Fuel requirements enforced

SHIP owners face increased compliance costs with lowering of sulphur oxide limit for shipping fuels. January 1, 2020 marked the implementation of the new sulphur oxide limit for shipping fuel imposed by the International Maritime Organisation under the MARPOL Convention, often referred to as IMO 2020.

IMO 2020 intends to improve global air quality and protect the environment through these measures, but concerns have been raised regarding the increased expenses that the maritime sector will face in order to comply with the new standards. This blog post considers the requirements under IMO 2020, how they will be enforced, and the solutions companies may utilise to ensure compliance.

IMO 2020 primarily lowers the limit of the amount of sulphur in fuel oil that can be used to power ships operating outside designated emissions control areas.

The new limit is 0.50 per cent m/m (mass by mass), compared to the previous mark of 3.50 per cent m/m. This significantly reduces the amount of sulphur oxides allowed to emanate from ships.

In order to meet the requirements of IMO 2020, ship owners have three options for their vessels. These are to use one of the following:

 Fuel oils with sulphur content of 0.5% m/m or lower;

 An approved equivalent means of compliance such as scrubbers (otherwise known as Exhaust Gas Cleaning Systems); and

 Non-fuel oil alternatives, such as Liquefied Natural Gas.

Most ships will likely opt to use fuel oils with lower sulphur content at first in order to be in compliance with their obligations.

Monitoring ships’ compliance with IMO 2020, and acting to enforce such compliance, are the primary challenges to its effective implementation.

“Port states” (those states whose territorial waters ships pass through) are obliged to monitor compliance by conducting initial inspections of ships based on documentation, as well as the use of remote devices.

If such monitoring reveals “clear grounds” to conduct further investigation, then more detailed monitoring can take place, including taking samples from the ship.

Guidelines, produced in 2019 (the 2019 Guidelines), state that all possible efforts should be made to avoid unduly delaying a ship for IMO 2020 monitoring.

In practice, however, this will not always be possible, particularly in ports that lack the infrastructure to carry out the process efficiently.