What UAE Law Actually Says About In-Water Hull Cleaning and Antifouling
Published by Yacht IQ, Dubai Maritime City — part of the Silver Yachts group of companies. This article is technical guidance, not legal advice. Confirm requirements for your vessel and berth with the relevant authority before work begins.
Ask a Dubai contractor whether in-water hull cleaning is permitted and you will get a confident answer. Ask for the regulation it rests on and the conversation usually stops.
We went looking for that regulation. What we found is worth setting out honestly, because the gap between what people assume and what is actually published is wide — and one UAE port has written the clearest rulebook in the region while the emirate most yachts are based in has published nothing specific at all.
What the international framework requires
The AFS Convention governs what can be on your hull. It bans organotins — TBT — and, since the 2021 amendments, cybutryne. The dates matter. New builds delivered after 1 January 2023 must be cybutryne-free. Existing vessels must comply “by the next scheduled anti-fouling system renewal survey after 1st January 2023, but no later than 60 months following the last application”, with two routes: removal, or “a coating that forms a barrier to this substance leaching from the underlying noncompliant anti-fouling system” (ABS Regulatory News 01/2023; DNV). Re-application is absolutely prohibited.
One correction worth making, because it circulates constantly: Selektope (medetomidine) is not banned by the AFS Convention. Its regulatory risk sits with the EU Biocidal Products Regulation, where approval was extended “until 31 December 2026” pending a decision (I-Tech). Different instrument, different consequence.
Does it catch a private yacht? Yes, in tiers, and most owners are in the middle one:
| Vessel | Requirement |
|---|---|
| 400 GT and above | International Anti-fouling System Certificate, surveyed |
| 24 m or more, under 400 GT, international voyages | AFS Declaration plus documentary evidence |
| Under 24 m | No certificate or declaration, but must use approved systems |
The documentary evidence is specific and mundane: “a paint receipt, contractor's invoice or other evidence of the type of anti-fouling system used” (UK Merchant Shipping (Anti-Fouling Systems) Regulations 2024, reg. 8; confirmed by the Swedish Transport Agency). If you cannot produce a paint invoice for a 30 m yacht on an international voyage, you have a compliance gap regardless of what is on the hull.
On UAE accession: we could not verify it. The IMO's aggregate figures show 97 Contracting States covering 96.04% of world tonnage, but the per-state detail pages were not reachable. Treat UAE party status as unconfirmed. It changes less than you might think — the Convention's no-more-favourable-treatment provision means a Gulf-based yacht calling at any Party's port needs to be compliant anyway, and a UAE-flagged yacht cruising the Mediterranean is squarely in scope.
The cleaning guidance is separate and newer than most people realise. MEPC.1/Circ.918 is dated 29 April 2025, not 2020 — worth correcting if you have an older reference. It distinguishes proactive cleaning (removing microfouling periodically to prevent macrofouling attachment) from reactive cleaning, and sets a capture standard: systems should “only release captured particles, including organisms, that are less than 10 µm in all dimensions.” Critically, it states that “cleaning without capture should only be performed if allowed by local regulations”, and that “the service provider should request the necessary approval and/or permits from the relevant authority” (IMO). It is recommendatory, not binding. The broader biofouling framework is MEPC.378(80), adopted 7 July 2023.
That “if allowed by local regulations” clause is where this article really begins.
What UAE federal law says — and does not
Federal Law No. 24 of 1999 is the governing environmental instrument. Article 21 prohibits marine transport from “discharging or disposing of oil or oil mixture into the marine environment”; Article 27 prohibits discharge of “harmful substances or wastes, directly or indirectly.” Penalties under Article 73 run AED 150,000 to 1,000,000 (official text).
The law does not mention hull cleaning, antifouling, paint scraping or ship maintenance. Not once.
Whether scraped biofouling and paint particles constitute “harmful substances or wastes” discharged “indirectly” is an interpretive question, and we are not going to answer it for you. What we will say is that an operator relying on the absence of a specific rule is relying on an interpretation, not on permission.
Dubai: the institutions changed twice, and neither has published a circular
Get this right, because outdated references are everywhere.
The Dubai Maritime City Authority no longer exists under that name. Law No. (3) of 2023 replaced it with the Dubai Maritime Authority. The DMA is required to “protect the marine environment by verifying compliance by Vessels with the technical environmental standards” (Art. 6(8)) and may “issue all types of approvals and permits required for the work of companies and corporations operating in the Maritime Sector” (Art. 6(6)) (Law No. 3 of 2023). The law contains no hull-cleaning or antifouling provision.
