In accordance with attached the recent Shenzhen government notification, all merchant ships are required to burn low sulphur bunkers (sulphur contents less than or equal to 0.5%) when calling the port of Shenzhen from 1st October...

China - Air emissions - new policy in Guangzhou

The Authority of Guangzhou which is located in Pearl River Delta ECA is drafting air emission rules to be applied to ships entering into port of Guangzhou. The current draft states that the ships engaging in international or coastal voyage, when berthing in Guangzhou port or jurisdiction of Guangzhou (excluding the first hour after arrival and the last hour before departure), shall use the fuel oil with sulphur content not more than 0.5% as of 1 January 2017. We shall continue to monitor this and keep members posted of the further developments.

20/04/16- Air Emissions update in China

Jiangsu MSA has announced and implemented their air emission new rules.

Jiangsu is within the Yangtze river delta ECA, and has two sea ports (Nantong and Yancheng) and 8 ports on Yangtze river (Nanjing, Zhenjiang, Yangzhou, Taizhou, Nantong, Changzhou, Wuxi and Suzhou). Jiangsu MSA air emission new rules provide that from 1 April 2016, ships berthing at the two core ports (i.e. Nantong and Suzhou) must use the bunker fuels with sulphur content of no more than 5000mg/kg, except for the 1st hour after arrival and the last hour before departure. From 1st January 2018, ships at berth of all ports within Jiangsu ECA shall be subject to this requirement. From 1st January 2019, ships entering into Jiangsu ECA water shall be subject to this requirement.

Shanghai MSA issues Notice Control Area on Supervision of Domestics Emission Control Area

On 29 Mar 2016, Shanghai MSA issued Notice on Supervision of Domestics Emission Control Area to specify the requirement for ships when calling Shanghai port, and to provide detailed explanation on those requirements.

We hereby summarize the key points as follows for your kind reference:

1.While ships are berthing in Shanghai Port, the sulphur content of any fuel oil used on board ships (including main engine, auxiliary machinery, boiler and generator) (excluding the first hour after arrival and the last hour prior to departure) shall not exceed 0.5% mm on and after 1 April 2016.

2. According to the Notice, “Berthing in Shanghai "Port” is defined as the period of time when the ship is firmly fastened to a bollard till all the cables of the ship are untied, which excludes anchoring and tying to buoys by the ship.

3. Ships are allowed to apply for an exemption to Shanghai MSA if using low surphul fuel oil is unsafe to ships. The shipping company or agency shall provide  Shanghai MSA  with a written application form and related documents,  and  obtain  the  exemption  after  approval.  (For  detailed circumstances in which ship can apply for exceptions and example of application form, please find the Notice (in Chinese Version and English Version) on Shanghai MSA’s website

4. Ships can take alternative measures equivalent to using low sulphur content fuel, such as shore power, clean energy, exhaust gas cleaning system and etc.

As far as we understand, there have already been a few cases where Shanghai MSA has issued penalty notice to ships for failing to keep fuel sample and fuel supply documents onboard as required.

Zhejiang MSA issues formal notice to implement the decision on higher requirement of fuel sulfur content from 01 April 2016 on 31 Mar 2016

1. According to the notice, ships calling Ningbo-Zhoushan port (including Beilun, Chuanshan, Daxie, Zhenhai, Meishan, Shengsi, Liuheng, Dinghai, Qushan, Jintang) are required to use fuel with sulfur content ≤0.5%mm when staying at berth (from one hour after getting berthed till one hour before departure from berth) from 1st April 2016. Considering the reforming time of fuel change-over system and alternative measures, any violation to the requirement found within two month as from the date when notice come into force, the punitive measures mainly be warning education and correction of breaches.

2. Ships can take alternative measures equivalent to using low sulphur content fuel, such as shore power, clean energy, exhaust gas cleaning system and etc.

Jiangsu MSA issues formal notice to implement the decision on higher requirement of fuel sulfur content from 01 April 2016

1. According to the notice issued on 31.03.2016, ships calling Suzhou and Nantong port are required to use fuel with sulfur content ≤0.5%mm when staying at berth (from one hour after getting berthed till one hour before departure from berth) from 1st April 2016.

2. Ships can take alternative measures equivalent to using low sulphur content fuel, such as shore power, clean energy, exhaust gas cleaning system and etc.

3. The rules of supervision and administration of ECA (including exception and exemption to the requirement) shall be published respectively.

