To: Shipowners / Managers / Operators
Subject: Black Sea Voyage Routing – Navigational Safety and Risk Mitigation
Recent developments in the Black Sea and the prevailing security conditions have made it increasingly important to minimise, to the extent possible, exposure to security and war risks when determining vessel voyage routes.
1. War Risk Area in the Black Sea Under JWLA-035
The Joint War Committee (“JWC”) issued JWLA-035 on 16 September 2026, expanding the scope of the area in the Black Sea identified as a war risk area. Under JWLA-035, the Black Sea is defined as:
“Black Sea excluding territorial waters of adjoining countries other than Russia and Ukraine”
Accordingly, the territorial waters of Türkiye, Bulgaria, Romania and Georgia are excluded from the listed area, whereas the territorial waters of Russia and Ukraine are not covered by this exclusion.
With this revision, the Black Sea war risk area is defined by reference to a broader geographical area, with the territorial waters of certain coastal States expressly excluded, rather than by reference to the previous coordinate-based definition. Accordingly, when assessing a voyage in the Black Sea, it is important to consider not only the vessel’s ports of departure and arrival, but also the actual route to be followed during the voyage.
2. Territorial Waters and Passage Regime
In Türkiye, pursuant to the Council of Ministers Decision No. 8/4742 dated 29 May 1982, it was decided to maintain the breadth of the territorial waters in the Black Sea as it existed prior to the entry into force of the relevant Law. Accordingly, Türkiye’s territorial waters in the Black Sea extend 12 nautical miles from the baselines.
From the perspective of international law, Article 3 of the 1982 United Nations Convention on the Law of the Sea (“UNCLOS”) provides that States may establish the breadth of their territorial waters up to a limit not exceeding 12 nautical miles from the baselines. With respect to Romania and Bulgaria, both of which are parties to UNCLOS, the 12-nautical-mile territorial waters are established under their respective national legislation. Pursuant to Article 2 of Romania’s Law No. 17/1990, Romania’s territorial waters extend 12 nautical miles from the baselines. Likewise, pursuant to Article 16 of Bulgaria’s Maritime Space, Inland Waterways and Ports Act, Bulgaria’s territorial waters extend 12 nautical miles from the baselines.
Against this background, a voyage conducted within the territorial waters of Türkiye, Romania and Bulgaria in the Black Sea will remain outside the listed area defined under JWLA-035, which excludes the territorial waters of these States.
3. Assessment of a Coastal Routing Option
In light of the above framework, following a coastal route within the territorial waters of Türkiye, Bulgaria and Romania, without proceeding into the more open areas of the Black Sea, may be considered as a routing option aimed at reducing exposure to the current war risk area.
In this context, following departure from the Istanbul Strait into the Black Sea, the vessel may proceed along the coasts of Bulgaria and Romania and subsequently continue along the Turkish Black Sea coast, with the route remaining within the territorial waters of the relevant States to the extent practicable. Choosing such a route may contribute to reducing the vessel’s exposure to the JWLA-035 listed area and, consequently, to the war and security risks associated with that area.
However, the fact that a route can be planned within territorial waters does not mean that such a route will be suitable or practicable for every vessel or in every circumstance. When determining the route, the vessel’s draft, the water depth in the areas where navigation will take place, the distance from the coast, prevailing sea and weather conditions, traffic density, current navigational warnings, applicable traffic separation schemes, and any temporary or permanent navigational restrictions should also be taken into consideration.
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