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Environmental regulations

Regulation overview

Regulation overview

In modern times the shipping industry has been unfairly singled out as a major source of global pollution. It is often said that when it comes to CO2 emissions, shipping is a bigger contributor than all but a handful of nation states. That may be true but so are power production, agriculture and most other essential industrial operations. It also does not take into account that shipping is a service industry that exists only to move goods and people around the globe. In that respect, it is recognised as being the most efficient of the various options that exist.

However, when it comes to other means of affecting the marine environment, shipping is perhaps among the most regulated of human activities. Shipping is not alone in having an effect on the marine environment. All around the globe, vast amounts of waste of all types find their way to the sea. From farming runoff into rivers through garbage from fishing and leisure use of the sea and coastal lands to sewage outflows from cities and towns, it is likely that far more damage is done to the marine environment by non-shipping activities than anything commercial ships are responsible for.

The latest threat is plastic, which is being found in increasing quantities in the world’s oceans. Whether it comes from microbeads used by cosmetic manufacturers, plastic bags or other synthetic materials used for all manner of reasons, it is certainly not related just to shipping but, because plastic is found at sea, it is shipping that gets an unfair proportion of the blame.

Regulating shipping’s environmental impact is quite a modern development and just over 60 years have passed since the first global regulations became effective. Before that, there may have been local rules in individual ports but whatever rules may have been in place appeared to have been universally ignored.

Even before ships had engines, they had the potential to impact on the environment. As well as the alien species that hitched a ride on ships – whether in the ship, in the cargo or under the hull – there was the waste produced by the crew and passenger on board and occasionally a cargo that needed to be dumped at sea.

It is generally accepted that oils and greases are the most pervasive and polluting by-products of shipping activity. The advent of mechanically propelled ships has increased the level of oily waste, and with no regulation barring it, that waste was regularly dumped at sea. Although steam ships also produced waste oil in quantities, the problem was only recognised soon after the first diesel engine was used in 1912. But it was the increase in crude oil transport and the consequent disposal of tanks washings at sea that was the spur for the first regulations prohibiting disposal of oil.

That was not to be until The International Convention for the Prevention of Pollution of the Sea by Oil (OILPOL) was formulated in London in 1954. The 1954 convention came into force in 1958 and was amended in 1962, 1969 and 1971. It was eventually superseded by the International Convention for the Prevention of Pollution from Ships (MARPOL), and its measures are now included there.

Sources of regulation

Regulating the environmental impact of shipping is done in a variety of ways. Firstly, nation states can regulate, enforce and control however they please in the territorial and economic zones that are recognised as being under their jurisdiction. In some cases, states may also claim jurisdiction that is not recognised under international law and here shipowners must either acquiesce or call upon their flag state to intervene.

Nation states or Port states as they are more properly defined in this context, are at liberty to delegate the right to make regulations as they see fit. With regard to shipping this is normally done at regional level (eg at state level in the US where California and a small number of other states are very active in drafting local rules) or even at port level. In some ports individual terminals will have their own by-laws adding complexity.

The second means of regulation is by flag states or perhaps by supra-national organisations to which the flag state belongs. The prime example here is the European Union (EU) which formulates environmental regulations that can apply to any ship flagged in an EU member state.

The third and final way is by international conventions to which flag states have signed. The most well known of these is the MARPOL Convention which comes under the IMO but there are others.

As examples, the International Convention on the Control of Harmful Anti Fouling Substances on Ships, 2001 and the International Convention for the Control and Management of Ships’ Ballast Water and Sediments, 2004 which entered into force in 2018 (although a five-year dispensation has been given by the IMO, meaning it will be 2024 before all ships are subject to its provisions).

The International Convention for the Prevention of Pollution from Ships (MARPOL)

The International Convention for the Prevention of Pollution from Ships (MARPOL)

MARPOL is an international convention of the IMO. Early international regulation of shipping was mostly concerned with safety and in particular the Safety of Life at Sea (SOLAS) Convention. MARPOL evolved from the earlier OILPOL Convention of 1954 during the 1970s and while initially concerned only with pollution by oil it has expanded to cover much more.

OILPOL did not put a complete ban on disposal at sea; it merely prohibited the dumping of oily wastes within a certain distance from land and in ‘special areas’ where the danger to the environment was especially acute. It also imposed a requirement for contracting parties to provide reception facilities, but the lack of facilities has been a bone of contention for the industry even through to today. OILPOL was mainly concerned with operational discharges as was the 1973 version of MARPOL drawn up by the IMO.

