The International Maritime Organisation (IMO) has been working to reduce the harmful impacts of shipping on the environment, setting progressively stricter limits on the sulphur content of fuel oils used by vessels. Failure to comply with these new rules can lead to substantial fines.

Recently, the IMO has adopted a 2008 resolution that introduces a reduced global sulphur cap on marine fuels. The current global limit of 3.5% mass/mass (m/m) shall decrease to 0.5% m/m from 1 January 2020.

While the new regulation has been welcomed by all, there are challenges in ensuring its full compliance and enforcement. This page is dedicated to provide Members with the resources necessary to overcome these challenges.

Search filters
The International Chamber of Shipping have produced a guide aimed at Shipping Companies and Crews on preparing for compliance with the 2020 'Global Sulphur Cap'.
Date: 13/09/2018
Download:
Vessels entering Suzhou and Nantong ECA Area in Yangtze River Delta ECA to use fuel with sulphur content not exceeding 0.5% m/m as from 1 October 2018
Date: 16/08/2018
The Club has recently been notified by our correspondent in Australia, HWL Ebsworth Lawyers, of an increase in fines for those polluting Australian waters.
Date: 19/07/2018
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. 
Date: 22/05/2018
The IMO’s Marine Environment Protection Committee (MEPC) adopted the IMO’s Greenhouse Gases (1)Emissions strategy at its 72nd session, 9 - 13 April 2018.  Below is a brief summary of the events leading to this...

UK Defence Club

The UK Defence Club has published a series of Soundings bulletins on the upcoming Sulphur Cap, each detailing the various issues that its Members will face leading up to the impending deadline.

The Defence Club has already received numerous queries on the cap. Who will have to pay the higher cost of low sulphur fuel? Can an owner be obliged to install scrubbers, in order to avoid having to stem low sulphur fuel? Who will be responsible for compliance with the new regulations?

One big issue Owners face is whether or not to install scrubbers on their vessels and the potential contractual issues that may arise. Who bears the time and costs required for scrubber installation? Who is responsible for maintenance and the consequences of defective scrubbers?  Issues may also arise under ancillary contracts for the finance, installation and maintenance of scrubbers.

Ships without scrubbers, on the other hand, will need to be physically prepared for the 2020 switchover by ridding themselves of any high sulphur fuel on board. This in itself is likely to pose logistical and contractual issues and will require careful planning.

Once the regulations are in force, other issues are likely to arise during the “teething period”. There is a concern that there will be insufficient supplies of low sulphur fuel to satisfy demand and this may result in practical and contractual difficulties relating to fuel unavailability. Some ports have banned “open loop” scrubbers and this could lead to problems where ships are prevented from entering such ports and therefore unable to perform the chartered service. 

Members will need to anticipate these types of issues when negotiating new contracts or amending existing charterparties in advance of 2020. With careful drafting and planning, it may be possible to mitigate the negative impacts of 2020. Nevertheless, this regulatory change is undoubtedly an area for potential dispute.

Members with specific queries regarding the cap should get in touch with their usual Club contact, or can refer to the Club's dedicated IMO 2020 team Philippa Langton and Caroline Avgerinou.

Visit the UK Defence Club's dedicated IMO 2020 webpage for all the latest updates from the Club. Members can download copies of the UK Defence Club Soundings bulletin below.

Sulphur Series 01 - Scrubbing Up

New BIMCO IMO 2020 clauses published

Low Sulphur Fuel


External Resources & News

International Maritime Organisation (IMO) FAQ:
http://www.imo.org/en/mediacentre/hottopics/ghg/documents/faq_2020_english.pdf

International Chamber of Shipping - Compliance with the 2020 'Global Sulphur Cap':
http://www.ics-shipping.org/docs/default-source/resources/ics-guidance-on-implementation-of-2020-global-sulphur-cap---september-2018.pdf?sfvrsn=18

Lloyds List Intelligence Topic Video - Global sulphur cap 2020: risks and challenges:
https://maritimeintelligence.informa.com/resources/product-content/global-sulphur-cap-2020-risks-and-opportunities

Hellenic Shipping News: Industry Experts Weigh Up Solutions For Sulphur Cap 2020:
https://www.hellenicshippingnews.com/industry-experts-weigh-up-solutions-for-sulphur-cap-2020/

IMO MARPOL 2020 Sulphur Clauses Published by BIMCO:
https://bdmlawllp.com/imo-marpol-2020-sulphur-clauses-published-by-bimco/

Coming changes in marine fuel sulfur limits will affect global oil markets:
http://www.bunkerportsnews.com/News.aspx?ElementId=a82bf38b-07d1-4663-a8cf-68d908555c31&utm_source=newsletter&utm_medium=email&utm_campaign=daily

Intertanko: Sulphur cap will take two years to bed in:
https://splash247.com/intertanko-sulphur-cap-will-take-two-years-to-bed-in/

Singapore bans open loop scrubbers:
https://shipandbunker.com/news/apac/363737-egcs-advocates-express-surprise-disappointment-at-singapores-radical-open-loop-scrubber-ban

US cruise ship captain fined in France over fuel sulphur content:
https://insurancemarinenews.com/insurance-marine-news/us-cruise-ship-captain-fined-in-france-over-fuel-sulphur-content/

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.

You are currently offline. Some pages or content may fail to load.