From National Rules to Global Norms: Aligning China’s L2 Autonomous Ship Regulations with the IMO MASS Code

Abstract

The advent of remote control and autonomous technologies is fundamentally transforming ship manning models, necessitating adaptations in seafarer standards for L2-class autonomous vessels. To address these challenges, the International Maritime Organization’s (IMO) Maritime Safety Committee (MSC) is developing a non-mandatory Code for Maritime Autonomous Surface Ships (MASS). This paper first conducts an in-depth analysis of the immutable legal obligations and variable technical standards governing seafarer manning for L2 autonomous ships, drawing on the China Classification Society’s (CCS) Rules for Intelligent Ships. It then scrutinizes the international legal barriers confronting CCS manning requirements, particularly concerning remote operator qualifications. The study focuses on aligning China’s regulatory framework with emerging IMO standards and proposes four targeted reforms to facilitate this alignment for L2 vessels: broadening the “seafarer” definition, updating minimum manning principles and procedures, modernizing competency standards, and establishing inclusive operational testing systems.