This was amended by the Protocol of 1978, which was adopted in response to a spate of tanker accidents in 1976-1977. As the 1973 MARPOL Convention had not then entered into force and thus could not be amended, the 1978 MARPOL Protocol absorbed the parent Convention. The combined instrument entered into force on 2 October 1983.

In 1997, a second Protocol was adopted to amend the convention and a new Annex VI – relating to air pollution – was added, which entered into force on 19 May 2005. MARPOL has been updated by amendments through the years, and most of its measures are the province of the IMO’s Marine Environment Protection Committee (MEPC), which is also entrusted with the development of other environmental conventions.

Structure of MARPOL

MARPOL is a wide ranging convention covering pollution from ships and shipping across a number of areas. Although originally intended to cover oil pollution it has grown to cover many other types of pollution.

The convention comprises the main text which mostly revolves around rights, responsibilities and definitions complemented by a number of annexes (presently six) covering specific pollution sources or types. Annexes I and II were part of the original convention text but all others have been added at various times since.

Categories of marine pollution

IMO says of MARPOL that it includes regulations aimed at preventing and minimising pollution from ships – both accidental pollution and that from routine operations – and currently includes six technical Annexes, most of which include special areas with strict controls on operational discharges.

Oil & grease

The Annex I Regulations for the Prevention of Pollution by Oil (entered into force 2 October

1983) covers prevention of pollution by oil from operational measures as well as from accidental discharges. The 1992 amendments to Annex I made it mandatory for new oil tankers to have double hulls and brought in a phase-in schedule for existing tankers to fit double hulls, which was subsequently revised in 2001 and 2003.

Noxious liquid substances

Annex II Regulations for the Control of Pollution by Noxious Liquid Substances in Bulk entered into force 2 October 1983) details the discharge criteria and measures for the control of pollution by noxious liquid substances carried in bulk. Some 250 substances were evaluated and included in the list appended to the convention. The discharge of their residues is allowed only to reception facilities until certain concentrations and conditions (which vary with the category of substances) are complied with. In any case, no discharge of residues containing noxious substances is permitted within 12 miles of the nearest land.

Harmful packaged substances

Annex III Prevention of Pollution by Harmful Substances Carried by Sea in Packaged Form (entered into force 1 July 1992) contains general requirements for the issuing of detailed standards on packing, marking, labelling, documentation, stowage, quantity limitations, exceptions and notifications.

For the purpose of this annex, “harmful substances” are those that are identified as marine pollutants in the International Maritime Dangerous Goods Code (IMDG Code) or which meet the criteria in the Appendix of Annex III.

Sewage

Annex IV Prevention of Pollution by Sewage from Ships (entered into force 27 September 2003) contains requirements to control pollution of the sea by sewage. The discharge of sewage into the sea is prohibited, except when the ship has in operation an approved sewage treatment plant or when the ship is discharging comminuted and disinfected sewage using an approved system at a distance of more than three nautical miles from the nearest land. Sewage that is not comminuted or disinfected has to be discharged at a distance of more than 12 nautical miles from the nearest land.

In July 2011, IMO adopted the most recent amendments to MARPOL Annex IV, which entered into force on 1 January 2013. The amendments introduced the Baltic Sea as a special area under Annex IV and add new discharge requirements for passenger ships while in a special area.

Garbage

Annex V Prevention of Pollution by Garbage from Ships (entered into force 31 December 1988) deals with different types of garbage and specifies the distances from land and the manner in which they may be disposed of. The most important feature of the annex is the complete ban imposed on the disposal into the sea of all forms of plastics. In July 2011, IMO adopted extensive amendments to Annex V, which entered into force on 1 January 2013.

The revised Annex V prohibits the discharge of all garbage into the sea, except as provided otherwise, under specific circumstances.

Air pollution and exhaust gases

Annex VI Prevention of Air Pollution from Ships (entered into force 19 May 2005) sets limits on sulphur oxide and nitrogen oxide emissions from ship exhausts and prohibits deliberate emissions of ozone depleting substances. Designated emission control areas (ECAs) set more stringent standards for SOx, NOx and particulate matter. Currently, these are few in number and, while more are predicted, there are none in the pipeline that will impact on the major trade lanes.

