One of 44 cruise vessels assessed in 2024-25 required cleaning. But the 2018 standard was revoked in October 2023, cruise ships are not short-stay vessels and get no macrofouling allowance at all, and 'eleven ships turned around' never happened. Biosecurity New Zealand and the industry publicly disagree on whether these rules caused the decline.
Compliance has improved dramatically — one of 44 cruise vessels assessed in 2024-25 required cleaning, against eleven notices of direction two seasons earlier. But three things are widely misreported: the 2018 standard was revoked in October 2023; cruise ships are not short-stay vessels and get no macrofouling allowance at all; and "eleven ships turned around" never happened. Meanwhile Biosecurity New Zealand and the cruise industry publicly disagree about whether these rules caused the deployment decline — and that disagreement is the actual story.
Our ideas and proposals for the future of New Zealand cruise. Forward-looking opinion, not statements of fact.
A note on this paper. Biosecurity regulation is the topic in this series where being wrong in public would cost most, and where the published record is thinnest. This paper is shorter than the others because it stops where the evidence stops. Regulatory extracts should be verified against the primary standard before anyone relies on them commercially.
Three things almost everyone gets wrong
One: the 2018 standard no longer exists
New Zealand's biofouling requirements are routinely described as "the 2018 Craft Risk Management Standard for Biofouling on Vessels Arriving to New Zealand."
That instrument was revoked and replaced on 13 October 2023 by the consolidated Craft Risk Management Standard: Vessels, issued under the Biosecurity Act 1993. The 2023 standard explicitly revokes both the October 2018 vessels standard and the November 2018 biofouling standard.
Anyone citing the 2018 standard as current — and a great deal of commentary does — is citing a revoked instrument.
Two: the threshold is 28 days, not 21
The 2018 standard used a 21-day threshold to separate short-stay from long-stay vessels. The 2023 standard extended it to 28 days. Vessels staying 29 days or more, or visiting places outside the designated Places of First Arrival, fall into the long-stay category.
Three: cruise ships are not short-stay vessels
This is the most consequential misunderstanding, and it inverts the entire picture.
Under clause 2.3 of the current standard, a cruise vessel must either:
"complies with long-stay requirements set out in Clause 2.2"
or
"operates under an MPI-approved system to manage topside and biofouling risk"
Cruise ships get no short-stay allowance, regardless of how long they are in New Zealand waters.
The practical difference is large. The short-stay thresholds in Schedule 4 Table 1 permit incidental coverage of up to 1% of tubeworms, bryozoans or barnacles on the hull, scattered coverage up to 5% in niche areas, algal growth to 4 millimetres, and green algae to 50 millimetres of frond length.
The long-stay thresholds that actually apply to cruise vessels, in Schedule 4 Table 2, permit exactly two things on all hull surfaces:
"Slime layer" "Goose barnacles"
That is the complete list. No percentage allowance for macrofouling of any kind.
The clean hull definition, at clause 2.2(2)(c):
"The vessel has a 'clean hull'. That is, no biofouling of live organisms is present other than those within the thresholds in Table 2 of Schedule 4."
Compliance is achieved by cleaning before arrival — inspecting and removing all biofouling less than 30 days before arrival — by holding a booking at an MPI-approved haul-out facility within 24 hours of arrival, or by treating on arrival. Non-compliant vessels "will be directed to either manage the biosecurity risk or to leave New Zealand."
These extracts were assembled from a document our tooling could only retrieve in fragments. The wording above is exact, but anyone relying on it commercially should verify Schedule 4 against the original standard.
What the enforcement record actually shows
Here the published record and the circulating summary diverge sharply.
| Season | What MPI reported | What is commonly written |
|---|---|---|
| 2022-23 | 11 notices of direction issued. Of those, 3 cleaned hulls before arrival; 8 received itinerary restrictions | "11 ships turned around" — wrong |
| 2023-24 | 4 non-compliant vessels of 54 expected. Of those, 1 did not enter New Zealand waters (Pacific Adventure); 3 cleaned at the border and completed their itineraries | "4 denied initial access" — wrong |
| 2024-25 | 44 cruise vessels assessed, 1 required cleaning | ✅ Accurate as stated |
| 2025-26 | Not published. MPI's most recent cruise biofouling season summary remains 15 April 2025 | — |
The trajectory is unambiguous. Eleven directions, then four non-compliant vessels of which one was excluded, then one requiring cleaning out of forty-four assessed.
Stuart Anderson, Deputy Director-General of Biosecurity New Zealand, February 2024:
"This season to date, only one of the 54 cruise vessels expected to arrive here for approximately 1100 port visits has not entered New Zealand waters because it was unable to meet our biofouling standards."
"The drop in biofouling issues is a good result when you consider there's been an increase of about 25 per cent in vessels arriving this season."
