In-water hull cleaning in Brazil (NORMAM-401)

Last reviewed 21 October 2026

Yes, you need permission. Since 17 June 2025, reactive in-water cleaning of a ship's hull and niche areas in Brazilian jurisdictional waters requires prior authorization from the local Maritime Authority office: the Capitania dos Portos (Harbour Master's Office), or the Delegacia or Agência that covers the port. The request must include a risk assessment and a description of the cleaning method. Removed material should be captured, and cleaning without capture is an exception that has to be justified. These rules are in chapter 4 of NORMAM-401/DPC, the Brazilian Navy standard on biofouling management. This guide explains what the rule covers, how it relates to the IMO guidance, and how to fit a cleaning into a port call without delaying the ship.

This guide summarizes public rules as of October 2026. It is not legal advice. Check the current text of NORMAM-401/DPC and confirm the procedure with the local Capitania dos Portos before planning an operation.

What NORMAM-401 chapter 4 covers

The Directorate of Ports and Coasts (DPC) added a chapter on biofouling management to NORMAM-401/DPC in June 2025. According to legal summaries of the text, the main points are:

Scope. Vessels over 24 m in length operating in Brazilian jurisdictional waters, including ships at anchor or laid up. Offshore oil and gas platforms and support vessels already covered by environmental licensing conditions follow those conditions instead of the ordinary chapter 4 regime.
Biofouling Management Plan and Biofouling Record Book. Ships must keep both on board. The record book logs inspections, cleanings and related maintenance, and records must be available to the Maritime Authority on request.
Reactive in-water cleaning needs authorization. This has applied since 17 June 2025.
Capture is the default. Removed residue must be captured and disposed of in line with environmental rules.
Biogeographic regions. Brazil's coast is divided into marine biogeographic regions. Ships moving between them are expected to keep biofouling below set limits. Where cleaning could not be done before arrival, legal commentary on the 2026 revision says it may be done at the first call, as an exception, on a reasoned request and with prior authorization.

Enforcement timeline. The penalty start date has been moved more than once. Commentary on the 2025 text gave February 2026. Commentary on the 2026 revision says sanctions under chapter 4 now apply from 10 January 2028, and that until then the Maritime Authority will act mainly in an advisory role. The obligations themselves already apply, and terminals, charterers and vetting teams may ask for biofouling documents before 2028. Confirm the current dates in the official text.

Hull cleaning in Brazil is a Maritime Authority matter. We found no specific ANTAQ (waterway transport regulator) or IBAMA (federal environmental agency) resolution on in-water hull cleaning, although local environmental and port rules may still apply to waste disposal and operations at the berth.

Reactive and proactive cleaning

NORMAM-401 defines both terms, and the IMO guidance uses the same distinction:

Type	What it removes	Authorization in Brazil
Proactive cleaning	Microfouling (slime), removed periodically to prevent macrofouling from attaching	Not covered by the summaries we reviewed. Confirm with the Capitania
Reactive cleaning	Micro- and macrofouling, as a corrective action	Prior authorization required since 17 June 2025

In practice, most commercial requests for a ship that has been idle or trading in warm waters are reactive. If you are unsure which category applies, assume authorization is needed and ask the Capitania early.

How the Brazilian rule relates to IMO guidance

The 2023 Guidelines for the control and management of ships' biofouling (resolution MEPC.378(80)) set out the Biofouling Management Plan and Record Book concepts that NORMAM-401 now makes mandatory in Brazil. In April 2025, at its 83rd session, the Marine Environment Protection Committee approved MEPC.1/Circ.918, Guidance on in-water cleaning of ships' biofouling. Several points in that guidance match the Brazilian rule:

Cleaning with capture can be used for proactive and reactive cleaning. Cleaning without capture should be limited to areas with a fouling rating below 2, unless local rules allow otherwise in an accepted location.
Where local rules require case-by-case approval, the service provider should request it. If the crew cleans with onboard equipment, the master, owner or local representative should request it.
The provider should give the ship a cleaning report. If cleaning stops early, the report should show where it started and stopped and why, so another provider can continue.
Inspection video and photos should be high definition (at least 1280 x 720 pixels), time- and date-stamped, and include ship markings such as draught marks.

MEPC.1/Circ.918 is guidance. NORMAM-401 is binding in Brazilian waters, so where they differ, the Brazilian text applies.

What the ship manager or agent should prepare

The Capitania's exact document list and lead time are not published in a form we could verify, so confirm them locally. Based on NORMAM-401 and the information MEPC.1/Circ.918 asks the ship to share, prepare the following:

Ship particulars: name, IMO number, flag, length, draught, and port and berth or anchorage with dates.
Biofouling Management Plan and recent Record Book entries.
Recent inspection, cleaning and dry-dock reports, including the antifouling coating type and age.
A pre-cleaning inspection (video and photos) to establish fouling rating and the areas to clean.
The areas to clean: flat bottom, vertical sides, niche areas, and any areas to avoid, such as damaged coating, anodes or sensors.
The provider's method statement and risk assessment, the capture system, and the plan for disposing of captured waste.
If cleaning without capture is proposed, the technical justification.
Other operations planned during the call, such as bunkering, cargo work, ballasting, repairs or shifting berth.

Planning the cleaning around the port call

Start early. Send the ship's details and the inspection footage as soon as the call is confirmed, so the authorization request is not the critical path.
Choose the location. Alongside or at anchorage affects currents, visibility, under-keel clearance and diver safety.
Coordinate with terminal operations. Cargo, crane movements and bunkering can restrict where and when divers or remotely operated cleaning units can work.
Secure the ship. Propeller, rudder, thrusters and sea-water intakes near the work area must be immobilized or isolated under the ship's permit-to-work and lockout procedures.
Agree on deliverables before mobilization. Agree on before-and-after video, a cleaning report, waste disposal records and a short summary for the Record Book.

Our team in Vitória can help prepare the inspection, method statement and documentation for the Capitania, and plan the work around your call.

Propeller polishing considerations

The propeller is a niche area. MEPC.1/Circ.918 notes that propellers usually need special equipment and procedures. Polishing removes fouling and surface roughness from the blades, and it is often done during the same call as a hull cleaning. Points to settle in advance:

Authorization. Whether polishing alone counts as reactive cleaning under NORMAM-401 is not stated in the summaries we reviewed. Ask the Capitania, and include polishing in the request if hull cleaning is planned too.
Shaft lock and permits. The shaft must be locked and the main engine and turning gear isolated before divers approach.
Blade condition. Note cavitation damage, bent tips or rope damage found during inspection. These may need repair rather than polishing.
Documentation. Before-and-after close-up images of each blade support the report and any performance analysis.

The IMO 2023 Guidelines recognise that good biofouling management helps a ship's hydrodynamic performance. Any fuel saving depends on the ship, its fouling condition and its operating profile, so measure it with your own performance data rather than relying on general figures.

In-water hull cleaning in Brazil: what NORMAM-401 requires