Preparing for the 2020 low sulphur limit

Preparing for the 2020 low sulphur limit

The IMO’s Marine Environment Protection Committee (MEPC) set 1st of January 2020 as entry-into-force date of the 0.50% m/m global sulphur in marine fuel cap at its 70th session on 24th - 28th October 2016.  In preparation for implementation of the limit, extensive work has been carried out by IMO and recently by its Intersessional Working Group that met during 9th -13th July 2018. 

Below is a summary of the outcome of this meeting, as well as a brief update of new developments expected on this issue.

Background

Regulation 14.1.3 of MARPOL Annex VI sets a 0.50% m/m limit of the sulphur content of fuel oil used onboard ships from 1st January 2020, down from 3.50% m/m currently. The limit will remain at 0.10% in the four internationally designated Emission Control Areas (ECAs): the Baltic Sea area; the North Sea area; the North American area (covering designated coastal areas off the United States and Canada); and the United States Caribbean Sea area (around Puerto Rico and the United States Virgin Islands).

At MEPC 71, IMO agreed the scope of work needed to achieve consistent implementation of the 0.50% m/m global limit of the sulphur content of ships’ fuel oil. The Sub-Committee on Pollution Prevention and Response (PPR) has been instructed to explore what actions may be taken to ensure consistent and effective implementation of the 0.50% m/m sulphur limit for fuel oil used by ships operating outside designated SOX ECAs and/or not making use of equivalent means such as exhaust gas cleaning systems; as well as actions that may facilitate the implementation of effective policies by IMO Member States.

To ensure this vital work is completed by 2020, the MEPC approved the holding of an intersessional working group meeting, which was held during 9-13 July 2018.

Draft guidance developed

Draft Guidance on the development of a ship implementation plan for the consistent implementation of the 0.50% sulphur limit under MARPOL Annex VI was finalized at the IMO’s intersessional meeting and is being forwarded directly to the MEPC 73 (22-26 October 2018) so it can be approved and issued as soon as possible. The guidance includes sections on:

  • Risk assessment and mitigation plan (impact of new fuels)
  • Fuel oil system modifications and tank cleaning (if needed)
  • Fuel oil capacity and segregation capability
  • Procurement of compliant fuel
  • Fuel oil changeover plan (conventional residual fuel oils to 0.50% sulphur compliant fuel oil)
  • Documentation and reporting

The meeting agreed to recommend MEPC 73 to invite the Maritime Safety Committee (MSC 100) to consider the outcome of this meeting concerning the safety implications associated with the use of low-sulphur fuel oil, and take action as appropriate noting the initiative of industry organizations to develop industry guidance and possibly training material.

The intersessional meeting also progressed its work on developing a range of other guidance, on impact on fuel and machinery systems resulting from new fuel blends or fuel types; verification issues and control mechanism and actions, including port State control and samples of fuel oil used onboard; a standard reporting format for fuel oil non-availability; and safety implications relating to the option of blended fuels.

In addition, the intersessional meeting developed draft amendments to MARPOL Annex VI on the definition of "sulphur content", "low flashpoint fuel", sampling of fuel oil used onboard, and testing and verification procedure for in-use fuel oil samples; and made progress on development of draft amendments to update the 2009 Guidelines for port State control under revised MARPOL Annex VI (resolution MEPC.181(59)) and Guidelines for onboard sampling for verification of the sulphur content of the fuel oil used on board ships (MEPC.1/Circ.864). These will be further developed and finalized during the next PPR 6 session in February 2019. 

Non-compliant fuel carriage ban

The MEPC 73 is also expected to consider for approval, with a view to adoption draft amendments to MARPOL Annex VI to prohibit the carriage of non-compliant fuel oil.

The exception would be for ships fitted with an approved “equivalent arrangement” to meet the sulphur limit, such as scrubbers, which would allow ships to continue to use “heavy” high sulphur fuel oil. For a ship without an approved equivalent arrangement, the effect of the draft amendment, which would enter into force on 1 March 2020, would be that the sulphur content of any fuel oil used or carried for use on board shall not exceed 0.50%.

Consistent implementation of the 0.50% sulphur limit for all ships will ensure a level playing field is maintained, with the result that the expected improvement of the environment and human health will be achieved.

For further details about challenges arising from low sulphur regulations please see our website publication here:

Members can also find frequently asked questions about the sulphur limit here.

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