During the extended delay period, the EPA is administratively continuing the current VGP (VGP 2.0), until VGP 3.0 enters into force. Namely:

  • Vessels which are currently covered by the existing VGP 2.0, specifically those vessels which have filed a Notice of Intent (NOI) prior to 18 December 2018, and have implemented VGP 2.0, are automatically covered by the administrative continuance with no additional follow-up action necessary.
  • Operators of new vessels, with keel laid prior to 18 December 2018, are required to file an NOI prior to 18 December 2018 in order to be covered by VGP 2.0.
  • If an operator of a vessel with keel laid prior to 18 December 2018 does not file an NOI with the EPA, that vessel will not be covered by the administratively continued VGP 2.0, and therefore may not discharge any discharges covered by the VGP 2.0 in US waters until it files a new NOI in accordance with the new VGP (VGP 3.0).
  • Vessels with keel laid after 18 December 2018 will be covered once the new VGP (VGP 3.0) is published in its final form and the vessel files the required NOI.
  • EPA has advised that a policy letter will be issued in the very near future addressing the above.

At the time of writing we hold no information about specific changes to the VGP requirements and potential consequences for the industry’s current compliance programmes. Members and clients with vessels calling at US ports are therefore advised to monitor the situation closely by consulting webpages maintained by the EPA as well as obtaining relevant advice from their local agents,

...Gard P&I Club advised in a statement.


The VGP provides for National Pollutant Discharge Elimination System (NPDES) permit coverage for incidental discharges into US waters from commercial vessels greater than 79 feet in length and for ballast water discharges from commercial vessels of all sizes.

The permit contains effluent limits for different types of discharges including ballast water, deck runoff, bilge water and grey water, as well requirements for the use of environmentally acceptable lubricants (EALs) in all oil-to-sea interfaces.

Each individual vessel in a fleet requires its own permit and the NOI requirements apply to vessels of 300 gross tons or more or vessels that have the ability to hold or discharge more than eight cubic meters of ballast water. Operators of smaller vessels and of vessels with less ballast water capacity must instead complete a PARI Form (Fill and Print) and keep a copy of that form onboard the vessel at all times.

For each vessel, operators must submit an Annual Report electronically for each year that they have active permit coverage.

EPA first issued the VGP in 2008 and subsequently reissued it in 2013. The current VGP 2.0 is effective from 19 December 2013 to 18 December 2018 and a general overview of the VGP, its requirements, as well as practical information on how to submit NOIs and Annual Reports, are available on EPA website.

The 194-page current edition of VGP  addresses reporting requirements for the discharges from vessels. Explore more by reading related article here