Particulate matter, or ‘PM’ as it is often known, consists of solid particles that originate from many sources. They are mostly natural but also come from an extremely diverse range of human activities including cooking, cement production and burning of fossil fuels. Shipping’s main source is, of course, the combustion of fuels in diesel engines. PM has been cited as a major health problem with the smallest size measuring 2.5μm, often referred to as PM2.5, being seen as the most dangerous in this regard. PM from burning fuels include sulphates which are of course partially regulated under Annex VI because of the limitation on sulphur levels in fuels.

Carbon dioxide is not actually classed as a pollutant under MARPOL, but there are rules aimed at reducing emissions, and there is a goal set by the IMO to decarbonise shipping over the next 50 years.

Black carbon

Another substance that is not yet regulated but which is coming under increasing attention is black carbon, especially with regards to Arctic shipping. There are many who believe that the impact is insignificant, but the IMO’s MEPC has decided to pursue the matter.

At MEPC 68 in May 2015, the IMO approved the 2013 ‘Bond et al.’ definition as proposed by the Pollution Prevention and Response Sub-Committee and noting the need for voluntary

black carbon measurement studies to be conducted in order to gain experience with the application of the definition and measurement methods, agreed that protocols for such voluntary measurement studies are needed and invited interested parties to submit relevant proposals/information to the next meeting of its Pollution Prevention and Response Sub-Committee.

Following that decision, the IMO’s interpretation of what constitutes black carbon was that it is a distinct type of carbonaceous material, formed only in flames during combustion of carbon-based fuels. It is distinguishable from other forms of carbon and carbon compounds contained in atmospheric aerosol because it has a unique combination of physical properties.

With respect to this issue, it was also noted that at this stage measures to reduce the impact on the Arctic of emissions of black carbon from international shipping is not possible

MARPOL, with its six annexes and SOLAS between them, regulate many aspects of ship

construction aimed at minimising the environmental aspects of ships. Similarly, MARPOL has influenced many operational practices onboard tankers and every other type of ship.

The Energy Efficiency Design Index (EEDI)

The Energy Efficiency Design Index (EEDI)

In recent years, the issue of climate change, supposedly caused by the emission of greenhouse gases most notably carbon dioxide (CO2), has had an impact on many areas of industrial and social activity around the globe. There are other gases which are considered as causes of global warming but most regulation has been focussed on CO2.

Regulation of CO2 emissions from all sources is primarily a matter for nation states and although there is some degree of consensus as regards regulation of CO2, only the Kyoto Protocol of 1997 (entered into force in 2005) and the 2015 Paris Agreement exist as aspirational commitments with no mandatory force. Individual states and supra-national bodies have in some cases restricted emissions from a variety of sources, but standards and uniform regulations are rare.

The shipping industry is the one exception to this. Although emissions from shipping are excluded from the Paris Agreement, the IMO has adopted regulations applying to new vessels ordered since 2015 that places limits on the emissions of CO2.

CO2 is an inevitable product of the combustion of any fuel containing carbon, which is most fossil fuels including LNG. The air used to support combustion contains oxygen and this will combine with the carbon in the fuel to produce CO2 and other compounds. Any nitrogen in the fuel will be converted to NOx, hydrogen to H2O and sulphur to SOx. Effectively, the only means of reducing CO2 while still burning fuel oil is to burn less, which is the intention of the efficiency regulations developed by the IMO.

In 2011, after extensive work and debate, IMO adopted these mandatory technical and operational energy efficiency measures: The energy efficiency design index (EEDI); ship energy efficiency management plans (SEEMPs) and the energy efficiency operational index (EEOI). They were included in MARPOL Annex VI and entered into force on 1 January 2013.

These measures are aimed at reducing the amount of CO2 produced per unit of work done which is crudely measured as moving one tonne of cargo over a distance of one kilometre.

The EEDI is a non-prescriptive, performance-based mechanism that leaves the choice of technologies to use in a specific ship design to equipment makers, shipbuilders and shipowners. As long as the required energy efficiency level is attained, ship designers and builders are free to use the most cost-efficient solutions for the ship to comply with the regulations.

The EEDI provides a specific figure for an individual ship design, expressed in grams of carbon dioxide (CO2) per ship’s capacity-mile (the smaller the EEDI the more energy efficient ship design) and is calculated by a formula based on the technical design parameters for a given ship. Technology aimed at improving ship efficiency is frequently developed and employed partly to allow newbuildings to meet the EEDI requirements but mostly driven by operators desiring to reduce fuel costs. This is especially so when a vessel has already satisfied the EEDI requirement but the owner continues to add features improving efficiency beyond the compliance level.

