As you are fully aware there are several different rules which limit the sulphur content of used fuel
oil. Beside the IMO MARPOL Annex VI, Rule 14, various countries have their own local rules. All those
different rules are very confusing. This Annex shall give you a small guidance about the local requirements which we are aware of – it however does not claim completeness as probably there are
still regional regulations which might not be known to us. If you are in doubt please check the latest
edition of MARPOL or ask your Agent for special local rules.
A. Global Sulphur Requirements
Except the so called Emission Control Areas and local regulations the global maximum Sulphur content in fuel is 3.5% since 01.01.2012. It is planned to reduce the Sulphur content to 0.5% from
01.01.2020.
B. MARPOL VI, Rule 14 Emissions Control Areas
Inside of all Emission Control Areas a maximum Sulphur content of 0.1% of fuel is allowed since
01.01.2015. Either, HFO, MDO or MGO with 0.1% Sulphur can be used or abatement technologies
like scrubbers can be installed for all combustion engines and boilers. Presently there are the following ECAs:
- Baltic Sea (Gulf of Bothnia, Gulf of Finland, entrance to the Baltic Sea bounded by the parallel
of the Skaw at 57°44’.8 N)
- North Sea (From southwards 62° N, eastwards 4° W, English Channel from eastwards 5° W
and northwards 48°30’ N)
- North America 200 nm from cost, Hawaii, US Caribbean (For exact co-ordinates please check
your MARPOL book Appendix VII)
C. Local Sulphur Regulations
In addition to the MARPOL ECAs there are different local rules in regards to the limitation of the sulphur content:
1. Europe as per EU Directive 2012
Ships at berth in the European Union ports shall not use marine fuels with a sulphur content exceeding 0,10 % by mass, allowing sufficient time for the crew to complete any necessary fuel-changeover
operation as soon as possible after arrival at berth and as late as possible before departure. Member
States require the time of any fuel-changeover operation to be recorded in ships' logbooks.
Same shall not apply, whenever, according to published timetables, ships are due to be at berth for
less than two hours or to ships which switch off all engines and use shore-side electricity while at
berth in ports.
2. Iceland
In line with the EU requirements vessels at berth shall not use marine fuels with a sulphur content
exceeding 0,10 % by mass, allowing sufficient time for the crew to complete any necessary fuel-
changeover operation as soon as possible after arrival at berth and as late as possible before departure.
This regulation was published in Icelandic only, therefore please verify with your agent once a port
call is scheduled.
3. Italy
Recently there has been a case where one of our vessels had to use fuel oil with maximum 0,1% sulphur when approaching Italy. Unfortunately we were not yet able to find the exact regulation in English language and therefore every vessel must get in touch with the agent prior arrival in order to determine which fuel oil has to be used in the territorial waters of the respective port(s).
4. Turkey
Every kind of boat and fishing boats operating in internal waters and all boats moored or anchored
within port boundaries shall have to use bunkers with a maximum sulphur content of 0.1% after January 1st 2012. In this context, the regulation stipulates that “ships must complete their bunker replacement operations within the shortest time possible after arrival at a port and as late as possible
after departure from a port.” The obligation of berthed ships to use bunkers with a maximum sulphur
content of 0.1% by mass shall not apply if the ship in question is or should be berthed for less than
two hours according to the published tariff.
Ships passing Turkish Straits without calling to Turkish Ports shall not be subject to the rule of using
bunkers with sulphur content not exceeding 0.1% by mass, as long as they proceed without calling to
any Turkish Port.
If you are in doubt with above please contact your local agent for clarification.
5. California USA
Since 01.01.2014 California limits for all Ocean going vessels the Sulphur content to 0.1% of MGO and
MDO. Important is that only Marine Gas Oil MGO or Marine Diesel Oil MDO can be used. So called
Ultra Low Sulphur Fuel Oils cannot be used. As per bunker delivery note the fuel must be MGO or
MDO. This regulation might be reviewed or even we can apply for exemptions if we want to use other fuel or a scrubber.
6. Hong Kong
A new Air Pollution Control Regulation has been issued which mandates ocean-going vessels to use
clean fuels while berthed in Hong Kong. This regulation takes effect on 1 July 2015. It requires to use
compliant fuel i.e. low sulphur fuel with sulphur content not exceeding 0.5% by weight; or liquefied
natural gas; or any other fuels while at berth in Hong Kong, except during the first hour after arrival
and the last hour before departure.
This regulation does not apply for vessels that only sail across the waters of Hong Kong without
berthing, or to ships that do not carry compliant fuel but enter the waters of Hong Kong solely for
safety reasons.
7. China
China has established three domestic emission control areas (Pearl River Delta, Yangtze River Delta
and Bohai-rim Waters) and announced a gradual strengthening of requirements concerning emissions of air pollutants from ships.
According to our information ships in the area of Pearl River Delta and Bohai Rim must use fuel with
a sulphur content not exceeding 0.50 per cent whilst berthed at any port within the DECAS (Domestic
Emission Control Areas).
Previously the same applied also for the Yangtze River Delta but they have changed their requirements with effective date of 1st of October 2018. As of this date vessels must burn fuel with a sulphur
content not exceeding 0.5% at all times while operating inside the Yangtze River Delta ECA. Hence,
from this date, any fuel change-over operation should be completed prior to the entry into or commenced after exit from the Yangtze River Delta ECA and not only at the berth.
