Non-Compliant Fuel Carriage Ban
From 1st March 2020, carriage ban on non-compliant fuel oil will enter into force. This means that ships can no longer carry non-compliant fuel on-board unless the same is carried as cargo. Any non-compliant fuel remaining on-board must be removed from the vessel’s fuel tanks failing which there will be a de-facto non-compliance even if such fuel was not intended to be used for consumption. The Carriage Ban does not apply to vessels fitted with operational scrubbers.
Plans to dispose such non-compliant fuel must have started well in advance, as this would have entailed careful planning between the vessel’s owner and charterer working out a bunkering strategy keeping in mind fuel price, supply timing, machinery fuel consumption patterns and subsequent disposal. Disposal plans must have considered among others, appropriate timing, ships trading pattern and disposal port regulations. It is a fact that not all ports allow disposal and there might be many ships seeking to dispose at the same time.
Keeping in mind the carriage ban, there might be many scenarios whereby a ship may end up with non-compliant fuel on board post 1st March 2020. It can be due to delays in the shipyard where a scrubber is scheduled to be fitted or, if the scrubber is already installed, it can malfunction and become inoperable. It can also occur when a vessel receives non-compliant fuel due to non-availability of compliant fuel at the bunkering port, or it is also possible that the has received compliant fuel oil as per the Bunker delivery note (BDN) but subsequent testing has revealed that the fuel oil is non-compliant. There could also be situations where certain operational limitations have put the vessel in a position where she is unable to discharge the non-compliant fuel prior the carriage ban deadline. Each case will need careful consideration and if non-complaint fuel remains on board after 1st March, it is advisable to follow MEPC.1/Circ.881, consulting the port state and flag state to agree on a solution.
Members can find all the latest developments on our dedicated resource page.
39223 MEPC1Circ881GuidanceforportStatecontroloncontingencymeasures4 (39 KB)
Source Risk Assessor
You may also be interested in:
Legal Update: The IMO Marine Environment Protection Committee (MEPC) 74th Session - Summary
The IMO Marine Environment Protection Committee (MEPC) met for its 74th session at the IMO Headquarters in London from 13-17 May. Below is a summary of the outcome from this meeting on the following topics
China MSA announces their Implementation Plan of 2020 Global Marine Fuel Oil Sulphur Limits on 23 October 2019
In order to effectively implement the IMO's global regulations on the limits of the sulphur
content of marine fuel oil, China MSA announced the Implementation Plan of 2020 Global
Marine Fuel Oil Sulphur Limits (hereinafter referred to as “The Plan”) on 23 October 2019.
The Plan specifies the requirements on the ships’ use and carriage of fuel oil as well as
alternative measures, reporting of information about the ships’ use and carriage of fuel
oil, disposal of ships’ non‐compliant fuel oil, prior registration of bunker suppliers, as well
as MSA’s supervision and administrative measures, etc. The Plan also includes the format
of the Fuel Oil Non‐Availability Report (Hereinafter referred to as “FONAR”).
Since early 2019, vessels calling in Dakar have been at an increased risk of Customs fines and/or detention for cargo shortages or overloading.