Mike Inglis, Commissioner North, Biosecurity New Zealand, April 2025:
"It's been a great season. Cruise operators continue to prioritise biofouling management."
"The results this season show the close working relationship we have established with the cruise industry is really paying off."
Why the rules exist
MPI's stated basis, repeated across three media releases: almost 90% of the exotic marine species already established in New Zealand likely arrived as marine growth on the submerged surfaces of international vessels.
Paul Hallett, Environmental Health Manager, Biosecurity New Zealand, September 2023:
"Biofouling continues to be a major biosecurity threat. We know that almost 90% of the exotic marine species already in New Zealand likely arrived here as marine growth on the submerged surfaces of international vessels."
That is not a marginal justification. Whatever view one takes of the compliance burden, the underlying risk is well founded and New Zealand's marine environment is the asset the cruise product ultimately sells.
January 2023, and what it cost
The season that produced New Zealand's reputation problem is worth setting out, because it is what cruise lines remember.
Seven vessels were affected: Viking Orion, Seven Seas Explorer, Queen Elizabeth, Oceania Regatta, Coral Princess, Celebrity Eclipse and Azamara Quest.
- Viking Orion was identified at Wellington on 26 December 2022 and missed Christchurch, Dunedin, Hobart and Adelaide — four of eight ports. Its hull was cleaned by divers roughly 17 nautical miles offshore near Adelaide. Passengers reported receiving a voucher worth 100% of what they had paid.
- Seven Seas Explorer failed a pre-arrival assessment on 4 January 2023 and was cleaned off Adelaide by an MPI-recognised contractor. Guests were compensated; some disembarked early.
- Queen Elizabeth cancelled Fiordland and missed Dunedin and the Bay of Islands across voyages. A 24-hour cleaning attempt on 14 January was incomplete.
MPI never published a ship-by-ship account, so the per-vessel detail rests on media reporting and should be treated as secondary. The aggregate cost to the industry has never been published by anyone.
The structural reason it happened
This is the part that gets least attention and explains most.
Until December 2025 there were no approved suppliers for in-water cleaning of international vessels in New Zealand territorial waters.
That single fact explains the 2022-23 season. A vessel arriving with fouling had no way to fix the problem here. "Clean before you arrive" was not one option among several — it was the only one. A ship that failed assessment could be cleaned in Adelaide, or it could leave.
In October 2025 the Port of Auckland and New Zealand Diving and Salvage Ltd applied to operate an in-water niche-area cleaning system, covering sea chests, propeller shafts and similar. Following trials on domestic vessels, it received provisional approval in December 2025 and was available for the 2025-26 summer.
Hon Andrew Hoggard, Minister for Biosecurity, December 2025:
"Marine growth on vessel hulls poses a biosecurity risk to New Zealand's marine environment."
"We are very aware of commercial pressures faced by shipping and cruise industries."
What is still not published: that system's capacity, its cost, or how a vessel books it. We could not find any of the three, in the ministerial release or on MPI's site.
For a deployment planner committing a ship three years out, "there is now a system" and "I can book it, at this price, with this contingency if it is unavailable" are entirely different propositions. The remaining gap is commercial certainty, not capability.
The disagreement at the centre of this
The most important thing in this topic is not a regulation. It is that two credible parties publicly disagree about cause and effect, and both are on the record.
Biosecurity New Zealand's position. Paul Hallett, June 2025:
"No cruise ships were stopped from entering our waters during 2024/25 and the vast majority of vessels were highly compliant."
Hallett attributed the deployment decline instead to "rising operational costs — including port fees and fuel — and global economic factors such as inflation and exchange rates," and said the rules "were developed in consultation with industry" and were designed to "provide greater clarity... not to introduce new barriers."
The industry's position. New Zealand Cruise Association chair Tansy Tompkins, March 2025, cites biofouling port-denial risk alongside "unpredictable new regulations" and compounding cost increases, describing New Zealand as the most expensive place in the world for a cruise ship to visit. NZCA has described biofouling as the number one concern raised by cruise lines.
Carnival's stated reason for moving Carnival Adventure to North America in April 2028 was "more favourable market conditions elsewhere and the uncertain regulatory environment in Australia and New Zealand."
Both positions cannot be complete, and the evidence does not cleanly settle it. Hallett is right that enforcement outcomes in 2024-25 were near-perfect. The industry is right that a rule which can strand a voyage is priced as risk whether or not it is ever triggered — and risk is priced at the planning stage, three years before the ship sails.
The most defensible reading is that the 2022-23 season did reputational damage that the 2024-25 compliance record has not yet undone, and that with no in-water cleaning capacity available at the time, the rule was effectively stricter in practice than on paper. Both of those conditions have now changed. Whether planners know that is a different question.
