Ocean Insight September 2026
Selected matters
This publication by BAHR’s Ocean group provides a monthly update on selected developments in the maritime sector from a Norwegian legal point of view.
Sanction Updates US codifies and expands Russia sanctions regime On 18 September 2026, the US enacted a new sanctions law aimed at increasing economic pressure on Russia and parties supporting Russian energy exports. The legislation – formally titled the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 – strengthens the existing US sanctions regime and introduces additional measures targeting energy trade and sanctions evasion. Despite its name, the Act is primarily focused on Russia, while its Iran-related provision only extends the existing Iran Sanctions Act to 2031. Specifically, the Act requires the US authorities to review relevant persons and vessels by 18 October 2026, and every 180 days thereafter. The measures target, among others, foreign vessels knowingly transporting specified Russian-origin energy products, vessels used to circumvent sanctions or engaging in certain ship-to-ship transfers with sanctioned vessels, as well as certain owners, operators, managers, insurers and foreign port operators supporting such vessels. However, the US authorities retain broad discretion in determining whether the statutory criteria are met in any given case. While several of these activities were already targeted under existing US sanctions, the Act now places the relevant categories and recurring review requirements directly in legislation, effectively requiring the US authorities to regularly refresh sanctions designations as new vessels and entities become involved in Russian energy trade and sanctions evasion. The legislation also introduces significant trade measures, including tariffs of up to 500% on Russian-origin imports and up to 100% on goods from certain major purchasers of Russian crude oil or natural gas, or countries identified as major facilitators of Russian oil sanctions evasion. Key takeaway: The shadow-fleet measures are now codified in statute, and designations must be refreshed every 180 days by the US authorities. Owners, managers, insurers and ports should expect a steady flow of new vessel designations from 18 October 2026. Check that sanctions clauses and screening routines capture newly listed vessels. Read more
Russia expands sanctioned fleet under own flag Russia has reportedly sharply expanded the number of vessels registered under its own flag as enforcement against stateless and false-flagged shadow-fleet vessels intensifies. A significant share of the newly registered tonnage is already subject to Western sanctions. The development illustrates how the shadow fleet is adapting to enforcement pressure. By moving vessels into the Russian register, Russia gives them a recognised flag state and brings them under Russian flag-state jurisdiction on the high seas, potentially making certain enforcement measures more difficult than against flagless vessels. Key takeaway: Russian flagging of shadow-fleet vessels does not remove existing sanctions, but may make enforcement at sea against shadow-fleet vessels more challenging. Read more
Regulatory US-China trade truce extended to January 2027; port fee extension pending In 2025, the US introduced new port fees targeting certain Chinese-owned, operated and built vessels calling at US ports. China subsequently introduced its own port fees on certain US-linked vessels. However, as part of a wider trade and economic agreement between the US and China, both sides agreed to suspend the measures from November 2025, until November 2026. On 23 September, US officials stated that US and China had agreed to extend their existing trade truce from November 2026 to 10 January 2027, giving the parties additional time to negotiate a broader economic agreement. As the port fee suspension formed part of the original US-China agreement, it is expected that the reciprocal port fees may also remain suspended until 10 January 2027. However, this has not been officially confirmed, and no formal announcement extending the port fee suspension has yet been issued by the US or Chinese government. Key takeaway: Owners and charterers potentially subject to the US or Chinese port fees should monitor whether the suspension is formally extended and ensure that any resulting costs are appropriately allocated in their contracts. Read more: Reported extension of US-China trade truce | BIMCO: Port fee uncertainty
