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.

Guidelines, resolutions and circulars on sulphur

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.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