Outline of the regulations
The regulations limiting the sulphur content of marine fuels for ships are specified in Regulation 14 (Sulphur Oxides (SOx) and Particulate Matter (PM)) of Annex VI of MARPOL 73/78, in which the sulphur content limit has been gradually strengthened. The limit for open sea area were strengthened from 3.50% to 0.50% on 1 January 2020.
In this situation, shipping companies and shipyards are considering by which means they comply with the regulations: using marine fuel oil with a sulphur content complying with the regulations (compliant fuel), installing SOx scrubber, or converting to alternative fuels such as LNG.
1. Schedule of implementation of sulphur cap and requirements
The limit of the sulphur content has been gradually strengthened in open sea area as shown in below figure.
For any ship of 400 gross tons or above engaged in international voyages, bunker delivery notes and the corresponding fuel oil samples (more than 400ml) are to be retained on board ships for more than 3 years and for more than 12 months respectively in accordance with Regulation 18 of MARPOL Annex VI. Guidelines for sampling and storage of fuel oil are provided in IMO Resolution MEPC.182(59).
From 1 March 2020, the carriage of fuel oil with a sulphur content higher than 0.5 % (excluding ships operating scrubbers) has been prohibited.
Also, the limit of the sulphur content has been gradually strengthened in Emission Control Area (ECA) as shown in below figure.
At present, the following sea areas are designated as the ECAs.
- The Baltic Sea area
- The North Sea area
- The sea area within 200 nautical miles of the United States/Canadian coast
- The United States Caribbean Sea area
The regulations stipulate that ships that enter and exit the ECA and that use two or more marine fuel oils should have written procedures for completing the switch of the fuel oils in accordance with the regulations on board. When switching the marine fuel oils, it is necessary to record the amount of low sulphur fuel oil in the tank together with the date, time and location in the logbook as prescribed by the Flag Administration at the time of the completion of switching before entering the ECA area as well as at the time of the start of switching after the leaving ECA area.
Compliant fuel oil
1. Guidance for onboard use of Compliant Fuel Oil with SOx regulation from 2020
ClassNK assessed the needs for further implications for the safe use of the compliant fuel oil from the perspectives of five properties, that is, Compatibility, Low viscosity, Cold flow properties, Cat-fines, and Ignition/Combustion quality. ClassNK wrapped up the potential changes and potential risks associated with the five properties, and also reviewed mitigation measures against these risks, and issued as this Guidance.
The Guidelines can be downloaded from “ClassNK MyPage” after the registration.
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2. Appraisal facts of fuel oil tank cleanings, etc.
ClassNK provides appraisal services related to change to the fuel oil with 0.50% sulphur limit e.g. such as fuel oil tank cleaning before bunkering the 0.50% compliant fuel oil, etc. according to the request. In case where you request the appraisal facts, please contact ClassNK Survey Department.
- E-mail: email@example.com
- Tel: +81-3-5226-2027
3. Fitting or designating of fuel oil sampling point
In case where modifications are made for fitting fuel oil sampling valves, etc. for the purpose of taking samples of the fuel oil being used on board the ship, plan approval is necessary. Fuel oil piping diagram concerning the modifications are to be submitted to ClassNK Machinery Department prior to the modification works.
Also, ClassNK conducts the approval of the plans (e.g. Fuel oil piping diagram) in which fuel sampling points are only designated upon request.
Please submit the plans to ClassNK Machinery Department by NK-PASS, E-mail or mail with the information of mailing address and billing address at the time of plan submission.
- E-mail: firstname.lastname@example.org
- Address: 3-3 Kioi-cho, Chiyoda-ku, Tokyo 102-0094, Japan
4. Precautions concerning change-over
ClassNK issued a booklet titled “Precautions concerning change-over to 0.50% sulphur compliant fuel oils”.
The purpose of this booklet is to provide crew members on board ships going to bunker and use the compliant fuel oils with information focusing on the "compatibility" and "cold flow properties" of such fuels as well as the risks associated with such fuels and the measures to be taken to mitigate such risks.
The booklet can be downloaded from the below.
Exhaust Gas Cleaning Systems
1. Guidelines for Exhaust Gas Cleaning Systems
ClassNK issued the Guidelines for Exhaust Gas Cleaning Systems to add the explanation of Guidelines for Exhaust Gas Cleaning Systems adopted by IMO (hereinafter referred to as IMO EGCS Guidelines), class requirements for EGCS and relevant equipment, class notations for EGCS and local/regional regulations for fuel oil sulphur content. As shown in the table below, there are different versions depending on the incorporated IMO EGCS Guidelines.
|IMO EGCS Guidelines||Guidelines issued by ClassNK|
|2015 Guidelines for Exhaust Gas Cleaning Systems (Res.MEPC259(68))||Guidelines for Exhaust Gas Cleaning Systems (Ver.3)|
|2021 Guidelines for Exhaust Gas Cleaning Systems (Res.MEPC340(77))||Guidelines for Exhaust Gas Cleaning Systems (Ver.4)|
Table: Correspondence to each guideline
The Guidelines can be downloaded from “ClassNK MyPage” after the registration.
ClassNK MyPage Login
(Updated on 1 Mar. 2022)
Regional regulations related to fuel oil and SOx scrubbers may be enforced independently in each country or port. ClassNK is also trying to collect relevant information since the contents or location of the regional regulations will have a major impact on ship operations. The collected information is summarized in the following link. (Only publicly notified by the government or government affiliated organizations are available. ClassNK will update the table as new information becomes available.)
