In the ninth year since enforcement of the Ballast Water Management Convention (BWMC) the latest Concentrated Inspection Campaign (CIC) on ballast water treatment systems makes depressing reading.

The CIC report followed a three-month survey, ending 30 November 2025, into the actual performance, operation and maintenance of installed ballast water treatment systems and was published in February this year.

Deficiencies found by the survey revealed that operational failures of BWTS were failures of the technology itself, in 46% of detainable deficiencies, while crew training deficiencies resulted in 21% problems and the vessel’s Ballast Water Management Plan was deficient in 15% of surveyed ships.

A year earlier, a Paris Memorandum of Understanding report on Port State Control recorded similar failures, including poor ballast water record keeping, inadequate crew training, system unfamiliarity, and invalid or missing certificates.

These failures have led to the development of land-based reception facilities (LBRF) that have been commissioned mainly in Europe, with the Denmark-based Bawat offering a simple solution for vessels arriving in port with untreated ballast.

Bawat’s mobile BWTS system, operated from a 40ft container, help ships that cannot carry on loading operations without first managing the ballast water in their tanks. Bawat’s system effectively pasteurises ballast water, heating and cooling it to render it clear of live invasive species.

LBRF technology is one way of dealing with failed BWTS, but Charlène Ceresola, BWT project manager and regulatory expert at BIO-UV Group, noted: “Once you focus specifically on deficiencies serious enough to result in a ship being detained, the majority are associated with the ballast water treatment system itself.”

Dubai’s Drydocks World shared this view, telling The Naval Architect: “Between 2021 and 2024, yard capacity was the dominant constraint.”

Today Port State Control has shifted its emphasis in Europe, the Gulf and Asia to demonstrable compliance with D-2 discharge standards, operational testing and sampling, calibration and maintenance documentation and crew familiarity with system procedures, taking on more importance said Drydocks World.

“This enforcement shift exposed a structural issue: systems compliant on paper may not perform optimally in varied salinity and sediment conditions if integration, commissioning or maintenance has been insufficient. The real test now is whether these installed systems consistently function,” added the yard.

Drydocks World worked on 12 BWTS in 2025, two of which ended this year, in total the yard has completed more than 300 retrofits of ballast systems on tankers, gas carriers and container ships, among other vessel types. According to the yard there has been a transition from installation to “performance-led engagement”.

The reasons behind that are precisely as the CIC report suggests, many systems are not operating as they should, while some manufacturers have discontinued production of their BWTS in a highly competitive market, leaving owners without spare parts.

“While the majority of vessels are operating effectively, the post-deadline environment is revealing a second wave of activity. In addition to new installations, yards are also supporting system recalibration and optimisations, repairs and modifications as well as the removal and complete replacement of underperforming systems,” explained Drydocks World.

The industry trend is to make repair yards a strategic partner, and that requires the yards to offer integrated design prefabrication planning to protect yard schedules, and, additionally, collaboration on upgrades, removals of legacy systems and what Drydocks World calls long-term performance economics.

“Technical integration capability, constructability foresight and lifecycle support are no longer differentiators at the margin, they are prerequisites for sustained compliance,” the yard claims, and it says they are well positioned to meet industry needs with a vast team of 400 engineers.

However, the yard concludes: “Ballast water management has moved beyond the question of whether systems are fitted. The decisive question now is whether they perform consistently, predictably and under scrutiny.”

Since the approval of the Ballast Water Management Convention by the IMO in 2004, the regulation has been fraught with industry concerns, with the US having more stringent regulations than the IMO. That made BWTS approvals far more complicated. Member state ratification was slow, taking 13 years, with final ratification and enforcement delayed until September 2017.

Since the Convention entered into the full enforcement phase, the industry has been confronted by a new and more complex reality, that has changed the way yards, particularly larger repair yard, approach BWTS repairs and replacements.

“In the enforcement era, engineering discipline is no longer procedural, it is commercial infrastructure, shaping both fleet reliability and the competitive position of yards equipped to deliver it,” said Drydocks World.