Ships Fuel Oil Sulphur (International)

From 1 January 2020, the limit for sulphur in fuel oil used on board ships operating outside designated emission control areas is reduced to 0.50% m/m (mass by mass), down from 3.50% m/m (a limit that was in effect since 1st January 2012).

The rules governing this are the regulations for the Prevention of Air Pollution from Ships (Annex VI) under the international MARPOL Convention. Annex VI seeks to control airborne emissions from ships (sulphur oxides (SOx), nitrogen oxides (NOx), ozone depleting substances (ODS), volatile organic compounds (VOC) and shipboard incineration) and their contribution to local and global air pollution, human health issues and environmental problems.

The date of 1 January 2020 was set in the regulations adopted in 2008. However, a provision was adopted, requiring IMO to review the availability of low sulphur fuel oil for use by ships, to help Member States determine whether the new lower global limit on sulphur emissions from international shipping shall come into effect on 1 January 2020 or be deferred until 1 January 2025. IMO’s Marine Environment Protection Committee (MEPC 70), in October 2016, decided that the 0.50% limit should apply from 1 January 2020.

Further information is found in this useful IMO Q&A – here.

MARPOL Annex VI: Fuel Oil Sulphur

From 1st January 2015, the sulphur content in ships’ fuel must be below 0.1 % in Sulphur Emission Control Areas (SECA).

Background

International regulations for pollution from ships are contained in the IMO “International Convention on the Prevention of Pollution from Ships”, known as MARPOL 73/78. On 27 September 1997, the MARPOL Convention was amended by the “1997 Protocol” which includes Annex VI titled “Regulations for the Prevention of Air Pollution from Ships”. In particular, Annex VI regulates emission of sulphur oxides (SOx), nitrogen oxides (NOx) and particulate matter. Annex VI entered into force on 19th May 2005 and in October 2008 the International Maritime Organisation (IMO) adopted a set of amendments to Annex VI of the MARPOL Convention.

The set of amendments to Annex VI of the MARPOL Convention introduces new standards for emission from ships of sulphur oxides (SOx), particulate matter and nitrogen oxides (NOx). The most stringent changes relate to SOx emission.

Reduction of SOx and particulate matter emission is achieved by limiting the maximum sulphur content of the fuel oils used onboard.

Two sets of emission and fuel quality requirements are defined by Annex VI: (1) global requirements, and (2) more stringent requirements applicable to ships in Sulphur Emission Control Areas (SECA).

On the global level, the sulphur cap is reduced initially to 3.50% (from the current 4.50%), effective from 1st January 2012; then progressively to 0.50 %, effective from 1st January 2020 (or in 2025 at the latest), subject to a feasibility review to be completed no later than 2018.

For SECA, the requirements are – from 1st July 2010, the maximum sulphur limit is reduced to 1.00%, (from 1.50%), while from 1st January 2015, sulphur content in ships’ fuel must be below 0.1 %.

Sulphur Emission Control Areas (SECA)

Currently, four regions are identified as Sulphur Emission Control Areas. NB: an Emission Control Area can be designated not only for SOx and particulate matter (PM) emission but also for NOx emission, or all three types of emissions from ships. These SECA are:

1. Baltic Sea area – as defined in Annex I of MARPOL (SOx only);

2. North Sea area – as defined in Annex V of MARPOL (SOx only);

3. North American area – as defined in Appendix VII of Annex VI of MARPOL (SOx, NOx and PM); and

4. United States Caribbean Sea area – as defined in Appendix VII of Annex VI of MARPOL (SOx, NOx and PM).

Marine Fuels Sulphur (EU) Query

EU Directive 2012/33/EU (effective 17th December 2012) is the implementation within the European Union of mandatory IMO rules on marine fuels, further amending Directive 1999/32/EC as regards the sulphur content of marine fuels.

The key elements of the new directive are:

– In line with Annex VI of the MARPOL Convention, the limits for the sulphur content of marine fuels used in designated SO2 Emission Control Areas (SECAs) will be 1% until 31st December 2014 and 0.1% as from 1st January 2015.

– The IMO standard of 0.5% for sulphur limits outside SECAs will be mandatory in EU waters by 2020. This will also be valid for passenger ships operating outside SECAs to which the current regime of 1.5% applies until that date.

NB: currently a general cap does not allow the use of marine fuels with a sulphur content of more than 3.5% by mass within member states territory, with the exception of fuels used by vessels with alternative exhaust gas cleaning systems operating in closed mode.

In line with the MARPOL Convention the directive provides that Member States shall endeavour to ensure the availability of the required marine fuels.

By 18 June 2014 at the latest, Member States will have to amend their existing legislation on the quality of marine fuels to align it with the new Directive.

From 2015 onwards, Member States are asked to ensure that ships use fuels with a sulphur content of not more than 0.1% in the Baltic Sea and the North Sea including the English Channel. Equivalent compliance methods, such as exhaust cleaning systems, are accepted.

From 2020 onwards, ships operating in all other European Sea areas will have to use fuels with sulphur content of 0.5% or less.

The Association of European Vehicle Logistics has a useful summary of this area.