JWLA-035 – Significant Change to the Black Sea Listed Area Definition

On 16 September 2026 the Joint War Committee (JWC), established within the Lloyd’s Market Association (LMA) and the International Underwriting Association (IUA), issued JWLA-035, introducing a significant change to the definition of the Black Sea Listed Area.

The change is significant in terms of war risks insurance, additional premium obligations, voyage planning and the rights and responsibilities of parties under charterparties for vessels trading in the Black Sea.

Definition of the Black Sea Area

Under JWLA-035, the previous coordinate-based definition of the Black Sea has been removed and replaced with the following wording: ‘Black Sea excluding territorial waters of adjoining countries other than Russia and Ukraine.’

Accordingly, almost the entire Black Sea has been brought within the Listed Area, while the territorial waters of Türkiye, Bulgaria, Romania and Georgia remain excluded. Russian and Ukrainian territorial waters remain within the Listed Area. The existing provisions concerning the Sea of Azov, specified inland waters of Ukraine, Russian-controlled areas, and Crimea also remain in force under JWLA-035.

Significance of the Change for Voyages

Under the previous definition, a substantial area in the southern Black Sea remained outside the Listed Area. As a result, depending on their route, certain vessels entering the Black Sea through the Turkish Straits or calling at ports in Bulgaria, Romania, or Georgia could navigate without entering the Listed Area. JWLA-035 has materially changed this position.

Under the new definition, a vessel entering the Black Sea through the Bosphorus may enter the Listed Area once it leaves Türkiye’s territorial waters. Similarly, although a port in Bulgaria, Romania, or Georgia and the territorial waters of the relevant coastal state may lie outside the Listed Area, the route to that port may pass through the Listed Area. The assessment should therefore be made by reference not only to the destination port, but also to the vessel’s actual route and the applicable territorial sea limits.

Effect on War Risks Insurance

Designation of an area by the JWC as a Listed Area does not prohibit voyages to that area and does not, by itself, mean that insurance cover is automatically terminated. However, entry into a Listed Area may represent an increased risk for war risks insurers and, depending on the terms of the relevant policy, may require:

• prior notice to insurers
• voyage-specific approval
• arrangement of breach cover
• payment of an Additional Premium (AP)
• acceptance of additional terms of cover.

Shipowners and operators planning a Black Sea voyage should therefore review the terms of their existing Hull War and other relevant war risks policies before departure. In particular, they should check which JWLA list is incorporated into the policy, any cancellation and reinstatement provisions, notice requirements for entering a Listed Area, Additional Premium requirements and geographical trading or navigation limits.

The publication of JWLA-035 on 16 September 2026 does not mean that the new list automatically became effective under every policy on that date. The date and mechanism by which the new list applies to a particular policy should be assessed by reference to the relevant policy terms and any notice issued by the insurer.

Operational Considerations

The positions and planned routes of vessels already in the Black Sea or scheduled to trade there should be reassessed in light of JWLA-035. For voyages to ports in Türkiye, Bulgaria, Romania, or Georgia, the fact that the relevant port is located outside the Listed Area is not sufficient on its own. It should also be determined whether the vessel will enter the Listed Area while proceeding to or from that port.

Where coastal navigation within the territorial waters of the relevant state is planned, the intended route should be confirmed with the insurer in advance and, where necessary, should be capable of being evidenced by AIS records, passage plans, ECDIS records and other navigational records.

Charterparty Considerations

The JWLA-035 amendment may also have implications for existing and future charterparties. In particular, charterparties incorporating CONWARTIME, VOYWAR or similar war risks clauses should be carefully reviewed in relation to:

• the availability of insurance cover
• any additional crew wages or bonuses
• alternative route and deviation provisions
• which party is responsible for additional war risks premiums
• the Owners’ rights to refuse orders involving areas exposed to war risks
• the allocation between the parties of additional costs arising from insurers’ requirements.

In particular, where the destination port lies outside the Listed Area but the vessel must pass through the Listed Area in order to reach that port, the allocation under the charterparty of any Additional Premium and other additional costs becomes particularly important.

Towage, Salvage, and Dead-Ship Operations

The new geographical definition should also be taken into account in relation to towage, salvage, wreck removal and dead-ship towage operations in the Black Sea. As vessels or tugs involved in such operations may remain within the risk area for longer periods than vessels engaged in standard commercial voyages, and as the operational route may differ, war risks cover should be confirmed with insurers on an operation-specific basis.

Where appropriate, the operation plan, intended route, estimated duration, details of the tug and the towed vessel, and the contingency plan should be submitted to insurers so that the terms of cover and any Additional Premium can be agreed in advance.

Recommendations for Shipowners and Operators

Shipowners and operators trading or planning to trade in the Black Sea should reassess their existing war risks policies and planned voyages in light of JWLA-035.

Before departure, the vessel’s intended route should be compared with the boundaries of the new Listed Area, all notices required under the policy should be given on time, and written confirmation of any Additional Premium and applicable cover should be obtained from the insurer where necessary. Likewise, where a voyage may give rise to an additional war risks premium, additional crew costs, or other expenses under the charterparty, the relevant contractual provisions should be reviewed before the voyage order is accepted.

JWLA-035 has introduced a significant geographical change to the assessment of war risks in the Black Sea. Certain voyages that could previously be performed without entering the Listed Area may now result in entry into the Listed Area once the vessel leaves the territorial waters of Türkiye, Bulgaria, Romania, or Georgia. Each voyage should therefore be assessed on a case-by-case basis, taking into account the vessel’s actual route, the applicable war risks policy, the insurers’ specific requirements and the relevant charterparty provisions.

This circular has been prepared for general information purposes only. Each matter should be assessed separately in light of the relevant insurance policy, charterparty provisions and voyage conditions.

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