Regulation and the relevant guidelines / guidance
1. AMENDMENTS TO MARPOL ANNEX VI (SOx・PM REGULATIONS)
|RESOLUTION MEPC.132(53)||Amendments to the Annex of the Protocol of 1997 to Amend the International Convention for the Prevention of Pollution from ships、 1973、 as modified by the Protocol of 1978 relating thereto (Amendments to MARPOL Annex VI and the NOx Technical Code)||Original|
|RESOLUTION MEPC.176(58)||Amendments to the Annex of the Protocol of 1997 to Amend the International Convention for the Prevention of Pollution from ships、 1973、 as modified by the Protocol of 1978 relating thereto (Revised MARPOL Annex VI)||Original|
|RESOLUTION MEPC.190(60)||Amendments to the Annex of the Protocol of 1997 to Amend the International Convention for the Prevention of Pollution from ships、 1973、 as modified by the Protocol of 1978 relating thereto (North American Emission Control Area)||Original|
|RESOLUTION MEPC.194(61)||Amendments to the Annex of the Protocol of 1997 to Amend the International Convention for the Prevention of Pollution from ships、 1973、 as modified by the Protocol of 1978 relating thereto (Revised form of Supplement to the lAPP Certificate)||Original|
|RESOLUTION MEPC.202(62)||Amendments to the Annex of the Protocol of 1997 to amend the International Convention for the Prevention of Pollution from ships、 1973、 as modified by the Protocol of 1978 relating thereto (Designation of the United States Caribbean Sea Emission Control Area and exemption of certain ships operating in the North American Emission Control Area and the United States Caribbean Sea Emission Control Area under regulations 13 and 14 and Appendix VII of MARPOL Annex VI)||Original|
|RESOLUTION MEPC.286(71)||Amendments to the Annex of the Protocol of 1997 to Amend the International Convention for the Prevention of Pollution from ships,1973, as modified by the Protocol of 1978 relating thereto (Designation of the Baltic Sea and the North Sea Emission Control Areas for NOX Tier III control) (Information to be included in the bunker delivery note)||Original|
|RESOLUTION MEPC.305(73)||Amendments to the Annex of the Protocol of 1997 to Amend the International Convention for the Prevention of Pollution from ships、 1973、 as modified by the Protocol of 1978 relating thereto (Prohibition on the Carriage of Non-Compliant Fuel Oil for Combustion Purposes for Propulsion or Operation on board a ship)||Original|
|RESOLUTION MEPC.324(75)||AMENDMENTS TO THE ANNEX OF THE PROTOCOL OF 1997 TO AMEND THE INTERNATIONAL CONVENTION FOR THE REVENTION OF POLLUTION FROM SHIPS, 1973, AS MODIFIED BY THE PROTOCOL OF 1978 RELATING THERETO||Original|
2. IMO guidelines and guidance (SOx・PM REGULATIONS)
|RESOLUTION MEPC.181(59)||2009 Guidelines for port State control under the revised MARPOL Annex VI||Original|
|RESOLUTION MEPC.182(59)||2009 Guidelines for the sampling of fuel oil for determination of compliance with the revised MARPOL ANNEX VI||Original|
and its amendments
|2010 Guidelines for monitoring the worldwide average sulphur content of fuel oils supplied for use on board ships (Consolidated text: MEPC.1/Circ.862)||Original|
and its corrigendum
|2015 Guidelines for Exhaust Gas Cleaning Systems||Original|
|RESOLUTION MEPC.280(70)||Effective date of implementation of the fuel oil standard in regulation 14.1.3 of MARPOL Annex VI||Original|
|RESOLUTION MEPC.320(74)||2019 Guidelines for consistent implementation of the 0.50% sulphur limit under MARPOL Annex VI||Original|
|RESOLUTION MEPC.321(74)||2019 Guidelines for port State control under MARPOL Annex VI Chapter 3||Original|
|MEPC.340(77)||2021 Guidelines for Exhaust Gas Cleaning Systems||Original|
|Unified Interpretations to MARPOL Annex VI||Original|
|Guidelines for onboard sampling for the verification of the sulphur content of the fuel oil used on board ships||Original|
|MEPC.1/Circ.875||Guidance on Best Practice for fuel oil Purchasers/Users for assuring the quality of fuel oil used on board ships||Original|
|Guidance on Best Practice for fuel oil suppliers for assuring the quality of fuel oil used on board ships||Original|
|MEPC.1/Circ.878||Guidance on the development of a ship implementation plan for the consistent implementation of the 0.50% sulphur limit under MARPOL Annex VI||Original|
|MEPC.1/Circ.880||Reporting of Availability of compliant fuel oils in accordance with Regulation 18.1 of MARPOL Annex VI||Original|
|MEPC.1/Circ.881||Guidance for port State control on contingency measures for addressing non-compliant fuel oil||Original|
|MEPC.1/Circ.882||Early application of the verification procedures for a MARPOL Annex VI fuel oil sample (regulation 18.8.2 or regulation 14.8)||Original|
|MEPC.1/Circ.883/Rev.1||Guidance on indication of ongoing compliance in the case of the failure of a single monitoring instrument, and recommended actions to take if the Exhaust Gas Cleaning System (EGCS) fails to meet the provisions of the EGCS Guidelines||Original|
|MEPC.1/Circ.884/Rev.1||Guidance for best practice for Member State/coastal State||Original|
|MEPC.1/Circ.889||2020 GUIDELINES FOR ON BOARD SAMPLING OF FUEL OIL INTENDED TO BE USED OR CARRIED FOR USE ON BOARD A SHIP||Original|