The Dubai Environment and Climate Change Authority was then created by Law No. (11) of 2024, with power to “regulate and license maritime and coastal projects with environmental impact” (Art. 6(21)) and to issue “permits, approvals, and no-objection certificates” (Art. 6(23)) (Law No. 11 of 2024).
So Dubai now has a body with clear authority to regulate in-water cleaning. As far as we can establish, it has not yet used it. We found no DMA, DECCA, Federal Transport Authority or MOCCAE circular specifically governing in-water hull cleaning or antifouling selection. If one exists, it is not published where a diligent operator would find it.
Be careful with the secondary sources here. Commercial aggregators state that “major UAE ports, including Fujairah and Dubai, have established operational requirements for hull cleaning” and that Abu Dhabi requires wash water “free from pollutants” — but neither cites a circular. Do not treat those as authority.
Fujairah has written the rulebook
One UAE port has published a real, detailed instrument, and it is the most useful document in this entire subject: the Port of Fujairah's Hull Cleaning — Guidelines and Requirements, Attachment 27 to NTM 148 v6 (official PDF).
What it actually requires:
- Above-waterline cleaning is permitted — “The Port of Fujairah allows registered diving companies to perform hull cleaning above the waterline.” This was a change: the previous ban was lifted on 4 May 2023.
- A hard pressure limit — “The maximum allowed High-pressure (HP) washing is 200 bar pressures.”
- Location restriction — “Hull cleaning is not allowed inside the Port or in the Service harbour.”
- Coating protection — methods that “could damage the hull or anti-fouling coating” are prohibited.
- Paperwork — Attachment 27 plus a method statement and risk assessment, submitted 48 hours in advance, by a Port-registered company.
- The environmental clause — “Ship cleaning methods must be adopted to ensure that viable biofouling organisms or chemical and physical pollutants are not released into the local aquatic environment.”
- Strict scope separation — oil spill response companies handle oil stains only and “are not allowed to clean marine growth and fouling”; diving companies must not do oil stains.
Note how those last two clauses interact, because it is commercially useful. A capture-equipped soft-groom regime satisfies both the environmental clause and the coating-protection clause. Aggressive scrubbing of a self-polishing film may satisfy the first while breaching the second.
For contrast: what regulation looks like when it exists
Australia and New Zealand's joint guidelines are the best-drafted comparison. They permit microfouling removal “without the need for full containment”, require that internationally-derived macrofouling “only be removed using cleaning methods that minimise release of all organisms”, set a capture target of 50 µm, and add a rule almost nobody else does: “in-water cleaning should not be performed on vessels or movable structures that have reached or exceeded their planned in-service period” (guidelines).
Set that 50 µm against MEPC.1/Circ.918's 10 µm in 2025 and you can see the standard tightening over a decade. Whatever the UAE eventually publishes is likelier to look like the 10 µm figure than the 50.
Regionally, the UAE sits within the ROPME / Kuwait Regional Convention framework, whose four protocols cover emergencies, the continental shelf, land-based sources and hazardous wastes (MEMAC). None addresses in-water hull cleaning.
What to actually do
Carry the paperwork. For a 24 m+ yacht under 400 GT on international voyages, an AFS Declaration plus the paint invoice. Above 400 GT, the IAFS Certificate. This is the one unambiguous obligation in the article.
Assume capture is expected even where it is not mandated. The direction of travel is one way. A contractor who cannot capture debris is a contractor who will be non-compliant within a few years.
Ask your contractor which instrument they work to. In Fujairah the answer should be Attachment 27 to NTM 148. Elsewhere in the UAE, a good contractor will cite MEPC.1/Circ.918 and their own method statement. A contractor who cannot name anything is telling you something.
Get permission in writing from the marina or port, per berth. The absence of a published federal rule does not mean the absence of a local condition of berth.
Protect the coating as well as the water. A grooming regime matched to your antifouling type — see our guide to choosing antifouling for Gulf conditions — costs less over a coating's life than an aggressive clean that shortens it.
Where this article will date. DECCA has the power and has not yet exercised it. If Dubai publishes a hull-cleaning circular, this piece needs rewriting. We will update it when that happens.
Contact Yacht IQ about hull cleaning compliance for your vessel or berth.
If you need clarity for a specific vessel or berth, get in touch and we will point you to the right authority and the right documentation, rather than guessing on your behalf.
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