Arctic Voyage of the Containership Istanbul Bridge and the IMO Polar Code

The 2025 voyage of the Chinese-owned (Liberian flag), Panamax containership Istanbul Bridge was hailed by Sea Legend, the Chinese operator, state-owned newspapers, and many in the Western media as a game-changer for global maritime trade. Yet there remain many unanswered questions about this ship and its voyage through polar waters. There is no debate that the Istanbul Bridge operated along the Northeast Passage (NEP) and Northern Sea Route (NSR) from Ningho-Zhoushan China (departing 23 [LB1] September) to Felixstowe, United Kingdon (arriving 13 October) – in polar waters (for approximately 4,000 nautical miles) as defined by the International Maritime Organization (IMO) Code for Ships Operating in Polar Waters (the Polar Code). [LAJ2] [LB3] In the North Pacific the ship entered the Polar Code area when it crossed 60 degrees North as it headed through the Bering Strait and west bound along the Russian maritime Arctic. There has been no announcement from Liberia, the Chinese owners, the Russian maritime authorities, or any ship classification society regarding compliance of this ship under the mandatory rules and regulations of the IMO Polar Code.

The only reference to capability has been brief mention of the ship having a ‘low ice-1 ice classification,’ possibly referring to the ability to operate safely in the Baltic Sea during winter. But other media reports note that the 294-meter-long Istanbul Bridge carrying 4900 standard containers is not an ice-class vessel, only a normal, open-ocean carrier. The binding rules and regulations of the Polar Code are designed to reduce risks and enhance marine safety and environmental protection when operating in polar waters. Amendments in the Code are to three existing IMO conventions: the International Convention for Safety of Life at Sea (SOLAS) addressing marine safety; the International Convention for the Prevention of Pollution from Ships (MARPOL) addressing discharges; and the International Convention on Standards of Training, Certification, and Watchkeeping for Seafarers addressing the critical training and experience necessary for polar operators. A Polar Ship Certificate approved and issued by the flag state administration or an authorized representative (such as a ship classification society) is required for operation in polar waters; such a certificate would normally include information on polar ship category and ice class, operational limitations, and required additional safety, communications, and navigation equipment.

An onboard Polar Water Operational Manual unique to the ship is also required. The owner or operator must perform an operational assessment to determine the capabilities, limitations, and risk mitigation measures to be taken for hazards when operating in their specific polar region. A central tenet of the Code’s implementation is that it is a flexible and goals-based approach advanced by the IMO. The onus is on the owners and operators to meet the high standards of the Code by using expert bodies such as ship classification societies for guidance to achieve these goals. If these standards or goals are met or exceeded, then a Polar Ship Certificate will ultimately be issued.

Lastly, to obtain marine insurance for all operations in polar waters, presumedly the insurers would ask for proof that these specific standards and requirements of the Polar Code have been met. Since it was built in 2000, available records show that the Istanbul Bridge has operated under the flags of four states: Greece (2000) as Kuala Lumpur Express and Oakland Express; Hong Kong (2013) as Oakland; Panama (2023) as Flying Fish I; and Liberia (2024) as Istanbul Bridge. As Flying Fish I, the ship sailed in 2024 from St. Petersburg on the Baltic Sea (departing 3 September) to Shanghai (arriving 26 September) and set a record as the largest container ship to make a full Arctic transit. There are no media reports or marketing material from the ship operator at the time, EZ Safetrans Logistics of Hong Kong, that suggest that this earlier voyage under different owners and another flag state (Panama) was conducted in compliance with the Polar Code.

The Istanbul Bridge is undoubtedly a Category C ship under the Code. Category A ships (Polar Class 1-5) and B ships (Polar Class 6-7) are vessels designed for operations in ice-covered regions under the International Association of Classification Societies scheme. Category C ships operate in essentially open water or light ice conditions less severe than those in Categories A and B. The mandatory IMO rules and standards apply to all three ship categories (especially all SOLAS-classed commercial carriers and passenger vessels 500 tons or greater). Importantly, even though a ship may be operating in open (ice-free) waters, the ship remains under the governance of the Polar Code since it is voyaging in polar waters.

Whether or not the Istanbul Bridge was in compliance with the Polar Code on recent Arctic voyages, the issue has drawn global attention to the safety and environmental protection challenges of the operation of high-risk, non-polar ships in the Arctic Ocean. Particularly worrisome are oil tankers and containerships, many of unknown flag states and marine insurers. Expanded marine operations throughout the Arctic Ocean due to increasing access require renewed attention by the IMO, the Arctic states, and the flag states to step up efforts to implement and enforce the Polar Code. At a time when Sea Legend and other Chinese shippers are planning for potential regular container services between China and Europe across the NEP and NSR (during summer, ice-free months), the IMO must consider the status and effectiveness of the Polar Code that came into force 1 January 2017 (1 July 2018 for STCW requirements). An IMO sub-committee to assess the Polar Code’s implementation and enforcement must be established.

Co-chaired by IMO members from an Arctic and non-Arctic state along with IACS experts as technical advisors, the sub-committee should review the challenges faced by the maritime industry in implementing the Code after eight years and evaluate its overall strengths and weaknesses. Also, the Arctic states, with possible inclusion of non-Arctic states such as China, South Korean, Japan, and European states, must develop a port state control agreement to enforce the Code more tightly. Inspections will ensure that ships sailing in polar waters comply with existing international polar safety, environmental protection, and crew competency standards. The IMO Polar Code is a critical element of Arctic Ocean governance. Full implementation and enforcement of the Code by all maritime states will ensure greater protection of Arctic peoples and the marine environment, and enhanced safety for crew and cargo.