Class and Statutory News

IMO 2020 GLOBAL SULPHUR CAP LIMIT

Jul. 12 2019

Imminent entry into force of the 0.50% sulphur limit on 1 January 2020.

 

IMO 2020 Global Sulphur cap limit

 

 

 

Compliance dates:

 

 > 1st January 2020 - Implementation date of global sulphur limit of 0.50% m/m for the fuel oil standard (regulation 14.1.3 of MARPOL Annex VI)

 

It is reminded that IMO (MEPC 70 – October 2016) agreed to "1 January 2020" as the effective date of implementation for ships to comply with global 0.50% m/m sulphur content of fuel oil requirement, and adopted resolution MEPC.280(70) on the Effective date of implementation of the fuel oil standard in regulation 14.1.3 of MARPOL Annex VI.

Under the new global limit, on 1 January 2020, ships will have to use fuel oil on board with a sulphur content of no more than 0.50% m/m, against the current limit of 3.50%, which has been in effect since 1 January 2012. The new global limit will not change the limits in SOx Emission Control Areas (ECAs) established by IMO, which since 1 January 2015 has been 0.10% m/m.

 

 

 

> 1st March 2020 - Carriage ban of non-compliant fuel oil for combustion purposes for propulsion or operation on board a ship

 

IMO (MEPC 73 – October 2018) adopted complementary MARPOL amendment to prohibit the carriage of non-compliant fuel oil for combustion purposes for propulsion or operation on board a ship - unless the ship uses an alternative compliance method (such as an exhaust gas cleaning system "scrubber") accepted by the flag State as an alternative means to meet the sulphur limit requirement.

 

 

 

The amendment (Resolution MEPC.305(73)) is expected to enter into force on 1 March 2020 :

 

 

NB: This amendment does not change in any way the entry into force date of the 0.50% limit from 1 January 2020. It is intended as an additional measure to support consistent implementation and compliance and provide a means for effective enforcement by States, particularly port State control.

 

 

 

Fuel oil of emergency equipment:

IMO approved MEPC.1/Circ.795/Rev.4 - unified interpretations to MARPOL Annex V which clarify that Regulation 14.1 of MARPOL Annex VI for the prohibition on carriage of non-compliant fuel oil should be applied to the fuel oil of emergency equipment.

 

  

 

Implementation of 2020 Global Sulphur limit

 

For a consistent implementation, IMO (MEPC 74 – May 2016) adopted Resolution MEPC.320(74) - 2019 Guidelines on consistent implementation of 0.50% sulphur limit under MARPOL Annex VI

These Guidelines are intended for use by Administrations, port States, shipowners, shipbuilders and fuel oil suppliers.  They cover the

 

  •     2020 ship Implementation

  •     Impact on fuel and machinery systems

  •     Verification issues and control mechanism and actions

  •     Fuel oil non-availability including the FUEL OIL NON-AVAILABILITY REPORT (FONAR) standard format

  •     Possible safety implications relating to fuel oils meeting the 0.50% m/m sulphur limit 

 

 

Furthermore, IMO (MEPC 73 -October 2018) approved Circular MEPC.1/Circ.878 on Guidance on the development of a ship implementation plan for the consistent implementation of the 0.50% sulphur limit under MARPOL Annex VI.

A ship implementation plan is not a mandatory requirement. A lack of a ship implementation plan or an incomplete ship implementation plan should not be considered as "clear grounds" for a more detailed inspection(reference MEPC.1/Circ.878 paragraph 4). Some Flag State Administrations have strongly and formally encouraged their ship owners to implement a SIP.

 

A ship implementation plan for the consistent implementation of the 0.50% sulphur limit under MARPOL Annex VI is recommended to be developed based on the indicative example as set out in appendix 1 of Circular MEPC.1/Circ.878.

 

 

 

 

 

Related MARPOL Annex VI amendments approved for future adoption – designated fuel oil sampling point(s)

 

Among others, draft amendments have been approved for future adoption (MEPC 75 – May 2020) to require one or more sampling points to be fitted or designated for the purpose of taking representative samples of the fuel oil being used or carried for use on board the ship taking into account guidelines developed by IMO*.

 

* Refer to the 2019 Guidelines for on board sampling for the verification of the sulphur content of the fuel oil used on board ships (MEPC.1/Circ.864/Rev.1).

 

 

 

Retro-active application on existing ships:

For a ship constructed before entry into force of these requirements, the sampling point(s) referred above shall be fitted or designated no later than the first IAPP renewal survey that occurs 12 months or more after the entry into force of this regulation (expected September 2021).

 

 Measures to enhance the safety of ships relating to the use of fuel oil

 

IMO (MSC 101 – June 2019) adopted a resolution providing recommended interim measures to enhance the safety of ships relating to the use of oil fuel.

 

It recommends that SOLAS Contracting Governments, inter alia, take action against oil fuel suppliers not complying with the minimum flashpoint as required by the SOLAS Convention (SOLAS Chapter II-2, Regulation 4.2.1.1).

 

 

 

 Additional guidance for Best practice / Port state Control / Sampling / EGCS

 

 

 

  •            MEPC.1/Circ.875 - Guidance on best practice for fuel oil purchasers/users for assuring the quality of fuel oil used on board ships

  •            MEPC.1/Circ.875/Add.1 – Guidance on best practices for fuel oil suppliers for assuring the quality of fuel oil delivered to ships

  •            MEPC.1/Circ.884 - Guidance for best practice for Member State/coastal State

  •            MSC‑MEPC.5/Circ.15 - Delivery of compliant fuel oil by suppliers

  •            Interim recommendations to enhance the safety of ships relating to the use of oil fuel (MSC.465(101)) [ TO BE PUBLISHED]

  •            MEPC.321(74) - 2019 Guidelines for port State control under MARPOL Annex VI Chapter 3 (2019 PSC Guidelines)

  •            MEPC.1/Circ.881 - Guidance for port State control on contingency measures for addressing non-compliant fuel oil

  •            MEPC.1/Circ.882 - Early application of the approved amendments to the verification procedures for a MARPOL Annex VI fuel oil sample [ TO BE PUBLISHED]

  •         MEPC.1/Circ.883 - Guidance on indication of ongoing compliance in the case of the failure of a single monitoring instrument, and recommended actions to take if the Exhaust Gas Cleaning System (EGCS) fails to meet the provisions of the 2015 EGCS Guidelines (MEPC.259(68))