EEDI Formula

 A ship’s EEDI rating is devised from the latest version of the original formula shown below which, until broken down into its constituent parts, looks far more complicated than it is. The formula has been amended since it first appeared.

Πfj (ΣPME*CFME*SFCME) + PAE*CFAE*SFCAE + (Πfj*ΣPPTI –Σfeff*PAEeff)*CFAE*SFCAE – Σfeff*Peff*CFME*SFCME
fi * Capacity * Vref * fw

Essentially the formula adds the CO2 emissions of the main engine(s) less any power take out device, to the CO2 emissions of the auxiliary engine(s) and the CO2 emissions due to power supplied by any power take in system then deducts any CO2 emissions saving allowed by ESDs and systems. The result is then divided by the product of the deadweight and the speed of the ship to give a figure that represents grams of CO2 per tonne/nautical mile.

Allowance for reserve power for use in heavy seas is made by calculating main engine power at 75% and a similar allowance against deadweight is made for container ships which rarely carry a full deadweight cargo.

The EEDI regulations lay down a target rating that a ship will not be permitted to exceed so simple mathematical logic dictates that the lower the final figure above the line and the higher the figure below, the greater will be the chance of meeting the required EEDI. That can be achieved in one of several ways.

The first is reducing the power of the main and auxiliary engines which is easily achieved but has led to accusation that the result could be dangerously underpowered ships. Alternatively the deadweight and/or speed could be increased but doing the first would give the same underpowered vessel result and increasing speed could probably only be done by increasing power which would be counter-productive as an increase in power would be needed. All of which leaves reducing the above the line figure by making use of energy saving devices and power take in such as could be provided by waste heat recovery as the best option.

The reference line from which the rating of measured ships will be read has been formulated using data of the existing fleet. As the reference line has been placed in the mid-range of the fleet, meeting the first reduction will likely not present too many problems for shipyards and designers. Reference lines have been drawn up for several ship types beyond the seven categories that will be included from the outset. The ship types first affected are; bulker, tanker, containership, gas carrier, general cargo, reefer and combination carrier. As things stand, agreement has not been reached on an acceptable formula for diesel electric cargo ships or for non-cargo vessels.

EEDI Timetable

As introduced, the EEDI mandated a regular reduction for new ships at five-yearly intervals with the initial framework due to cease in 2025 when ship emissions should be around 30% below those of vessels in service when the regulation began.

EEDI rules apply to ship orders placed on or after January 1, 2013 and to ships delivered after January 1, 2015. The first tranche of ships needed to meet the reference ratings set by the IMO but greater efficiencies were demanded for the future. The initial programme required 10% greater efficiency for ships delivered between 2015 and 2019, 15-20% depending upon ship type and size between 2020 and 2024, and 30% from 2025 onwards.

In 2019, the MEPC decided that some categories of ships were having little difficulty in meeting the scheduled EEDI targets and decided that the 2025 date for Phase 3 could be brought forward by three years. It was also felt that consideration should be given to adding a fourth phase and possibly extending that even further in future. As can be seen from the table of new EEDI limits shown below, the largest container ships will be obliged to be 50% more efficient by 2022 which is well in advance of the targets set as recently as 2018.

Accelerated EEDI Phase 3 Dates and Reductions

Ship type Starting year Reduction rate
 

Gas Carriers

2022 (15,000dwt) 30%
2025 (10,000 – 15,000dwt) 30%
2025 (2,000 – 10,000dwt) 0 – 30%
 

 

Container Ships

2022 (200,000dwt and above) 50%
2022 (120,000 – 200,000dwt) 45%
2022 (80,000 – 120,000dwt) 40%
2022 (40,000 – 80,000dwt) 35%
2022 (15,000 – 40,000dwt) 30%
2022 (10,000 – 15,000dwt) 15-30% **
General Cargo Ships 2022 (15,000dwt and above) 30%
2022 (3,000dwt – 15,000dwt) 0-30%
Refeer Ships 2025 (5,000dwt and above) 30%
2025 (3,000 – 5,000dwt) 0-30%
Combination Carriers 2025 (20,000dwt and above) 30%
2025 (4,000 – 20,000dwt) 0-30%
LNG Carriers 2022 (10,000dwt and above) 30%
Cruise Ships having non-conventional propulsion 2022 (85,000 GT and above) 30%
2022 (25,000 – 85,000GT) 0-30%

 

Entries in Bold Italics represent changed requirement

**actual percentage to be extrapolated depending upon dwt

US Pollution Regulation

US Pollution Regulation

In general, the US follows the requirements of international regulations such as MARPOL but it is also very active in producing additional regulations or even making alternative laws that may be similar but not identical to IMO rules.