From 1st of January 2019 this also will be adapted for the Pearl River Delta and Bohai Rim.
Pearl River Delta: 0.5% while at berth at all ports as of 1st January 2018
0.5% for all operations in the area as of 1st January 2019
Yangtze River Delta: 0.5% for all operations in the area as of 1st October 2018
Bohai Rim: 0.5% while at berth at all ports as of 1st January 2018
0.5% for all operations in the area as of 1st January 2019
Please note that there have been several changes in the past and the wording of the regulations is
vague. Further most of them are being published in Chinese only and translations are missing. Therefore please make sure to check the actual local requirements with your agent.
Local cities and relevant authorities continue to evaluate the implementation of the new regulation
and the control measures to be taken. Updates on same will follow once these are finally published.
Applicable port requirements at any given time should be verified with the agent or port authorities
before arrival.
8. Taiwan
As of 1st of January 2019 all ocean-going ships entering Taiwanese international commercial ports will
be required to use a fuel oil whose sulphur content does not exceed 0,5% by weight. As per our information the applicable ports will be: Keelung, Taichung, Kaohsiung, Hualien, Taipei, Suao and
Anping. In any case please kindly verify this with your agent before arrival to Taiwan.
9. Panama Canal
Vessels operating on heavy fuel oil shall change to light fuel (MGO/MDO) prior to entry into water
bodies under the responsibility of the Panama Canal Authority. The outer boundaries of Canal waters
are those of the Pacific and Atlantic anchorage areas, as indicated in nautical charts DMA No.21603
and DMA No.26068 respectively.
All vessels must switch from Heavy Fuel (even if it meets the 3.5% sulphur content cap) to Light Fuel
(MGO or MDO) meeting all IMO specifications, especially the cap on sulphur content which is also set
at 3.5% in the Panama Canal.
Alternatively vessels can burn one of the following products under the conditions stated below:
- Heavy fuel with less than 3.5 % sulphur content provided the vessel is equipped with an approved exhaust gas cleaning system (scrubber).
- Hybrid fuel as defined in the Advisory. No scrubber is required for burning this type of fuel.
This requirement is in place since 1 January 2001 already, but apparently has only rarely been followed by the industry.
Following exceptions in regards to the usage of Light fuels can be made:
- Vessels that need to anchor at the Pacific or Atlantic Anchorages prior to their transit through
the Panama Canal are allowed to use heavy fuel to operate their auxiliary engines, boilers
and other ancillary equipment during their stay at anchorages. Vessels shall change over to
light fuel operation at least two (2) hours prior to the scheduled pilot time for their Canal
transit.
- Vessels that solely will visit either the Pacific or Atlantic port terminal and will not transit may
be allowed to proceed to and from the port terminal on heavy fuel oil, including the main
propulsion engines.
Additional information can be found in the Panama Canal OP NOTICE TO SHIPPING No. N-1-2017, Advisory to Shipping No. A-04-2017 and A-15-2015 which can be provided to you upon request.
D. Fuel Change Over and Documentation
Upon entry into the regulated area, the ship’s crew has to ensure that fuel used in any consumer
onboard has a sulphur level not exceeding 0.10 %. In order to calculate the time needed for change
over you have received a Fuel Change-Over Manual as well as its calculators. The Fuel Change-Over
Manual must be kept on board as per MARPOL Requirement.
Completion of fuel change-over has to be recorded in an appropriate log book with respect to date,
time and position as well as the volume of low sulphur fuel oil remaining in each tank.
Please note that for ships with single service and settling tanks; the fuel change-over can take 2-4
days. In relation to MARPOL Annex VI, the ship crew has to ensure that they:
Receive and file compliant Bunker Delivery Notes (BDN) from suppliers for minimum 3 years;
Receive and store a compliant MARPOL sample from suppliers until the fuel has been substantially consumed but not less than 12 months. Unless the Port State in question has ruled otherwise, the MARPOL sample is to be taken at the ship manifold, using a continuous drip sampler throughout the duration of the bunkering;
Maintain a record of MARPOL samples.
E. EU Directive 2015 and Sample Inspections
As from 2015 member states are obliged to carry out MARPOL Inspections where BDNs and Log
Books will be sighted of min. 10% of all vessels entering a port of a member state. Sampling taking is
not compulsory in 2015, the member states decide on its own.
As from 1 January 2016 bunker sampling and/or quality of bunkers of bunker samples available on
board is compulsory. The frequency depends on the geographical scope of an ECA or Non-ECA.
- From 40% of the vessels samples have to be taken if the member state borders entirely on
an ECA
- From 30% samples have to be taken when the member state partly borders to an ECA
- From 20% samples have to be taken if the member state does not border to an ECA (this increases to 30% from 2020 on when the SOx limit value of 0.5% is in force in EU waters)
Results of those inspections will be treated like a PSC and maintained in the applicable database
“Thetis” at EMSA (European Maritime Safety Agency). Thus utmost attention has to be paid on regular bunker samples taken, the quality of bunkers and finally correctness in Log Book documentation.
The sample will be taken inlet to engines. Therefore a carefully and complete change over from 3.5%
to 0.1% must be assured. Also the 0.1% fuel shall not be contaminated with 3.5% fuel.