How New Zealand compares
The genuine distinction is not strictness. It is what is being regulated.
| New Zealand | Australia | California | |
|---|---|---|---|
| In force | 2018; replaced 13 October 2023 | 15 June 2022 | 1 October 2017 |
| Basis | Numeric fouling thresholds on arrival | Management practices; no numeric thresholds | Documentation; no numeric thresholds |
| Coverage | All vessels | International arrivals | Vessels 300 GRT and above |
| Compliance route | Meet Schedule 4 thresholds via one of four measures | One of three: biofouling management plan, cleaned within 30 days, or pre-approved alternative | Management plan plus Biofouling Record Book; coatings within service life |
| Pre-arrival reporting | Pre-Arrival Report, mandatory from 1 May 2025 | MARS pre-arrival questions | Annual Vessel Reporting Form |
| Cruise-specific rule | Yes — clause 2.3 | No | No |
| Enforcement observed | Entry denial, direction to leave, itinerary restriction | Rare | Rare |
Australia and California regulate whether a vessel has a plan. New Zealand regulates whether the hull is clean.
That is a genuine difference in kind, not degree. An outcome-based standard produces enforcement events; a practice-based standard largely does not. It is why New Zealand generates headlines that Australia does not, on rules that are not obviously more onerous in intent.
It is also, arguably, the more honest regime — a plan is not a clean hull — and New Zealand should say so rather than apologising for it.
What we cannot tell you
No cruise line is publicly identified as holding an MPI-approved system or approved Craft Risk Management Plan. The only publicly named approved biofouling plan we located belongs to the Royal New Zealand Navy, signed 20 October 2020. It is useful as an illustration of the mechanism, not as a cruise precedent.
The application timeframe, fee and assessment criteria for an approved system are not published. MPI publishes only contact addresses.
No 2025-26 enforcement statistics exist publicly. MPI's most recent cruise summary is from April 2025. Obtaining 2025-26 figures would likely require an Official Information Act request.
Auckland's in-water cleaning capacity, cost and booking process are not published.
The aggregate cost of the January 2023 incidents has never been published.
There is no current review of the biofouling standard. The government–cruise sector engagement announced on 11 April 2026, and the second Cruise Forum on 26 May 2026, are a growth and tourism initiative that mentions biosecurity engagement. They are not a regulatory review and should not be reported as one.
What we are asking
Publish the in-water cleaning service standard. Capacity, price, booking process, turnaround time and contingency. This is the single highest-value change available and it requires no regulatory amendment at all. A rule a planner can price is a rule a planner can accept.
Publish 2025-26 enforcement statistics. The 2024-25 record is excellent and MPI should want it known. Sixteen months without an update lets the 2022-23 story stand as the current one.
Name a case manager per vessel and publish the pre-arrival pathway. Certainty at the planning stage is worth more than leniency at the border.
Publish who holds approved systems, and the route to getting one. An alternative-compliance mechanism that nobody can see anyone using is not, in practice, an available option.
Resolve the causation dispute in public. Biosecurity New Zealand says the rules did not cause the decline. Carnival cites the regulatory environment in a redeployment announcement. Both are on the record and both cannot be complete. The sector would benefit from that being examined rather than each side repeating its position.
Correct us. The regulatory extracts here were retrieved in fragments and should be checked against the primary standard. If anything is wrong, tell us and we will amend the page and say what changed.
Sources
Primary regulation — Craft Risk Management Standard: Vessels, issued under the Biosecurity Act 1993, in force 13 October 2023; MPI Craft Risk Management Standard FAQs, February 2024; MPI biofouling management and commercial vessels pages.
Enforcement — MPI media releases: "Dirty bottom alert for visiting cruise ships," 14 September 2023; "Biofouling fight protecting unique NZ environment and economy," 5 February 2024; "Cruise ships cleaner over the past summer season," 15 April 2025; "Biofouling measures approved for naval vessels," 20 October 2020.
In-water cleaning — Ministerial release, 13 December 2025.
Quotes — Paul Hallett via MPI (14 September 2023), RNZ (4 January 2023 and 18 June 2025); Stuart Anderson via MPI (5 February 2024); Mike Inglis via MPI (15 April 2025); Andrew Hoggard (13 December 2025); Tansy Tompkins via Seatrade Cruise (25 March 2025); Carnival via Seatrade Cruise (26 February 2026).
January 2023 incidents — Cruise Passenger, 12–13 January 2023; Maritime Executive; RNZ, 4 January 2023; NZ Herald. MPI published no ship-by-ship account; this detail is secondary.
International comparison — Australian Department of Agriculture, Fisheries and Forestry industry advice 80-2022; California State Lands Commission guidance document (2017); North Standard, 19 June 2025 (Pre-Arrival Report).
Government engagement — Beehive release, "Government and cruise sector team up for further growth," 11 April 2026.
Where a figure or document could not be located in the published record, this paper says so rather than estimating.