ARTICLE
22 October 2018

The 2020 Sulphur Cap

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Fenech & Fenech Advocates

Contributor

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On 27 October 2016 the IMO agreed to implement a 0.50% mass by mass (m/m) sulphur cap on all marine fuel by 2020, from the current 3.50% m/m
Malta Transport

On 27 October 2016 the IMO agreed to implement a 0.50% mass by mass (m/m) sulphur cap on all marine fuel by 2020, from the current 3.50% m/m.

This decision is arguably one of the industry's most significant developments since the invention of the steam engine – with over 90% of the international trade conducted by sea and waterways, the sulphur cap is an ambitious environmental measure that presents several transitional issues that will affect approximately 70,000 ships.

Issues revolving around the implementation of the sulphur cap have formed the core of the IMO's Marine Environment Protection Committee (MEPC) meetings and draft guidelines to date, with the aim to help ensure the consistent implementation of the MARPOL regulation.

The sulphur content of any fuel oil used on board ships is targeted at shipping activities outside of the four internationally designated Emission Control Areas (ECAs), where the sulphur limit has been capped at 0.1% since January 2015.

The IMO MEPC meetings continue to consider and decide on other preparatory and transitional issues that need to be addressed before 2020. These include the use of Fuel Oil Non Availability Reports (FONAR), the inclusion of a ban on the carriage of non-compliant fuels and the development of standards for the new 0.5% fuels that might be used to comply with the sulphur cap.

Alternatives to low sulphur fuel oil are in fact available to comply with MARPOL Annex IV, such as gas and methanol as a fuel – other alternatives include using approval equivalent methods, such as exhaust gas cleaning systems or "scrubbers", which clean the emissions before they are released into the atmosphere.

Exceptions to the sulphur cap are provided for in certain situations, which inter alia, include:

  • safety of the ship;
  • saving life at sea;
  • damage to a ship or its equipment; and
  • sea trials testing ship emission reduction and control technologies, amongst others.

The IMO MEPC meetings reconvene later this month at MEPC 73 where further discussions on transitional issues and mitigation measures will be held.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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