Amendments to NOx Technical Code 2008 (in force on 1 Sep 2026)

C26039| 25 August 2026

Notice to: Ship Owners / Managers / Operators / Surveyors / Auditors

This is to inform of amendments to NOx Technical Code 2008, adopted by IMO Res. MEPC.398(83) on 11 Apr 2025 and coming in force on 1 Sep 2026. The amendments refer to certification of an engine subject to substantial modification or being certified to a Tier to which the engine was not certified at the time of its installation.

Meaning of Substantial Modification

A substantial modification means any change or alteration to a marine diesel engine that could potentially cause the engine to exceed the applicable NOx emission limits defined in Regulation 13 of MARPOL Annex VI.

Examples of substantial modification could be:

Change of key technical parameters or core components such as camshafts, fuel injection systems, air systems, combustion chamber configurations, or timing calibrations;
Upgrade or alteration of parts listed in the engine’s official NOx Technical File with unverified or non-OEM parts that change combustion or emission characteristics.

What is not a substantial modification:

Normal / routine maintenance and replacement of parts specified in the NOx Technical File of an engine;
Installation of a certified “Approved Method” designated for pre-2000 engines under MARPOL Annex VI, Regulation 13.7.

Key points to know as per the Amendments

The amendments refer to an Individual Engine or an Engine Group represented by the Parent Engine. They shall not be accepted for Engine Family certification;
Where, as a result of a substantial modification, the rated power and/or the rated speed of the engine is altered from the original condition, the engine nameplate shall be replaced accordingly;
In setting the load points of the test cycle, load points with 100% load point no lower than 85% of rated power are allowed;
The Administration agreement on Engine Emission test plan is required before scheduling;
A new Figure 4, flowchart guidance on the certification process has been added as Appendix II of the Code.

Act now

Ship Owners / Managers / Operators should take note of the circular and seek Dromon Head Office advice in case an engine is going to be subject to a substantial modification or to be certified to a Tier to which the engine was not certified at the time of its installation.

Surveyors will receive special instructions from Dromon Head Office in case they are requested to inspect / certify such engines.

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