Regional Sulphur Emission Limits at A Glance

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The shipping industry is facing increasing pressure to reduce sulfur emissions as part of broader efforts to improve air quality and protect public health. This detailed guide, authored by Kristin Urdahl and published on July 2, 2024, outlines the various regional sulfur emission limits and compliance strategies for ship operators and crews. While the International Maritime Organization (IMO) has established designated Emission Control Areas (ECAs) with stringent sulfur limits, numerous regions and ports worldwide have implemented their regulations. Compliance actions include ensuring crew awareness, switching to low-sulfur fuels, and verifying the acceptability of exhaust gas scrubbers, reports Grad.

Regional Sulphur Emission Limits at a Glance

Although the shipping sector is now heavily focused on reducing greenhouse gas emissions, the IMO is also working to improve air quality by increasing the number of MARPOL-designated sulfur emission control areas. Many regions, states, and ports enforce strict sulfur emission limits to protect the health of port communities.

Actions for Compliance 

Some regions, states, and ports around the world have implemented their strict sulfur emission limits – and the list of such places is growing. We have therefore provided an overview of sulfur emission regulations that we are aware of, hoping that it may be helpful for ship operators and crews.

However, as new local regulations or changes to existing legislation can be implemented with little notice, and regulatory enforcement strategies vary by region/port, ships’ masters should always seek guidance on local requirements from their agents well in advance of a ship’s intended port call. In addition, ship operators are recommended to:

  • Ensure crews are aware of sulfur emission limitations in their trade jurisdictions and have clear procedures and guidelines to follow.
  • Assess their ships’ fuel options and switch to low-sulfur fuels that meet the relevant sulfur content regulations.
  • When using more than one fuel grade, make sure fuel change-over procedures allow enough time to flush a ship’s fuel oil system of non-compliant fuels before entering a sulfur emission control region.
  • When using exhaust gas scrubbers, confirm with relevant authorities that the use of this technology to reduce a ship’s sulfur emissions is acceptable. The crew onboard ships that operate open-loop scrubbers must also be aware of local restrictions applicable to the discharge of wash water from scrubbing. BIMCO maintains a list of local restrictions on the discharge of scrubber wash water, and the Exhaust Gas Cleaning System Association (EGCSA) provides similar information in its SOx regulation map.

The following overview of requirements can be used as a checklist but should not be considered exhaustive. Future requirements are shown in italics.

MARPOL Designated Emission Control Areas (ECAs) The entry into force of the global 0.50% sulfur limit has not altered the requirements applicable in the ECAs designated under Regulation 14 of MARPOL Annex VI. The 0.10% sulfur limit continues to apply inside the North American, US Caribbean, North Sea, and Baltic ECAs, and will soon apply in the Mediterranean Sea as well. The IMO website displays the exact coordinates of all ECAs currently in force.

The Mediterranean Sea ECA is set to come into force on 1 May 2025. The IMO MEPC 79, in December 2022, adopted amendments to MARPOL Annex VI to establish a Mediterranean Sea ECA. The amendments entered into force on 1 May 2024, but the 0.10% sulfur limit will take effect after a 12-month grace period as per Regulation 14.7 of MARPOL Annex VI.

Furthermore, in March 2024, the IMO MEPC81 approved proposals to designate the Canadian Arctic and the Norwegian Sea as ECAs. The amended MARPOL regulations are up for adoption at the committee’s next meeting in October 2024, with the 0.10% sulfur limit likely to take effect in early 2027.

European Union (EU) 

Under the EU Sulphur Directive, ships at berth in EU ports must use marine fuels with a sulfur content not exceeding 0.10% and complete any necessary fuel changeover operation as soon as possible after arrival at berth and as late as possible before departure.

While guidance on the permissible time for the crew to complete a fuel changeover operation may vary depending on port and ship type, most port authorities allow one hour to complete the operation. Ships are expected to have compliant fuel onboard upon arrival at the berth, and additional delays in the changeover operation caused by time spent procuring and taking delivery of compliant fuel after berthing may not be accepted. Ships that, according to published timetables, are due to be at berth for less than two hours are explicitly exempted from the requirement, and so are ships that switch off all engines and use shore-side electricity while at berth in ports.

‘Ships at berth’ means ships that are securely moored at berth or an anchor in an EU port. With delimitations of each port being established locally, Masters should always confirm with the ship’s local agent whether an outer anchorage is considered to fall within the port limits for sulfur emission compliance.

Turkey

Turkey is not a member of the EU, but its sulfur emission regulation is aligned with that of the EU. Hence, all ships are required to use marine fuels with a sulfur content not exceeding 0.10% while at berth in Turkish ports or operating on Turkish inland waterways. The requirement does not, however, apply to ships transiting the Turkish Bosporus and Dardanelles Straits and the Marmara Sea, unless their transit process, e.g., a stay at an anchorage or in a port whilst awaiting passage, exceeds two hours.

Israel

A new Israeli regulation came into effect on 23 February 2023, requiring ships berthed in Israeli ports to use marine fuel with a sulfur content not exceeding 0.1% by mass. Alternative solutions for compliance, such as exhaust gas cleaning systems (scrubbers), are also accepted. According to the Israeli Ministry of Transportation and Road Safety, the new regulation put in place measures that are similar to those set forth by the EU Sulphur Directive. The regulation applies to ships moored alongside as well as ships anchored within port limits and requires the fuel changeover operation to be completed as soon as possible after arrival at berth/anchorage and as late as possible before departure. For detailed information on the new regulation, please refer to the Israeli government’s Notice MP 27 of 11 January 2023.

