Bunker management software specialist Inatech has a link on its website to (link: https://shipandbunker.com/news/world/145908-imo-has-made-2020-compliance-unnecessarily-complicated-inatech text: an article by Alok Sharma), the company’s Global Head of Sales published on the online bunker news service Ship & Bunker. The article is titled, “IMO has made 2020 Compliance unnecessarily complicated” and suggest that the uncertainty approaching the 2020 deadline has come about because the IMO could have just said that use of fuel with a sulphur content above 0.5% is not permitted. According to Sharma, allowing the use of technology such as scrubbers to achieve the desired result has let refiners off the hook. Those who can remember the discussions and arguments about the sulphur cap when the idea of ECAs was being discussed at the IMO will recall that the use of technology as an alternative to the level of sulphur in fuels was something the industry pushed for despite being sceptical as to its effectiveness. (link: https://shipinsight.com/guides/the-global-sulphur-cap-insight-report text: We recommend reading our report on this here). That scrubbers, or indeed any alternative technology, could be used was seen as a small victory for the industry which at the time felt that it was being pushed into using distillates only to meet the ECA rules. At the time, the reduction of the global cap was seen as being twenty years or more into the future. In the article Sharma draws parallels with other areas of fuel use, where regulations are imposed on the suppliers but while that is a point of view that others may share it demonstrates a misunderstanding of what the IMO is and what it can do. IMO regulations require a consensus of the attending national delegates to be passed but they must then be enacted into national law by the governments concerned. Governments can opt out of some regulation applying to ships flying their own flags when operating in domestic waters or on the high seas. The ships will however be subject to Port State Control rules which may be the same as the IMO rules but could be more or less stringent if the government concerned decides otherwise. Quite clearly ships which operate across national boundaries are not subject to the same level of control as road vehicles or plant that operates solely in a single country. Governments can easily restrict the sale of products in their own country but could not stop a ship or indeed a vehicle from using a fuel that is not compliant if supplied outside the country although they could of course impose penalties if it could be proved it was doing so. It might be argued that it is not the IMO that has made the rules unnecessarily complicated, but the system that exists of the IMO formulating regulations for ships but not for ports or for suppliers of products and equipment. We may well all desire things to be simpler but what one person wants is not necessarily what others want and we just have to live with what there is. The successful owners – and the cheats – will always find a way to muddle through.