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Ansuman Ghosh
Ansuman Ghosh
Director of Risk Assessment (Singapore)
Date
27 May 2025

Shipping has long been one of the most energy-efficient modes of global transportation. However, despite its efficiencies, the industry has contributed to air pollution. Ships can emit large quantities of sulphur oxides (SOₓ) from burning heavy fuel oil with high sulphur content, and nitrogen oxides (NOₓ) from high-temperature combustion processes in marine engines. 

The environmental impact of these emissions is potentially significant and, recognising these issues, the International Maritime Organization (IMO) established a global framework to regulate emissions from ships under the International Convention for the Prevention of Pollution from Ships (MARPOL). 

Milestones in Sulphur Emissions Regulation 

The cornerstone of the IMO’s efforts was the adoption of MARPOL Annex VI in 1997, which entered into force in 2005. This marked the first global treaty dedicated specifically to addressing air pollution from ships. It introduced a global sulphur cap of 4.5% by mass in marine fuels and, importantly, allowed for the establishment of Emission Control Areas (ECAs) where even stricter standards could be enforced. 

Over the years, these standards have become more stringent. In 2012, the global sulphur limit was lowered to 3.5%, marking an important step towards cleaner shipping. The most significant change occurred with the introduction of "IMO 2020," which, starting January 1, 2020, reduced the allowable global sulphur content in marine fuel to 0.50%. This regulation required ships to switch to very low sulphur fuel oil (VLSFO), marine gas oil (MGO), or install scrubbers to clean exhaust gases. 

In Emission Control Areas (ECAs), the regulations are even stricter. In existing ECAs such as the Baltic Sea, North Sea, North America, the United States Caribbean Sea, and the Mediterranean Sea (starting May 1, 2025), the maximum allowable sulphur content in marine fuels is limited to 0.10%. Ships operating in these zones must use compliant fuels like marine gas oil (MGO) or ultra-low sulphur fuel oil (ULSFO). Alternatively, they can install scrubbers to continue using higher-sulphur fuels. 

Milestones in NOₓ Emissions Regulation 

Alongside the efforts to reduce sulphur emissions, the IMO introduced a tiered approach to address nitrogen oxide (NOₓ) emissions from ship engines. The first level, Tier I, applied to ships built from 2000 onwards and required modest reductions in NOₓ emissions. For ships built from 2011, Tier II standards imposed stricter limits on newer vessels. 

A significant milestone was reached on January 1, 2016, when Tier III emission standards were enforced for ships constructed on or after this date and operating within existing NOₓ Emission Control Areas (ECAs). At that time, the North American coasts and the US Caribbean Sea were designated as NOₓ ECAs. Tier III standards demand up to an 80% reduction in NOₓ emissions compared to Tier I standards. This reduction is achievable through advanced technologies such as Selective Catalytic Reduction (SCR) systems or Exhaust Gas Recirculation (EGR) and also depended on the fuel type. 

In 2021, the Baltic Sea and North Sea also adopted Tier III standards, further tightening controls on NOₓ emissions in these busy maritime corridors. The Tier III standards apply to ships constructed after January 1, 2021 and visiting these areas. "Constructed" refers to ships whose keels are laid or which are at a similar stage of construction.  

The table below outlines the applicable NOx tiers for ships operating within existing Emission Control Areas (ECAs) and those operating outside these areas: 

Upcoming ECAs and NOₓ Control Areas 

The Canadian Arctic ECA and the Norwegian Sea ECA adopted by MEPC 82 

The Canadian Arctic Emission Control Area (ECA) will expand the current North American ECA to include all of Canada’s Arctic waters. Similarly, the Norwegian Sea ECA will extend the existing North Sea ECA, starting at 62° north and covering the Norwegian Exclusive Economic Zone (EEZ) up to 200 nautical miles beyond the territorial sea, reaching the Russian border. 

These amendments will come into effect on March 1, 2026. The regulations for sulphur oxides (SOx) and particulate matter (PM) in both the Canadian Arctic and Norwegian Sea ECAs will be enforced starting March 1, 2027, one year after the amendments take effect. 

For the Canadian Arctic ECA, the NOx regulations are based on the construction (keel-laid) date of January 1, 2025. This means that ships with keels laid on or after this date must use Tier III certified engines when operating in the Canadian Arctic ECA, effective from March 1, 2026. 

In the Norwegian Sea ECA, ships with building contracts placed on or after March 1, 2026, or without a building contract but with keels laid on or after September 1, 2026, or delivered on or after March 1, 2030, must operate Tier III-certified marine diesel engines within the Norwegian Sea ECA. 

North-East Atlantic Ocean ECA 

During the 83rd session of the IMO’s Marine Environment Protection Committee (MEPC 83) in April 2025, the Committee approved the creation of the world’s largest Emission Control Area (ECA). This new zone will cover the Exclusive Economic Zones (EEZs) of Greenland, Iceland, the Faroe Islands, Ireland, the United Kingdom, France, Spain, and Portugal. 

Ships operating in this extensive area will need to adhere to a 0.10% sulphur fuel limit. Additionally, vessels constructed on or after January 1, 2027, must meet Tier III NOₓ standards. 

The formal adoption of this North-East Atlantic ECA is scheduled for October 2025, with the regulations set to take effect by March 2028. This timeline provides the shipping industry with ample time to prepare for the new requirements. 

Conclusion 

The evolution of the IMO’s sulphur and NOₓ regulations highlights a global commitment to balancing the role of shipping in world trade with the urgent need for environmental protection. By tightening emission limits through MARPOL Annex VI and expanding ECAs across key maritime regions, the IMO continues to drive innovation toward cleaner fuels, greener technologies, and a healthier future for our oceans and our communities. 

If you have any queries, please contact Ansuman Ghosh (Director of Risk Assessment), Patrick Ryan (Sustainability Director) or your usual Club representative.