Circular issued by International Group clubs IOPC Funds Amended Guidance for Member States on the definition of ‘ship’ under the 1992 Civil Liability Convention (1992 CLC) At the November 2025 Sessions of the IOPC Funds’ Governing Bodies, the Executive Committee of the IOPC Funds approved a new footnote for inclusion in the IOPC Funds’ publication ‘ Guidance for Member States – Consideration of the definition of ‘ship’ under the 1992 Civil Liability Convention ’.  The footnote sets out guidance on a standard procedure for determining when a ship which can serve as a qualifying ship under both the 1992 CLC and the 2001 Bunkers Convention, ceases to be a “ship” under the 1992 CLC. This circular provides members with an overview of the reason for the change and guidance for tankers that switch between MARPOL Annex I [1] and MARPOL Annex II cargoes. Legal framework Overview of compensation regime for oil pollution damage from tankers carrying persistent oil The 1992 CLC, 1992 Fund Convention and 2003 Supplementary Fund Protocol establish a liability regime for pollution damage caused by spills of persistent oil from tankers, which occur in the territory or exclusive economic zone of a State Party to the respective Convention. The 1992 CLC governs liability for oil pollution damage under which the registered owner is held strictly liable for pollution damage caused by the escape or discharge of persistent oil from the ship. In return for this strict liability, the registered owner is able to limit its liability based on the size of the ship up to a maximum of 89,770,000 Special Drawing Rights (SDR). Above this limit, the 1992 Fund Convention establishes a regime for compensating victims where the 1992 CLC is either not available or inadequate up to a maximum of 203 million SDR. The Supplementary Fund provides additional compensation beyond the amount available under the 1992 Fund, giving a total amount of compensation for each incident of 750 million SDR.  Both