IMO Net-Zero Framework negotiations remain deadlocked The IMO continues to negotiate its proposed Net-Zero Framework, which is intended to introduce global greenhouse-gas fuel intensity requirements for international shipping together with an economic compliance mechanism. The framework was approved in 2025, but its formal adoption was postponed following strong opposition from several member states. At the latest IMO working group meeting in September, significant differences remained over several core issues, including the level and pace of the fuel-intensity requirements, whether the framework should use a one- or two-tier compliance structure, and whether payments generated under the regime should be channelled through a central IMO fund. BIMCO also notes that there may no longer be universal agreement on the ambition and interim targets set out in the IMO's 2023 GHG Strategy, and considers convergence by December this year to be challenging. The final outcome of the Net-Zero Framework may materially affect the relative cost and availability of different marine fuels, as well as newbuild, retrofit and long-term fleet investment decisions. At the same time, the absence of a common global framework increases the risk of regional or national measures developing in parallel, potentially creating a fragmented regulatory landscape for internationally trading vessels. The longer it takes to reach agreement at IMO level, the greater the risk of overlapping requirements, increased compliance complexity and uncertainty over future regulatory costs. Key takeaway: The IMO Net-Zero Framework remains unresolved, increasing uncertainty around long-term fuel and fleet decisions and the risk of further regulatory fragmentation. Read more
Industry and contract standards BIMCO updates: electronic bills of lading and ship recycling September saw notable developments in both the digitalisation of shipping documentation and the availability of compliant ship-recycling facilities. - BIMCO proposes revised Electronic Bills of Lading Clause BIMCO circulated the first draft of a revised Electronic Bills of Lading Clause in September. The draft addresses the selection of electronic systems, interoperability, fees and liabilities, P&I cover requirements, including International Group approval, and interaction with other charterparty provisions dealing with bills of lading and cargo delivery.
The work reflects the growing use of electronic trade documentation and the need to align contractual wording with platform requirements and operational practice. Owners, charterers, traders and P&I interests moving from paper documents should therefore review the legal clause, system compatibility and claims-handling workflow together rather than treating eBL implementation as a purely technical exercise. - Industry backs adding Indian yards to EU recycling list Major shipping organisations welcomed the European Commission’s proposal to add two Indian ship-recycling facilities to the European List of Ship Recycling Facilities. The industry considers the proposal an important step towards increasing compliant recycling capacity, particularly as a growing number of vessels are expected to reach the end of their operational lives over the coming decade. Approval of Indian yards could broaden the range of recycling options available to European owners and may affect yard selection, pricing and end-of-life planning. Key takeaway: The September developments may require owners and charterers to revisit both contractual arrangements for electronic trade documentation and longerterm planning for compliant ship recycling. Read more: eBL Clause | Ship recycling
Other LNG bunker fleet may need to more than double by 2030 DNV estimates that the global LNG bunker-vessel fleet may need to more than double by 2030, with between 165 and 208 vessels potentially required as demand from LNG-fuelled ships grows faster than the infrastructure needed to supply them. The potential capacity gap is relevant not only to bunker operators and ports, but also to owners considering LNG-fuelled newbuilds and long-term fuel strategies. Insufficient bunkering capacity could constrain fuel availability, increase costs and reduce operational flexibility in certain markets. DNV also highlights the need for coordinated investment across the wider bunkering ecosystem, including safety management, competence and operational readiness as bunkering operations become more frequent and geographically widespread. Key takeaway: LNG-fuelled fleet growth may outpace bunkering capacity, making long-term fuel availability and infrastructure an increasingly important consideration in vessel investment decisions. Read more
Security risks increasingly linked across regions BIMCO’s September Maritime Security Symposium highlighted how risks in the Black Sea, Red Sea, Strait of Hormuz and organised maritime crime are increasingly connected. The central message was that developments in one region can quickly affect routing, commercial decisions and risk assessments elsewhere. The finding supports a dynamic approach to war-risk assessments, voyage planning, charterparty provisions, insurance arrangements and security protocols, with reliable links to government, military and law-enforcement information sources. Key takeaway: Maritime security risks should increasingly be assessed across regions rather than in isolation, with contractual and operational arrangements capable of responding to rapid shifts in routing, insurance and threat conditions. Read more
Should you have any questions related to the above, please do not hesitate to contact Henrik Aadnesen (Head of BAHR’s Ocean Group), Sondre Vegheim (editor) or Even Torvanger (editor).
Henrik Aadnesen
Sondre Vegheim
Even Torvanger
haa@bahr.no
soveg@bahr.no
evtor@bahr.no
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