US - EPA Reminder of VGP Requirements


The Club would like to draw Members’ attention to Enforcement Alert #310F22002 issued by the US Environmental Protection Agency (EPA) in January 2023. The Alert is a reminder to vessel owners and vessel operators to comply with the Clean Water Act (CWA) 2013 Vessel General Permit (VGP) requirements when operating in US waters. The VGP requirements apply to 'commercial vessels', defined widely to include all usual commercial vessels, offshore support and supply vessels, mobile offshore drilling units, emergency response vessels and other vessels operating ‘in a capacity as a means of transportation’.

On 4 December 2018, the Vessel Incidental Discharge Act (VIDA) was enacted into law. VIDA brought the USCG’s type-approval methodology for ballast water treatment systems (BWTS) into line with that of the IMO (see EPA proposing vessel discharge standards under VIDA ( and extended the validity of VGP 2013 beyond 18 December 2018. VIDA charged the EPA with the task of establishing new regulations addressing VIDA requirements, and the USCG with the task of enforcing VGP 2013 until such new regulations are in place. Most vessels operating in or to US waters are expected to be fitted with a USCG type approved BWTS.

In their Enforcement Alert, the EPA draws attention to the adverse impacts on human health and the environment when VGP requirements are not complied with. The EPA also provides examples of three recent EPA VGP enforcement cases where large penalties were imposed for VGP violations.

The EPA’s Enforcement Alert #310F22002 and the Final 2013 VGP and its requirements may be downloaded below. If Members have yet to do so, they are also reminded to update their records to incorporate the new phone number for the EPA’s Help Desk effective 23 January 2023: 1-866-498-2945.

If Members have any questions on the above article, your usual contact at the Club will be pleased to assist you.

  • EPA Enforcement Alert #310F22002 dated January 2023 560 KB


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  • Final 2013 VGP 1 MB


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Jacqueline Tan

Legal Services Manager