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Web alert: MARPOL and Annex VI amendments – sulphur reduction

14 October 2014

A guide to sulphur requirements in the EU from 1 January 2015
In 2008 the International Maritime Organisation (IMO) adopted amendments to the MARPOL Convention Annex VI. These amendments introduced a gradual reduction of the sulphur content of marine fuels. From 1 January 2012 the global sulphur cap will be reduced, first to 3.50% (from 4.50% in 2008) and then, subject to a feasibility review, progressively to 0.50% from 1 January 2020 or 2025 at the latest.

Emission Control Areas (ECAs) requirements are stricter. On 1 January 2010 the sulphur limit was reduced to 1.00%, and as of 1 January 2015, the limit will be further reduced to 0.10%. It is this last requirement that has caused most concern within the EU. The ECAs are defined in Annexures of MARPOL and include the European waters of the Baltic Sea (since 2005) and the North Sea (since 2006). By June 2014, all EU member states were expected to implement directive 2012/33/EU to bring European national air pollution laws in line with MARPOL Annex VI.

Annex VI Regulation 14
Regulation 14 provides the limit values, and the means to comply with the same. Any vessel that operates both outside and inside ECAs should operate on different fuel oils in order to comply with the respective limits. This means that, before entry into the ECA, the vessel must change over to ECA compliant fuel oil. Each vessel in this position has to carry written procedures including instructions for:

  • recording quantities of the ECA compliant fuel oils on board;
  • recording the date, time and position of the ship when either completing the change-over prior to entry or commencing change-over after exit;
  • entries to be made in a logbook as prescribed by the vessel’s flag state (in the absence of such prescription, entries can be made in the vessel’s Annex I Oil Record Book).

The first level of control under regulation 14 is the actual sulphur content of the bunkered fuel oil. The value should be stated by the fuel supplier on the bunker delivery note and tested where necessary. The sulphur content will therefore be directly linked to the fuel oil quality requirements under regulation 18 which are noted on the bunker delivery notes.

The second level of control is the ship’s crew who must ensure ECA compliant fuel oils are kept separately and are not mixed with other oils with higher sulphur content in transfer operations.

Annex VI regulation 14, 5.1.1 does allow national administration to approve different means of compliance so long as they are at least as effective as the means prescribed in regulation 14. These must be approved by the appropriate administration under IMO guidelines.

Compliance & Documentation requirements
Once an initial or renewal survey has taken place and compliance with Annex VI has been verified, an International Air Pollution Prevention Certificate will be awarded to every ship over 400gt. This is subject to the vessel being registered under a flag state signatory to the MARPOL Convention. Under regulation 18, appropriate authorities may require the ship to provide logbooks of fuel oils and bunker delivery note as well as this certificate if the ship is found not to comply with Annex VI standards. The logbook and delivery note must be accompanied by a fuel sample, sealed and signed by the master and kept for at least 12 months.

EU Sulphur Directive
The amended EU Sulphur Directive 2012/33/EU will undoubtedly impact shipping in Northern Europe, especially post 1 January 2015 when the Directive will require ships sailing the North European ECA to use bunker oil with a maximum of 0.10% sulphur.

Member states are required to implement ‘effective, proportionate and dissuasive’ penalties for violating the sulphur provisions. In most member states, the violation of the Directive’s laws will result in stringent fines and other consequences as determined by the member state.

One of the industry’s main concerns is that fuel with 0.10% sulphur content is significantly more expensive than oil with 1.00% sulphur content. The EU Commission proposes the installation of ‘scrubbers’ to reduce the impact. Scrubbers are devices that use water to wash unwanted substances from an exhaust gas stream which allow ships to continue to use heavy fuel oil, without violating the environmental and legislative standards.

Whilst scrubbers seem to be an effective method, they are still expensive. Furthermore, not all member states allow water discharge close to their shores so the scrubber solution is one that still needs clarification within the European Union and its maritime industry. The shipping industry is hence continuously trying to find solutions that will reduce air pollution with equally effective means.