As for other ports within Yangtze River Delta, no intention for the port authorities to require using fuel sulphur content not exceeding 0.5%mm for calling ships at this stage. The local MSA advised us that they will declare the date for implementing the control measures in due time in advance

Owners are recommended to take appropriate measures when berthing at Shanghai, Ningbo-Zhoushan, Suzhou and Nantong port as from 01 April 2016 to ensure satisfaction of relevant requirements and to avoid any delay or penalty to the ship.

Please contact Ioana Gonciari/Helen Huang at the Club if you wish to receive a copy of the Notice.

15/02/16-Air Emissions Update in China

Further to our note China MSA recently issued the Notice on Strengthening the Supervision and Management on Emission Control Areas for Vessels including the Guideline of Supervision and Management on ECAs for Vessels, which provides for the following:

  • vessels using low sulphur bunkers shall keep records in the engine logs about the beginning and ending dates for transferring the bunker fuels, time, latitude and longitude of vessel, the content of sulphur, the amount of use of such fuel with low sulphur, the operating personnel who transfers the fuels and other relevant information. Such vessel shall also prepare a written procedure for transferring the fuels as the part of vessel safety control system.
  • vessels using shore-based power and has made relevant arrangement about such procedure, shall be given priority. By the same token, such vessel shall record the dates and times as well as other related information into the engine log.
  • vessels using liquefied natural gas or other clean energy shall remark the type of such clean energy on the Air Pollution Prevention Certificate issued by vessel survey authority. The vessel powered with mix fuel shall record the amount of use, the date and time of transferring the fuel, and other information within the engine log.
  • vessels using exhaust after treatment device as substitute measures, is required to hold the Product Certificate of Exhaust After treatment Device issued by vessel survey authority, and make such note under the Certificate of Air Pollution Prevention. Similarly, the information related to the date and time of using the said device etc shall be recorded in the engine log.
  • vessels which are unable to comply with the requirements shall timely report to the local MSA and makes a relevant record in the deck log.

Please contact Ioana Gonciari/Helen Huang at the Club if you wish to receive a copy of the Notice.

New Shanghai port anti-pollution regulations with effect 01/06/15

In an effort to reduce air pollution from ships, a new Shanghai port anti-pollution regulation took effect from 1st June 2015. Under the new regulation vessels are required to use only fuels that comply with the city’s quality standard, although the new fuel standard will be established at a later date. Violators will be fined between 10,000 yuan and 100,000 yuan (US$16,120), according to the new regulation.

The Shanghai Maritime Safety Administration has authority to fine Masters and vessel owners that breach regulations on emissions. The Shanghai MSA will stage regular inspections of vessels to encourage compliance with the new rules. Vessels will also be required to use electricity at the city’s ports while docked rather than burning high-polluting fuels for power. 

Members requiring further information should contact:

Helen Huang (Tel:+852 2832 4436 email: helen.huang@thomasmiller.com ) in Hong Kong or

Ioana Gonciari in London (Tel: +44 20 7204 2117 email: ioana.gonciari@thomasmiller.com) 

06/11/15- Lewis & Co CO2 emission information and declaration

Lewis & Co have published a CO2 emission information and declaration on the new European regulation (EU) 2015/757 which adds to the current existing obligations of shipping companies whose vessels call in France.

View the PDF here:

MARPOL Annex VI sets limits on sulphur oxide and nitrogen oxide emissions from ship exhausts and prohibits deliberate emissions of ozone depleting substances. It also contains provisions allowing for special SOx Emission Control Areas (SECAS) to be established with more stringent controls on sulphur emissions.

On the 1st January 2010 the EU implemented its requirement that ships burn fuel of 0.1 per cent sulphur content or less when they are within EU ports or within EU inland waterways.

On the 1st July 2010 this requirement was extended offshore into Emissions Control Areas (ECA) which include the North Sea and the Baltic Sea.

In the United States, the California Air Resource Board implemented a corresponding directive on low sulphur fuels with effect from 1st January. Phase II of that directive, imposing stricter levels of sulphur content, is scheduled for 2012.

The US Emissions Control Area would include the entire coastline of the lower 48 states, south-eastern Alaska and the main Hawaiian Islands, extending 200 nautical miles from the coastline.

(February 2012)

Club publications

China MSA has issued a Guidelines on supervising the implementation of ECA regulations. In accordance with the Guidelines, ships are required to correctly and accurately document bunkers changes on board, keep good record of...

