India Implements New Pre-Arrival Notification of Security (PANS) Procedure for Ships Entering Indian Ports

New Circular Consolidates Guidelines to Streamline Compliance for International and Domestic Vessels

Mumbai, September 12, 2024 — In a significant move aimed at bolstering maritime security while enhancing the ease of doing business, the Directorate General of Shipping, India, has released a consolidated circular on the Pre-Arrival Notification of Security (PANS) procedure for vessels entering Indian port facilities. This update aligns with India’s commitment to international maritime security standards, following the International Ship and Port Facility Security (ISPS) Code established under the International Convention for the Safety of Life at Sea (SOLAS), 1974.

The ISPS Code, which has been in force since July 1, 2004, provides a comprehensive framework for maritime and port security worldwide, mandating contracting governments to enforce specific security protocols on ships entering their jurisdictions. India, having ratified the SOLAS Convention and its amendments, is reinforcing these measures through updated procedural requirements under its Merchant Shipping (Ships and Port Facility Security) Rules, 2024.

Key Requirements and Compliance

Under the new circular, all vessels on international voyages, as well as those operating in coastal waters or between Indian ports, must submit a Pre-Arrival Notification of Security (PANS) 96 hours prior to arriving at any Indian port facility. This requirement is mandatory for the following types of vessels:

• Passenger ships, including high-speed passenger crafts
• Cargo ships, including high-speed crafts of 500 GT and above
• Mobile offshore drilling units
• Pleasure yachts
• Sailing vessels

These vessels or their designated Ship Masters, Owners, Managers, Operators, or Agents are required to provide the necessary information as outlined in Annexure I (for passenger ships, cargo ships, and drilling units) and Annexure II (for yachts) to both the relevant regional authorities and the Port Facility Security Officer of the port of call.

Simplification and Consolidation of Previous Circulars

The new guidelines consolidate various earlier circulars, including those issued in 2005, 2009, 2011, and 2020. This effort is part of the government’s broader policy to simplify regulatory procedures and reduce bureaucratic hurdles, thereby promoting ease of doing business in India.

“By consolidating and updating the guidelines, the government aims to streamline compliance processes, making it easier for ships to adhere to security requirements while ensuring that India’s port facilities remain secure and efficient,” stated an official from the Directorate General of Shipping.

Impacts on Logistics, Trade, and Security

The updated PANS procedure is expected to have significant implications for the logistics and trade sectors. While the new requirements enhance security, they also place additional compliance burdens on shipping companies, which could impact operational efficiencies and scheduling.

According to Nagmani Pandey, a Senior Journalist specializing in maritime trade, “The tightening of security protocols is essential in today’s geopolitical climate. However, the industry must balance these security needs with the operational realities of global trade. These regulations, while necessary, may increase the operational costs and complexity for logistics providers.”

He further, added, “Enhanced security measures are not just about safeguarding assets but also about protecting our marine ecosystems from illicit activities like illegal fishing and unauthorized dumping.”

Potential Challenges for Stakeholders

While the updated circular aims to streamline compliance, stakeholders have raised concerns about potential delays and increased administrative burdens, especially for smaller operators such as pleasure yachts and sailing vessels.

Aziz Rajkotwala, a Sustainable and Marine Environmental Analyst, highlighted, “The 96-hour pre-arrival notification window is designed to give authorities ample time to assess security risks. However, the industry will need to adjust to these timelines, which could affect just-in-time shipping models and increase congestion at ports.”

Future Implications and Global Alignment

India’s move to update and consolidate its maritime security requirements reflects broader global trends towards tighter regulation of maritime and port security. The enhanced focus on compliance and security aligns India with other major maritime nations, reinforcing its role as a key player in international shipping.

As new regulatory challenges emerge, the Indian government’s proactive approach in updating its maritime security framework will likely be viewed as a positive step towards safeguarding both national interests and the global maritime community.

With the implementation of these measures, India reiterates its commitment to secure its port facilities against evolving threats, ensuring that its maritime gateways remain safe, efficient, and conducive to global trade.

To read the complete circular CLICK HERE