Abstract: Vessel anti-fouling is key to the efficient operation of ships, and essential for effective control of invasive species introduced through international shipping. Anti-Fouling Systems, however, pose their own threats to marine environments. The Anti-Fouling Convention of 2001 banned the use of organotin compounds such as Tributyltin, and created a system for adoption of alternative anti-fouling biocides. In 2011, the Marine Environmental Protection Committee of the International Maritime Organization (IMO) released guidelines on bio-fouling management record keeping, installation, inspection, cleaning, maintenance, design and construction. Though these Guidelines provide a template for more effective and environmentally sound anti-fouling control and implementation, they are not mandatory. This article proposes that the member states of the IMO adopt the 2011 Guidelines as a mandatory instrument.