Further to Bulletin 1070 and Bulletin 1078, the Association has received the attached circular from our local correspondent in China.

A new regulation on ship emission control areas of the Pearl river  delta, the Yangtze river delta and Bohai sea waters was issued by the Ministry of Transport of P.R.China.

Further to our article published on 09 April 2015, the Association would like to remind its Members that the Air Pollution Control (Ocean Going Vessels) (Fuel at Berth) Regulation (the “Regulation”) is coming into force on 1st July 2015.

Members will be aware from the Club’s legal briefing on stricter air pollution regulations and subsequent updates that from 1stJanuary 2015 vessels trading in designated areas would have to use fuel on-board with a sulphur content of no more than 0.10%.

IMO FAQs relating to new requirements relating to sulphur emissions that are due to enter into force in emission control areas on 1st January 2015


In our latest Legal Briefing we share the Club's legal expertise and experience on the stricter air pollution regulations of the horizon. By 18th June 2014 all European Union member states are expected to implement directive 2012/33/EU, which brings European national air pollution laws in line with MARPOL Annex VI.

Typical technical problems experienced by shipowners when they are required to use low-sulphur fuels include issues with the supply and storage of low-sulphur fuel, problems with machinery operation when using low-sulphur fuel, incompatibility between fuel types, and difficulties and delays when changing over from one fuel type to another.

The United States Environmental Enforcement Agency (EPA) has announced that it will trial vessel fly-overs to monitor compliance with MARPOL Annex VI.

Policy & convention information

International Maritime Organisation (IMO)

The best starting point in the IMO website is the Marine Environment section. Click on the blue button labelled “Marine Environment” and a dedicated menu item on ‘Air pollution’ appears in a right hand menu. Click on that item to view an extensive overview of MARPOL Annex VI and related items such as the full text of the convention and explanation of the work of the Marine Environment Protection Committee (MEPC).


California Air Resources Board

This organisation has published a series of marine notices regarding the implementation of air emissions regulations. These notices include the requirements for ships to maintain records on fuel use within the regulated area.

European Union

In November 2002, the European Commission adopted a European Union strategy to reduce atmospheric emissions from seagoing ships. A dedicated area on the Commission website provides information on the status and development of its directives on air pollution from ships.


This section includes as special Q& A sheet relating to the Directive 1999/32/EC in regard to use of low sulphur fuels at berth.


Technical information

Lloyds Register
Lloyds Register has recently published two useful magazine features explaining the developments in air pollution regulation with regard to ship design and operation.

A number of guidelines and FAQ documents on the topic are also available in the Document Finder service in Lloyds Register website e.g. ‘At Berth’ requirements FAQs

Germanischer Lloyd

Intertanko advice:
Air emissions for tankers encompass both engine exhaust and emissions from cargoes.

Intertanko maintains resources for its members on responding to the MARPOL VI requirements including a management plan which can be purchased and downloaded online and a policy statement. Access to both these resources is restricted to Intertanko members only and requires a website username and password.

A copy of the brochure for the Intertanko energy efficiency management plan can be found here.

Intertanko policy

Emissions are covered in three areas of their website – Air Emission/Annex VI; Air Emission GHGs and Environment.

Industry developments

Polar Shipping

Legal, navigational and environmental resources, news and updates on the development of polar shipping. Read more

US VRP Compliance

With effect from 30th January 2014 non-tank as well as tankships calling at US ports will be required to submit VRPs.  For Club and other resources to assist in compliance click here

International Environmental compliance

Environmental Compliance resource page collates material in respect of International environmental compliance issues affecting our Members. Information from the Club, Loss Prevention and external resources has been collated in one place for ease of reference.

MLC 2006

The Maritime Labour Convention enters into force in August 2013 - resources, news & advice on implementation can be found in this dedicated section.  READ MORE

International sanctions

Recent guidance & corresponding material in respect of international sanctions against various countries has been updated with respect to temporary easing of sanctions against Iran.  READ MORE


Essential precautions and preparation against piracy, as well as additional information and resources, loss prevention advisories and useful external web links

Emergency Contacts

If you need to call our offices out of hours and at weekends, click After Office hours for a up to date list of the names of the Duty Executives and their mobile phone numbers. 

Ship Finder

This Ship Finder is updated on a daily basis. Members who need to advise the Club of updates to their recorded ships' details should advise their usual underwriting contact.