Concurrent with the development of MARPOL before emissions to air were included, the US was introducing its own regulations in the form of the Clean Water Act (CWA) passed by the US Congress in 1972 and covering cleaning up the territorial waters of the US. This was done through the National Pollutant Discharge Elimination System (NPDES) permit programme which controls water pollution by regulating sources that discharge pollutants into the nation’s waters.

In most cases, the NPDES permit programme is administered by individual states but for matters extending beyond individual states, the Environmental Protection Agency (EPA) is the governing body.

Section 301(a) of the CWA prohibits the discharge of any ‘pollutant’ unless authorised by an NPDES permit. Shortly after the enactment of the CWA, the EPA issued a regulation that exempted from NPDES permitting “any discharge of sewage from vessels, effluent from properly functioning marine engines, laundry, shower, and galley sink wastes, or any other discharge incidental to the normal operation of a vessel.”

After the turn of the century, environmentalists began legal actions in some states demanding ships should not be exempted from the regulations. In December 2003, the California federal district and appeals courts ruled that the EPA had exceeded its authority when it excluded ships’ discharges from the NPDES permitting system. As a consequence, EPA had to implement a permit system for a wide variety of vessel discharges which would affect all US-flagged vessel and foreign-flagged vessels trading to the US.

The Vessel General Permit (VGP)

The Vessel General Permit (VGP)

This resulted in the introduction in 2008 of the Vessel General Permit (VGP) that would apply to all affected vessels whose owners filed a Notice of Intent. A VGP provides “NPDES permit coverage nationwide for discharges incidental to the normal operation of commercial vessels greater than 79 feet (24m) in length.”

The initial VGP did not cover ballast water and in the fact sheet that it issued as a guide to the VGP, the EPA emphasises that it fought efforts to require incidental discharges to be permitted, not because it dismissed the significance of aquatic invasive species or other environmental hazards resulting from these discharges, but because, in its view, permitting was not the best or most efficient way of addressing the problem. The EPA notes that Congress has already enacted legislation that directed the US Coast Guard, rather than the

EPA, to address and come up with a regulatory programme for the discharge of ballast water and other discharges, and that nothing in the CWA prevented individual states from coming up with regulations to control ballast water discharges under state law. In 2013, a new version of the VGP was introduced which should have run until 2018 but has since been extended.

This permit regulates 27 specific discharge categories and also provides for improvements to the efficiency of the permit process and clarifies discharge requirements. For the first time, the final 2013 VGP contains numeric ballast water discharge limits for most vessels and generally aligns with requirements contained within the 2012 US Coast Guard ballast water rulemaking. Additionally, the VGP contains requirements to ensure ballast water treatment systems are functioning correctly.

The final permit also provides additional environmental protection for certain vessels. For example, certain high-risk vessels entering the Great Lakes must conduct additional management measures to reduce the risk of introducing new invasive species to US waters.

The final VGP also contains more stringent effluent limits for oil-to-sea interfaces such as propeller shaft seals, along with exhaust gas scrubber washwater. EPA has also amended several of the VGP’s administrative requirements, including allowing electronic recordkeeping, requiring an annual report in lieu of the one-time report and annual noncompliance report, allowing combined annual reports for some vessel operators.

In September 2018 it was recognised by the US authorities that the renewal of the VGP regulations would not be completed in time to introduce on schedule. Thus, the existing rules were extended to ships already covered by a VGP and those without one were recommended to apply before the end of the year or risk being excluded from US waters.

On 4 December 2018, the US signed into law the Vessel Incidental Discharge Act (VIDA) (Title IX of the Frank LoBiondo Coast Guard Authorization Act of 2018). VIDA requires EPA to develop new national standards of performance for commercial vessel incidental discharges and the USCG to develop corresponding implementing regulations. Pursuant to VIDA, the 2013 VGP rules continue to apply until EPA publishes future standards and the USCG publishes corresponding implementing regulations under VIDA. Currently this is anticipated in 2022.

EU Pollution regulation

EU Pollution regulation

Arguably, the area with the most environmental regulation is the EU which frequently seeks to impose requirements in excess of those covered under IMO rules or earlier than the IMO deadlines. This is despite the fact that individual member states of the EU are signatories to IMO conventions and codes.

