IMO Amendments Take Effect Ahead of 2020


  • IMO regulatory amendments and North Sea and Baltic Sea NOx ECAs entered into force on the first day of 2019
  • The BDN amendments require shipowners and operators to carry a certified declaration
  • Amendments address the use of fuel oil that does not meet low sulphur limits
  • Bunker supplier can deny to provide HSFO, if he doubts a buyer’s ability to use HSFO compliantly.
  • IMO requires ships of 5,000 gt and above to begin collecting and reporting data on their fuel-oil consumption.

Several agreed amendments to IMO regulatory schemes have entered into force as of the first day of 2019, says an article published in Marine Propulsion.

The International Maritime Organization said that amendments to the bunker delivery note relating to the supply of marine fuel oil to ships with alternative mechanisms to address sulfur emissions requirements entered into force on January 1, 2019.

Bunker delivery note amendments

According to a Platts report, the bunker delivery note amendments that came in on 1 January this year require shipowners and operators to carry a certified declaration.

The certificate need to be signed by a representative of their fuel oil supplier. This is to confirm the sulphur content of the fuel oil supplied meets relevant sulphur limits.

Alternative compliance method

The amendments are intended to address the use of fuel oil that does not meet low sulphur limits.

Fuel oil that does not fall under IMO global limit on sulphur is permitted in ships which uses ‘alternative compliance methods’ under regulation 4 of MARPOL Annex VI to reduce the sulfur oxide emissions of the ship in order to comply with MARPOL requirements, the IMO said.

This may be abatement technology such as an exhaust gas cleaning system (EGCSs or scrubbers), if accepted by the flag state of a ship as an alternative means to meet the sulfur limit requirement, it said.

Regulation for non-compliant fuel

According to the IMO regulation, the Bunker Delivery Note should include declaration signed and certified by the fuel oil supplier’s representative that the fuel oil supplied confirms to the regulation 18.3 of MARPOL Annex VI and that the supplied fuel does not exceed the limit outside emission control areas under regulation 14.1; the limit in ECAs under regulation 14.4;

The fuel oil supplied to shipowners and operators using non-compliant fuel must not exceed “the purchaser’s specified [sulphur] limit value, on the basis of the purchaser’s notification that the fuel oil is intended to be used:”

  1.     In combination with an equivalent means of compliance [i.e. scrubbers]; or
  2.     Is subject to a relevant exemption for a ship to conduct trials for sulphur oxides emission reduction and control technology research.

Bunker supplier’s conern

A bunker supplier can choose not to provide HSFO, if he has concerns about a buyer’s ability to use HSFO compliantly.

But there is no obligation on them to make checks, IBIA said.

“Policing of ship compliance is up to port state control officers and it is quite simple for them to do so in this case: if they check the [bunker delivery note] and it shows that the ship has purchased fuel with sulfur above 0.50% after January 1, 2020, they should immediately ask for the ship’s IAPP [International Air Pollution Prevention] supplement detailing if it has an equivalent arrangement approved in accordance with regulation 4.1 (or an exemption under Regulation 3.2) which allows the ship to use (or carry for use post 1 March 2020) fuel with sulfur above 0.50%,” IBIA said.

North Sea and Baltic Sea NOx ECAs

Amendments designating the North and Baltic Seas as emissions control areas (ECAs) for nitrogen oxides (NOx) entered into force on 1 January.

The new ECA rules in the regions will come into effect on 1 January 2021, subjecting vessels to IMO’s Tier III NOx emission limits.

Mandatory fuel oil data collection and reporting come into effect

From 1 January 2019, IMO requires ships of 5,000 gt and above to begin collecting data on their fuel-oil consumption.

The Marpol Annex VI regulation on collection and reporting of ship fuel oil consumption data that came into force in March 2018 requires the vessels to collect consumption data for each type of fuel oil they use among other data points.

Vessels report the aggregated data each calendar year and the flag state checks the data collection is compliant and issues a Statement of Compliance to be held on board the vessel and presented during inspection.

Flag states also transfer the data into the IMO Ship Fuel Oil Consumption Database from which IMO will produce an annual report to the MEPC, summarising the data collected.

The data collection system is one of the measures designed to support IMO implementing its Initial Strategy on Reduction of GHG Emissions from Ships, adopted in 2018.

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Source: Marine Propulsion, Platts


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