Circular JWLA-035, headed “Hull War, Piracy, Terrorism and Related Perils”, lists the Sea of Azov, all inland waters of Ukraine, Russia’s Don and Donets river systems, and the Black Sea outside the territorial waters of the countries around it, Russia’s and Ukraine’s excepted. “This week, the JWC has expanded the Black Sea reporting requirements to the whole of the Black Sea area,” the committee’s secretary, Neil Roberts of the Lloyd’s Market Association, said in remarks Reuters carried on 18 September. “The coastal waters of Russia and Ukraine were already listed. However, voyages within the territorial waters of adjacent countries still do not require notification.”
A listing, as Roberts describes it, is a reporting requirement: a voyage into the area has to be notified to the insurers. Dunya wrote on Monday that the change puts notification, voyage approval and cover conditions in front of transit voyages that call at no Russian or Ukrainian port. Premiums follow no tariff, it added: the frequency of attacks, the ship’s type, ownership and flag, its cargo, its route and its days in the area all enter the price.
The price has moved already. Dunya puts war-risk premiums at 1% to 1.5% of hull and machinery insured value, from 0.1% to 0.2% in normal conditions, and the extra cost of a 7-day voyage at $150,000 to $300,000. Reuters wrote of “hundreds of thousands of dollars” for every 7-day voyage.
For Kazakhstan the list now touches both of its Black Sea outlets. KazTransOil said on Monday that it sent 460,000 tonnes of oil toward Novorossiysk in August, up from 360,000 in July, while the flow toward Ust-Luga on the Baltic fell to 200,000 tonnes and cargo toward the port of Batumi rose to 293,000, Reuters reported. Novorossiysk, like the Caspian Pipeline Consortium’s terminal that carries more than 80% of Kazakhstan’s oil exports, lay inside Russia’s listed coastal waters before the change. Batumi did not. KazTransOil has owned 100% of Batumi Oil Terminal since August 2017, the terminal holds the exclusive right to manage Batumi Sea Port, and it handled 1.86 million tonnes in 2024.
The exemption has a shape. Twelve nautical miles wide, the territorial waters of Georgia, Turkey, Bulgaria and Romania run in an unbroken strip along the eastern, southern and western shores. On the chart, a tanker leaving Batumi for the Bosphorus can stay inside it the whole way. A ship crossing from Poti or Batumi to Constanta or Burgas cannot, unless it takes the long way round the coast.
That turns one corridor into 2 prices. Any route from Central Asia that ends at Georgia’s Black Sea ports now carries a London line item on the direct crossing, set voyage by voyage, and Brussels put “up to €12 billion” on that corridor on 16 September. The coastal strip, most of it Turkish, becomes the passage that needs no notification.
The traffic is already sorting itself. Salih Zeki Cakir, honorary president of the coaster owners’ association KOSDER, told Dunya that about 70 ships are queuing for the Sulina canal, held in Turkish, Bulgarian and Romanian waters, and that some cargoes are moving to Georgian ports. Engin Kocak of Navis Consulting said nothing has moved in the Sea of Azov since 10 July and that traffic at Novorossiysk has thinned. Ships waiting for an insurer’s approval before entering the Black Sea, he said, are lengthening the waits at the entrances to the Turkish straits.
The coastal strip, most of it Turkish, becomes the passage that needs no notification.
The Turkish Shipowners’ Association counted 146 commercial ships hit or damaged in the Black Sea, the Kerch Strait and the Sea of Azov between 24 February 2022 and 26 August 2026, 82 of them this year, with 37 seafarers and port workers killed; 34 of the ships were Turkish-owned or Turkish-controlled. Since that count closed, the tug Tedy, the Ro-Ro Lionfish and the freighter Mariam M, all Turkish-owned, have been hit, the last with its captain killed in the Bystre canal on 17 September.
The committee says its listed areas “will be re-adjusted if required by circumstances”. What a Batumi cargo pays against an Odesa one is the number to watch.