The bunker fuel supply and availability landscape changed when the IMO’s regulation capping the global fuel sulphur limit at 0.50% was enforced from 1 January 2020. While the technological solutions are many, decisions are hard to take.
Following an availability review of compliant low-sulphur fuel oil in 2020, the IMO decided that the global fuel sulphur limit of 0.50% was to enter into force in 2020. This requirement is in addition to the 0.10% sulphur limit in the North American, US Caribbean, North Sea and Baltic Sulphur Emission Control Areas (SECAs). Vessels that have exhaust gas cleaning systems installed are still allowed to use high-sulphur fuel oil (HSFO).
New amendments ban high sulphur fuels without using scrubbers
A significant amendment to the regulation is the carriage ban for HSFO as of 1 March 2020, from which ships equipped with scrubbers are exempted. While it’s still permitted to carry HSFO as a cargo, it's no longer permitted to have HSFO in fuel tanks unless scrubbers are installed. This enables port state control (PSC) to detain ships carrying non-compliant fuel without having to determine if it has been used or not. Certain ports have banned the use of open-loop scrubbers within their areas. For an overview on local wash water restrictions, please see the map on the Alternative Fuel Insight (AFI) platform (Link)
Regional sulphur limits vary
The European Union Sulphur Directive stipulates a maximum of 0.10% sulphur content for ships in EU ports. In certain EU countries, the Water Framework Directive constrains the discharge of scrubber water. Belgium and Germany have prohibited the discharge of scrubber water in many areas, constraining the operation of open-loop scrubbers. Other EU countries may follow suit, with no common EU practice likely to be agreed.
In China, as of 1 January 2020 vessels operating in the Inland ECAs (Yangtze and Xijiang River) shall use fuel with a sulphur content not exceeding 0.10% sulphur. The same will apply within the Hainan Coastal ECA from 1 January 2022. In addition, discharging wastewater from scrubbers is banned within inland Emission Control Areas (ECAs), port waters and the Bohai Bay waters.
California’s Air Resources Board (ARB) enforces a 0.10% sulphur limit within 24 nautical miles of the California coast. The regulation does not allow any other compliance options than low-sulphur marine gas or diesel oil (DMA or DMB). A temporary research exemption may be granted, allowing the use of a scrubber. The application must be sent before entering California waters. After a formal review of the regulation, California legislators have decided to retain it as an addition to the ECA requirements. Both sets of regulations must be complied with when calling at port in California.
There is a general global trend of stricter local air pollution regulations coming into play.
On demand: Alternative Fuels Online Conference (15 Oct 2020)
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GUIDANCE PACKAGE: Global Sulphur Cap 2020
Download our guidance documents including scrubbers, fuel switch options, checklists and more
Technical and Regulatory News No. 09/2019
2020 Sulphur update - outcome of the MEPC 74
Technical and Regulatory News No. 26/2018
Update on emissions to air regulations for ships operating in Chinese coastal waters
Joint Industry Guidance on the supply and use of 0.50% - sulphur marine fuel
Download the 64-page paper at cimac.com
Alternative fuels and technologies
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Alternative Fuels Insights platform
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Video: 2020 sulphur update – MEPC 74 expert review
Watch our video about the 2020 sulphur update
Guidelines, resolutions and circulars on sulphur
CIMAC WG7 Guideline
MARINE FUEL HANDLING IN CONNECTION TO STABILITY AND COMPATIBILITY
MEPC.305(73)
PROHIBITION ON THE CARRIAGE OF NON-COMPLIANT FUEL OIL FOR COMBUSTION PURPOSES FOR PROPULSION OR OPERATION ON BOARD A SHIP
MEPC.320(74) 2019
2019 GUIDELINES FOR CONSISTENT IMPLEMENTATION OF THE 0.50% SULPHUR LIMIT UNDER MARPOL ANNEX VI
MEPC.321(74) 2019
2019 GUIDELINES FOR PORT STATE CONTROL UNDER MARPOL ANNEX VI CHAPTER 3
MSC.465(101)
RECOMMENDED INTERIM MEASURES TO ENHANCE THE SAFETY OF SHIPS RELATING TO THE USE OF OIL FUEL
MEPC.1-Circ.795-Rev.4
MEPC.1-CIRC.795-REV.4 UNIFIED INTERPRETATIONS TO MARPOL ANNEX VI.
MEPC.1-Circ.864-Rev.1 2019
2019 GUIDELINES FOR ON BOARD SAMPLING FOR THE VERIFICATION OF THE SULPHUR CONTENT OF THE FUEL OIL USED ON BOARD SHIPS
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 PRACTICE FOR FUEL OIL SUPPLIERS FOR ASSURING THE QUALITY OF FUEL OIL DELIVERED TO SHIPS
MEPC.1-Circ.878
GUIDANCE ON THE DEVELOPMENT OF A SHIP IMPLEMENTATION PLAN FOR THE CONSISTENT IMPLEMENTATION OF THE 0.50% SULPHUR LIMIT UNDER MARPOL ANNEX VI
MEPC.1-Circ.880
REPORTING OF AVAILABILITY OF COMPLIANT FUEL OILS IN ACCORDANCE WITH REGULATION 18.1 OF MARPOL ANNEX VI
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 VERIFICATION PROCEDURES FOR A MARPOL ANNEX VI FUEL OIL SAMPLE (REGULATION 18.8.2 OR REGULATION 14.8)
MEPC.1-Circ.884
GUIDANCE FOR BEST PRACTICE FOR MEMBER STATE/COASTAL STATE
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 EGCS FAILS TO MEET THE PROVISIONS OF THE 2015 EGCS GUIDELINES (MEPC.259(68)
MEPC.1/Circ.889
2020 GUIDELINES FOR ON BOARD SAMPLING OF FUEL OIL INTENDED TO BE USED OR CARRIED FOR USE ON BOARD A SHIP