Norwegian World Heritage Fjords

From 1 March 2019, the North Sea ECA 0.10% sulfur limit was extended to include the entire Norwegian world heritage fjord area, including the Nærøyfjord, Aurlandsfjord, Geirangerfjord, Sunnylvsfjord, and Tafjord in Western Norway. The exact coordinates of the sea areas included in the heritage fjords are outlined in the Norwegian regulation on environmental safety for ships and offshore units.

Ships of 10,000 gross tonnes and above sailing in the world heritage fjords must also carry environmental instruction specially adapted to the ship and operation in these areas. The environmental instruction shall ensure that the ship is operated as environmentally friendly as possible through technical and operational measures and crew training. The instruction shall as a minimum include operational and technical measures for reducing particulate matter emissions and visible smoke, and speed as a measure for reducing emissions and discharges. The Norwegian Maritime Administration’s guidelines for developing environmental instruction provide additional details.

The Norwegian Authorities have also kicked off a process of drawing up zero emissions regulations for cruise ships, tourist boats, and ferries in the UNESCO-listed West Norwegian Fjords by 2026. DNV provides further insight into the implications of these regulations.

Iceland

On 1 January 2020, the permissible sulfur content of marine fuels used in Iceland’s territorial sea and internal waters, i.e., including the fjords and bays, was reduced from 3.50% to 0.10%, aligning the requirements with those currently in force in the MARPOL-designated ECAs. Iceland’s territorial sea extends 12nm from its coastline. Please refer to the website of the Government of Iceland for additional information.

China

In September 2015, China designated its own domestic ECAs and announced a gradual implementation of requirements covering emissions of air pollutants from ships. At the time of writing, a Coastal ECA has been designated and includes all sea areas and ports within China’s territorial sea, as well as a specially designated ECA in China’s southernmost province, Hainan, the Hainan Coastal ECA. In addition, two Inland ECAs have been designated, which include parts of the Yangtze and Xi Jiang Rivers.

While China currently continues to apply a 0.50% sulfur cap in its Coastal ECA, ships destined for the Yangtze and Xi Jiang Rivers, or the Hainan province must use fuel with a sulfur content not exceeding 0.10% while operating within the defined ECAs. Any fuel changeover operation must be completed before entry into or commenced after exit from an ECA.

The exact coordinates and maps of China’s domestic ECAs are included in our correspondent Huatai Insurance Agency’s Circular PNI1816 of 13 December 2018. It is worth noting that China has declared straight baselines along parts of its coast. This means that China’s baseline, from which its 12nm territorial sea limit must be measured, can lie many nautical miles off its coast.

South Korea

In line with China, South Korea has designated its own domestic ECAs and announced a gradual implementation of requirements covering emissions of air pollutants from ships. The ECAs cover South Korea’s five major port areas: Incheon, Pyeongtaek-Dangjin, Yeosu-Gwangyang, Busan, and Ulsan. Please refer to the Korean Ministry of Oceans and FFisheries(MOF) announcement on 19 August 2020 for details.

At the time of writing, ships are required to use fuel with a maximum sulfur content of 0.10% at all times while operating within the South Korean domestic ECAs. Any fuel changeover operation must be completed before entry into or commenced after exit from an ECA. The Korean Register’s Technical Information of 20 January 2020 includes the exact coordinates for the different domestic ECAs.

Sydney, Australia

Following concerns raised by residents living near the White Bay Cruise Terminal in Sydney, the Australian Maritime Safety Authority (AMSA) implemented a 0.10% limit on sulfur emissions from cruise vessels berthing in Sydney Harbour. ‘Cruise vessel’ means a vessel not having a cargo deck, designed exclusively for carriage of over 100 passengers in overnight accommodation. The limit on sulfur emissions applies from one hour after the vessel arrives at the berth until one hour before the vessel’s departure. Additional details are outlined in AMSA’s Marine Notice No.02/2024.

Panama Canal

Panama is outside of the MARPOL-designated ECAs, and therefore the global 0.50% sulfur cap applies. However, at the time of writing, vessels planning to transit the Panama Canal are required to switch their main propulsion engines, boilers, auxiliary generator engines, and other ancillary equipment from residual fuels to marine distillate fuels when arriving at Panama Canal (ACP) waters. The geographic limits of ACP waters, as well as information on alternative solutions that may be accepted by the Panama Canal Authorities, are set out in its Shipping Notice N-01 “Vessel Requirements,” which is updated annually.

California, USA

Although Californian waters fall within the North American ECA designated under MARPOL Annex VI, the state continues to apply its low-sulfur fuel regulations, the California Air Resource Board (CARB) Ocean-Going Vessel (OGV) Fuel Regulation. Ships operating within 24nm of California’s coastline are therefore subject to two separate sets of sulfur emission regulations.

While both regulations specify a sulfur limit of 0.10%, the CARB OGV Fuel Regulation requires that the fuel also meet the specifications for distillate grades (marine gas oil or marine diesel oil) and does not permit compliance via exhaust gas scrubbers. Additional information is available via the CARB OGV Fuel Regulation website and a detailed comparison of the two sets of regulations that apply in Californian waters can be found in CARB’s Marine Notices 2020-1 and 2020-2.

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Source: Grad