2020 Sulphur Limit – Guidance and useful information

The global  limit of of 0.5% sulphur in ships’ fuel oil (the Sulphur Cap) has been adopted and approved by the International Maritime Organisation (IMO) and will enter into force on the 01 January 2020.

In addition to the Sulphur Cap, the IMO adopted amendments to MARPOL Annex VI which will ban carriage of non-compliant fuel for use by ships (the carriage ban).

Following the adoption of the above two amendments to MARPOL VI, various organisations (industry associations, member states, Class Societies, etc), including INTERCARGO, have worked together together or individually to produce guidelines aimed to assist with the implementation of the Sulphur Cap.

IMO  Guidance/Best Practice

• Roundtable discussion on the consistent implementation of the 0.50% sulphur limit (18 November 2019)

INTERCARGO participated in a roundtable industry meeting hosted by IMO at its London Headquarters, following a previous meeting in June. An IMO symposium on IMO 2020 and alternative fuels in October also brought together stakeholders, including Member States, the shipping and  refineries sector. After the Nov.18 meeting, IMO issued a Briefing available here.

• 2019 Guidelines for the consistent implementation 0.50% sulphur limit under MARPOL Annex VI
  • Provides guidance to Administrations, port States, shipowners, shipbuilders and fuel oil suppliers for the purpose of ensuring consistent implementation of the Sulphur Cap (available below)
• Guidance on the development of a ship implementation plan  for the consistent implementation of the 0.50% sulphur limit under MARPOL Annex VI
  • Provides guidance to produce an implementation plan and includes an indicative example of a ship implementation plan (available below)
• Guidance on best practice for fuel oil purchasers/users for assuring the quality of fuel oil used on board ships 
  •  Provides information  “…to assist fuel oil purchasers/users in assuring the quality of fuel oil delivered to, and used on board ships, with respect to both compliance with the MARPOL requirements and the safe and efficient operation of the ship.”(available below)
• Guidance on best practice for fuel oil suppliers for assuring the quality of fuel oil delivered to ships 
  • Provides information “…to assist fuel oil suppliers to ensure the quality of fuel oils delivered to ships which is compliant with the agreed specification and statutory limits.” (available below)
• Guidance for the best practice for member state/coastal state
  • Provides information “… to assist Member States in carrying out their responsibilities under MARPOL Annex VI, to ensure effective implementation and enforcement of statutory requirements of that Annex.”  (available below)
• Guidance for port state control on contingency measures for addressing non-compliant fuel oil
  • Provides potential contingency measures for the guidance of port state control officer when fuel oil has not been available  (available below)
• 2019 Guidelines for on board sampling for the verification of the sulphur content of the fuel oil used on board ships
  • Provides guidance “…to establish an agreed method for sampling to enable effective control and enforcement of liquid fuel oil being used on board ships under the provisions of MARPOL Annex VI.” (available below)
• 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 2015 EGCS Guidelines (available below)

Further information can be found on the IMO website by clicking here

Class Guidance

• ABS “2018 Marine Fuel Advisory”
  • Provides “in-depth technical guidance covering a range of topics, from engine considerations to fuel properties to operational risks” (available below)
  • Further information can be found on the ABS website by clicking here
• ABS “Practical considerations for the transition to 2020 compliant fuel”
  • “Introduces the regulatory requirements and outlines items to be considered when sulphur limit compliant fuel is selected as the compliance option.”(available below)
  • Further information can be found on the ABS website by clicking here
• DNV GL “Global Sulphur Cap 2020”
  • Provides “insights on compliance options and implications for shipping” (available below) 
  • Further information can be found on the DNV GL website by clicking here

• Lloyd’s Register  “Sulphur 2020: What’s your plan?”
  • Provides guidance for shipowners and operators on MARPOL Annex VI Sulphur Cap and includes:  “Regulatory overview, overview of compliance options and 0.50% conventional fuel pathway” (available below)
  • Further information can be found on the Lloyd’s Register website by clicking here

Industry Guidance

• International Chamber of Shipping “Compliance with the 2020 ‘Global Sulphur Cap’”
  • This guidance is “primarily intended to assist shipping companies with the significant task of planning in advance to ensure that they have an effective Implementation Plan in place, for each of their ships, which will facilitate full compliance with the Global Sulphur Cap” (available below)
  • Further information can be found on the ICS website by clicking here

European Union Guidance

• European Maritime Safety Agency  “Sulphur Inspection Guidance”
  • “This document is intended to provide guidance for a harmonised approach to the inspection of ships, ascertaining their compliance, identifying non-compliances and applying control procedures for the enforcement……..”
  • The document can be found on the EMSA website by clicking here

ISO Standards

• ISO Publicly Available Specification (PAS) 23263 is now available for purchase/download from the ISO website by clicking here
  • The standard: “…addresses quality considerations that apply to marine fuels in view of the implementation of maximum 0,50 mass % S in 2020 and the range of marine fuels that will be placed on the market in response to the international statutory requirements to reduce exhaust gas emissions. It defines general requirements that apply to all 0,50 mass % sulfur (S) fuels and confirms the applicability of ISO 8217 for those fuels. It gives technical considerations which might apply to particular fuels for the following characteristics:— kinematic viscosity;— cold flow properties;

    — stability;

    — ignition characteristics;

    — catalyst fines.

    Additionally, it provides considerations on the compatibility between fuels and additional information on ISO 8217:2017, Annex B (see Annexes B and D)”  (source: ISO Website, ISO/PAS 23263:2019)