water Management (BWM) Convention:
- 35% Threshold Tonnage
- Entry Into Force Date
- D2 Standard Implementation Scheme
The total number of ratifying States is 47 (Only 30 States are needed for entry into force). However, the IMO GISIS website indicates that the percent tonnage of ratifying States (including Indonesia, Ghana and Morocco) based on 2014 data is 34.07%; 0.93% short of the 35% threshold.
BWM Convention shall enter into force twelve months after the date on which not less than thirty States, the combined merchant fleets of which constitute not less than thirty-five percent of the gross tonnage of the world‘s merchant shipping, have signed it. The latest ratification date of 24 November 2015 by Indonesia will be used as the date that conditions were fulfilled for entry into force.
The implementation scheme states that ships constructed on/after the entry into force date are to comply on delivery from the yard; and ships constructed before the entry into force date are to comply at their first MARPOL Annex I (IOPP) Renewal Survey carried out on/after entry into force.