Maritime

Breadcrumbs

FAQ - Regulation

Global Sulphur Cap
Sulphur limits

What are the sulphur limits for fuel in use under MARPOL?

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With the adoption in 2008, 1 January 2020 was given as the effective date for the 0.50% global sulphur cap, with an option to later defer the date until 1 January 2025, taking into account the global market supply and demand. In 2016, the IMO decided, based on information provided, to stick with the 1 January 2020 date. Hence, from 1 January 2020, the global sulphur limit will be lowered from 3.50% to 0.50%. For vessels operating in Sulphur Emission Control Areas (SECA) under MARPOL, the limit, which will remain unchanged, has been 0.10% since 1 January 2015.

What will be the implication of having fuel exceeding 0.50% sulphur remaining on board after 1 January 2020?

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Unless the vessel is fitted with a scrubber (Exhaust Gas Cleaning System [EGCS]), fuel oil exceeding 0.50% sulphur can’t be used after 1 January 2020. All remaining HSFO must be de-bunkered before 1 March 2020 when the carriage ban for HSFO enters into force. To avoid having non-compliant fuel on board on 1 January 2020, it is important to work out a bunkering strategy ahead of the 2020 deadline.

What control measures will be in place to enforce the 0.50% global sulphur requirements from 2020?

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PSC will typically check the IAPP certificate, together with the Bunker Delivery Notes (BDNs), filed on board. If there are “clear grounds” to do so, PSC may conduct a more detailed inspection, including on-board sampling or analysing of the MARPOL sample following the BDN. “Clear grounds” may be indications from remote sniffing devices or portable sulphur content measuring devices that the fuel used on board may be non-compliant.

What may be the consequence of failing to comply?

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Using non-compliant fuel without an EGCS in use, or failing to provide the necessary evidence that fuel oil was not available at the port of bunkering (Fuel Oil Non-Availability Report [FONAR]), may result in fines, detention and de-bunkering. As sanctions are established by the individual states, the imposed sanctions will vary from port to port.

What happens if compliant fuel cannot be obtained in the port of bunkering?

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A Fuel Oil Non-Availability Report (FONAR) shall be submitted to the flag state, with a copy to the port of destination, as soon as it is determined that compliant fuel oil will not be available.

What is to be included in the FONAR?

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A standard format of the FONAR will be given in an appendix to the “2019 Guidelines for Consistent Implementation of the 0.50% Sulphur Limit under MARPOL Annex VI”, to be adopted by MEPC 74 in May 2019. The FONAR will include a description of the voyage plan, evidence of attempts to purchase compliant fuel, alternatives for fuel oil supply disruption as well as operational constraints such as fuel quality issues deemed to cause operational or safety problems, plans to obtain compliant fuel and a record of previously filed FONARs.

For a vessel fitted with an EGCS and using HSFO instead of compliant fuel, will there be any restrictions on incineration of sludge generated from HSFO after 2020?

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No, the use of an incinerator to burn oil residues (sludge) generated on board, e.g. from the purification of fuel oil, is permitted under MARPOL, regardless of the sulphur content of the fuel in use. However, there may be local restrictions on the use of incinerators in some ports. On-board incineration of residues/sludge generated by the EGCS is, however, prohibited by MARPOL Annex VI Regulation 16.2.6.

Is the carriage ban for non-compliant fuel also applicable to emergency equipment?

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Yes, the prohibition on carriage of non-compliant fuel oil should be applied to the fuel oil of emergency equipment, e.g. lifeboats and emergency generators.

FAQ - Technical, operational

How can I best prepare for 2020?

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The IMO has developed a “Guidance on the Development of a Ship Implementation Plan (SIP) for the Consistent Implementation of the 0.50% Sulphur Limit under MARPOL Annex VI”. Making a ship-specific SIP is considered a good starting point for preparing, as the plan will cover the expected challenges. The plan is not mandatory and is not subject to endorsement by the flag state or a recognized organization (RO). However, port state control (PSC) may consider the preparatory actions described in the SIP when verifying compliance. DNV GL has prepared a Web-based SIP application which is free of charge and available in the DNV GL Veracity marketplace

DNV GL has also developed a checklist which contains an overview of the critical activities to be reviewed, and implemented, before the end of 2019. The checklist is available here.

Do I have to clean my bunker tanks before switching to compliant fuel?

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Tank cleaning is basically done for the following reasons: 

  • To avoid operational issues with purifiers and filters, as new fuel blends and distillates may, due to their physical properties, be prone to dissolve and dislodge sludge and sediment build up in the fuel oil storage and service tanks 
  • To avoid separation and sludge formation due to incompatibility with remaining tank content, as new FO blends may carry a higher risk of incompatibility
  • To avoid contamination of the LSFO, potentially exceeding the required sulphur content 

The decision on tank cleaning should be taken based on the amount of sediments inside the tank and the type of fuel to be used. An alternative to manual tank cleaning may be using ship-specific changeover procedures to load on top and gradually flush through the fuel system until the sulphur content is within the compliant level. Another alternative is to gradually clean the sediments and asphaltic sludge from HSFO tanks and the fuel system by dosing additives to the HSFO used prior to the switch. .