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STANDARDS · IMO

AFS Convention: the international rules on antifouling paint

UPDATED 12 NOVEMBER 2026 · 3 SOURCES

What the AFS Convention and EU Regulation 782/2003 ban in antifouling paint, TBT and cybutryne, which yachts need an AFS certificate or declaration.

AT A GLANCE
AFS Convention
OFFICIAL TITLE
International Convention on the Control of Harmful Anti-fouling Systems on Ships (AFS), applied in the EU by Regulation (EC) No 782/2003
COVERS
A ban on organotin biocides such as TBT in antifouling paint on all ships, and controls on cybutryne. A certificate from 400 GT, a declaration from 24 m
SURVEYORS CHECK
What's on the hull and when it was applied, from the yard's paint records, and the AFS certificate or declaration on larger yachts
GET THE TEXT
IMO's summary page; the EU regulation on EUR-Lex and legislation.gov.uk

The AFS Convention is the International Maritime Organization's treaty on antifouling paint. It bans harmful organotins, tributyltin (TBT) above all, and sets up a way to control other harmful substances, which is how cybutryne was added. In the EU, Regulation (EC) No 782/2003 put the organotin rules into law for EU-flagged ships and ships calling at EU ports.

What it bans

IMO's summary is direct: all ships shall not apply or re-apply organotin compounds that act as biocides in antifouling systems. The convention covers ships flying a party's flag, ships operating under its authority, and all ships entering its ports, shipyards or offshore terminals.

The EU regulation says the same in two steps:

  • Article 4: organotin compounds acting as biocides "shall not be applied or re-applied on ships".
  • Article 5: ships may not bear them on their hulls or external surfaces, unless they bear a coating that forms a barrier to stop the old paint leaching.

Cybutryne

A later amendment to the convention controls cybutryne, a biocide used in some paints. IMO says ships must remove a cybutryne coating, or apply a coating over it, at the next scheduled renewal of the antifouling system, and no later than 60 months after it was last applied.

Certificates and declarations

Article 6 of the EU regulation sets the paperwork by size:

Ship Requirement
400 gross tonnage and above Surveyed and certified, before first entering service and when the antifouling system is changed
24 m or more, under 400 GT Carries an AFS declaration showing compliance
Under 24 m No specific survey or declaration; member states may set their own measures

The regulation's recitals explain the last row: boats under 24 m are mainly recreational craft and fishing vessels, already covered by EU rules on marketing antifouling products.

In the UK, Regulation 782/2003 was revoked and replaced by the Merchant Shipping (Anti-Fouling Systems) Regulations, SI 2024/509.

For surveyors

On most yachts under 24 m there's no AFS paperwork to see. What matters is what's on the hull: old hard paint built up in layers, flaking or blistering, and whether the yard's records show the product and when it went on. On a larger yacht, ask for the AFS declaration or certificate and check it against the yard's record of the last antifouling. See bottom paint for boats for paint types, and the out-of-water survey for the rest of the hull inspection.

Frequently asked

What does the AFS Convention ban?

Harmful organotins, such as TBT, in antifouling paint. IMO says no ship may apply or re-apply organotin compounds acting as biocides, and the convention was later amended to control the biocide cybutryne.

Does the AFS Convention apply to small yachts?

The ban on organotins applies to all ships. The paperwork depends on size: under EU Regulation 782/2003, ships of 400 GT and above are surveyed and certified, and ships of 24 m or more but under 400 GT carry an AFS declaration. Member states may set measures for smaller boats.

What happens to an existing cybutryne coating?

IMO says ships must remove it, or apply a coating over it, at the next scheduled renewal of the antifouling system, and no later than 60 months after it was last applied.

Can old TBT paint stay on the hull?

Under Article 5 of the EU regulation, a ship may not bear organotin antifouling unless it's covered by a coating that forms a barrier to stop it leaching out.

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