2020 sulphur update - outcome of the IMO PPR 6 meeting

The MEPC sub-committee on Pollution Prevention and Response (PPR) met at the IMO in London, 18-22 February 2019. Top of the agenda was the consistent implementation of the 0.50% sulphur limit under MARPOL Annex VI, in force from 1 January 2020. This statutory news contains a summary of topics related to sulphur and the implementation of the 2020 sulphur cap. Items agreed at the meeting are subject to final approval/adoption at MEPC 74 in May 2019.

Relevant for ship owners and managers as well as flag states.

Guidelines for consistent implementation of the 0.50% sulphur limit under MARPOL Annex VI

Following the decision on 1 January 2020 as the effective date for the global 0.50% sulphur limit for fuel oil in use, and the carriage ban for non-compliant fuel from 1 March 2020, a set of guidelines has already been adopted by the IMO to assist involved parties in the preparation, while other guidelines are in the making.

The “2019 GUIDELINES FOR CONSISTENT IMPLEMENTATION OF THE 0.50% SULPHUR LIMIT UNDER MARPOL ANNEX VI” were agreed at this session. These guidelines are intended for use by administrations, port states, ship owners, shipbuilders and fuel oil providers to ensure a consistent implementation of the 0.50% sulphur limit. It will cover, for instance, ship implementation planning, the impact on fuel and machinery systems, verification issues and control mechanisms, the nonavailability of fuel oil, and possible safety implications.

FONAR (fuel oil non-availability report)

Annexed to the abovementioned guidelines is a standard format of a FONAR to be used by the vessel for reporting the nonavailability of compliant fuel to the flag administration and port authorities in the port of destination. The FONAR includes, besides the ship particulars:

  • A description of the voyage plan,
  • Evidence of attempts to purchase compliant fuel,
  • Alternatives for fuel oil supply disruption and operational constraints such as fuel quality issues deemed to cause operational or safety problems,
  • Plans to obtain compliant fuel,
  • A record of previously filed FONARs.

The FONAR is meant to be used under exceptional circumstances, when all reasonable steps have been taken to ensure compliant fuel.

Amendments to MARPOL Annex VI

Draft amendments to Regulation 14 were agreed, introducing the term in-use sample to describe a sample drawn for the FO system and the term onboard sample to describe a sample taken from the bunker tanks. Both samples will serve as a means for port states to determine whether the fuel oil being used or carried for use meets the applicable sulphur requirements when conducting a detailed inspection.

A new retroactive requirement for designating, or if necessary fitting, sampling points to facilitate taking the in-use sample will be included in Regulation 14. This will require ships to designate sampling points no later than the first IAPP renewal survey that occurs 12 months or more after the entry into force of the regulation, expected to be in 2021. The designation of sampling points should consider the “2019 GUIDELINES FOR ONBAORD SAMPLING FOR THE VERIFICATION OF THE SULPHUR CONTENT OF THE FUEL OIL USED ONBOARD (MEPC.1/ Circ.864/Rev.1)”, also agreed at the meeting. It was further noted that additional guidelines to support implementation of the onboard sample taken from the fuel oil tank were needed. In addition, the form of the IAPP certificate will be revised to reflect the sampling points when designated.

Finally, draft amendments to Appendix VI to MARPOL Annex VI were agreed on, revising the verification procedure for fuel oil samples, now covering both the MARPOL delivered sample, the in-use sample and the onboard sample.

Guidance for Port state Control (PSC) on contingency measures to address non-compliant fuel oil

PSC guidance addressing how to deal with non-compliant fuel was discussed, e.g. how to deal with excess fuel after a voyage using non-compliant fuel due to non-availability (FONAR). Clear guidance on this issue may be needed, both for ship owners to have some certainty and PSC to have a degree of discretion over the action to impose. Concrete proposals were encouraged submitted to MEPC 74 to further develop the guidelines.

Application of sulphur limit to emergency equipment

It was also up for discussion whether fuel oil used for emergency equipment such as lifeboats and emergency generators is subject to the MARPOL sulphur requirements. The conclusion was that fuel used for such equipment shall comply as well.

Delivery of compliant fuel oil by suppliers

A joint Draft MSC–MEPC Circular addressing the delivery of compliant fuel oil by suppliers was agreed and will be subject to approval at both MSC 101 and MEPC 74. The circular urges member states to take appropriate action to ensure that fuel oil suppliers under their jurisdiction deliver compliant fuel meeting all requirements in SOLAS Chapter II-2 and Regulations 14 and 18 of MARPOL Annex VI.

PSC guidelines

The draft “2019 GUIDELINES FOR PORT STATE CONTROL UNDER MARPOL ANNEX VI” was agreed in principle with a view to adoption at MEPC 74. However, further amendments may take place at MEPC 74 prior to adoption. The guidelines are meant to provide consistency in conducting PSC inspections and to provide guidance to PSC officers on verifying compliance with the various requirements in MARPOL Annex VI.

Review of the 2015 EGCS (scrubber) guidelines

The review of the “2015 GUIDELINES FOR EXHAUST GAS CLEANING SYSTEMS” was, due to time constraints, postponed one year until PPR 7. However, Appendix 6 of the guidelines addressing how to deal with accidental breakdown and instrument malfunction of scrubbers was deemed a priority matter and proposed as a separate interim circular until the review of the EGCS guidelines is finalized. This interim circular is expected to be completed and adopted at MEPC 74.


Planning is key when preparing for the 2020 sulphur cap, and ensuring compliance of your vessel by 1 January 2020. DNV GL recommends it customers to prepare the ship implementation plans (SIPs) in line with the IMO guidelines. Please note that DNV GL is developing a web-based application to support ship owners in the SIP preparation. It will soon be available in My Services on Veracity. An upcoming Technical and Regulatory News will provide further information on the SIP.


Global sulphur cap web page by DNV GL


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