One area where this has been best exemplified is in connection with sulphur levels in fuels. The basic EU legislation for regulating sulphur emissions from ships was Directive i999/32/EC. This was amended by Directive 2005/33/EC, which designated the Baltic Sea, the North Sea and the English Channel as sulphur emission control areas (SECAs) which were approved and adopted by the IMO and limited the maximum sulphur content of the fuels used by ships operating in these sea areas to 1.5%. The fuel standards also applied to passenger ships operating on regular service outside the controlled areas.

From 1 January 2010 when the 2005 directive came into force, as well as reinforcing the limits of sulphur for vessels operating in SECAs and limiting the sulphur content of fuels used ashore in the EU, it also introduced legislation governing the maximum sulphur content

of fuels used by inland waterway vessels and ships at berth in ports which are part of the European Community. The limit for ships in ports was set at 0.1% sulphur, which is the maximum sulphur content of gas oil under ISO standards.

The rules permit some leeway in that they allow ‘sufficient time’ for the crew to complete any necessary fuel changeover operation as soon as possible after arrival at the berth and as late as possible before departure. Ships in port for periods of less than one hour or those that connect to shore electricity supplies are exempt from the requirement. Considering the IMO timeline for cutting sulphur levels, the EU is now only out of step in applying the 0.1% limit to ports outside of the two SECA zones.

Most recently, the EU has been vociferous in complaining that IMO regulation to limit CO2 emissions from shipping are proceeding too slowly. This despite the application of the EEDI. The EU is keen to include shipping in an emission trading scheme but so far has not received sufficient support from the various EU rule making bodies.

Another area where the EU is in advance of the IMO is in the controlled recycling of end of life ships. Most IMO member states prefer this to be managed by the Hong Kong Convention but the EU has already established regulations under which any EU-flagged vessel must be recycled in one of an approved list of recycling facilities. This does not prevent the owner of an EU-flagged vessel from selling the ship to another party for recycling abroad but there are some regional and national sanctions that can act against this. 

Other Pollution Regulation

Other Pollution Regulation

Away from the EU, China’s Air Pollution Control (Marine Light Diesel) Regulation 01/04/2014 introduced a new sulphur content cap of 0.05% for the locally-supplied marine light diesel (MLD). Hong Kong’s Environmental Protection Department has required all ocean-going vessels to use low sulphur fuel, defined in the new legislation as fuel with sulphur content not exceeding 0.5% by weight, when at berth in Hong Kong waters. All such ships must initiate fuel switch upon arrival at berth, complete the switch to low-sulphur fuel within one hour, then use low-sulphur fuel throughout the berthing period and until one hour after departure.

On 4 December 2015, China announced the establishment of further ship ECAs in the Pearl River Delta, the Yangtze River Delta and the Bohai Bay rim area. The regulation applies to all merchant ships navigating, anchored or under operation in the waters of the control areas.

With effect from 1 January 2016, ships were required to follow the requirements current international conventions or local laws/regulations (whichever is stricter) on the emission control of SOx, particulates and NOx. If the port condition allows, ports within control areas may implement stricter requirements than current conventions, regulations such as requiring use of fuel with 0.5% m/m sulphur content or below.

The implementation schedule for the new Chinese requirements was:

  • From 1 January 2016, some ports (if the port condition allows) within the control
  • areas may implement the requirement for use of fuel with 0.5% m/m sulphur content or below when ships are alongside or at anchor. Note that this is for any port within the control area, not just the key/core ports;
  • From 1 January 2017, key/core ports of control areas shall implement the requirements for use of fuel with 0.5% m/m sulphur content or below when ships are alongside or at anchor;
  • From 1 January 2018, all ports within control areas shall implement requirements for use of fuel with 0.5% m/m sulphur content or below when ships are alongside or at anchor; and
  • From 1 January 2019, ships entering into control areas shall use fuel with 0.5% m/m sulphur content or below.

The requirements for ships at berth or at anchor are applicable from one hour after ships are berthed to one hour before departure. Ships may use other alternative measures to reduce emissions, such as shore power, clean energy systems or scrubbers.

More regulations, including restrictions on use of scrubbers, have been announced by Singapore, Norway and Fujairah among others. Apart from Norway, these restrictions are centred on the wash water from open-loop scrubber systems. Effectively this bans the use of scrubbers in the waters concerned unless the scrubber can also be operated in closed loop mode

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