LOW SULPHUR REGULATIONS: EMISSION CONTROLLED AREAS

Published: 1 January 2020

Updated: 13 November 2020

The global low sulphur requirements of 0.50% by mass (m/m) came into force on 1 January 2020 under the MARPOL convention. However, some areas/regions have implemented separate local legislation with stricter requirements.  

Experience has shown that new changes to existing legislation in some places can happen with very little notice. Therefore, it is very important that shipowners always show due diligence and liaise closely with their local representative to obtain latest advice and before their ship enters a port state’s territorial waters.

MARPOL Emission Control Areas

There are currently five Emission Control Areas (ECAs) controlling the emissions of Sulphur Oxides (SO_X). Control is achieved by capping the sulphur limit of the fuels in use in these areas at 0.10% m/m. These ECAs are the ‘Baltic Sea’, the ‘North Sea’, the ‘North American’, the ‘United States Caribbean Sea’ and the ‘Mediterranean Sea’.

For the Mediterranean Sea, the requirement to use fuel with a 0.10% m/m sulphur content limit will come into force on 1 May 2025, following the 12-month exemption period as per MARPOL Annex VI, Regulation 14.7.

Similarly, the new ‘Canadian Arctic Waters’ and the ‘Norwegian Sea’ ECAs will come into force on 1 March 2026, with the fuel sulphur limit becoming enforceable 12 months later.  

It is highly recommended to verify the current status with the latest IMO updates or official communications.

Regional and National Requirements 

Australia

As per the Australian Maritime Safety Authority (AMSA) 02/2024, all cruise ships berthing in Sydney Harbour with a capacity to accommodate more than 100 passengers are required to limit sulphur emissions. This can be achieved by using low-sulphur fuel (sulphur content <0.10% m/m) or implementing an alternative measure, such as an Exhaust Gas Cleaning System (EGCS) or shore power etc. The limitation on sulphur emissions applies from one hour after the ship’s arrival at berth until one hour before its departure.

China

• From 1 January 2020, ships must use low sulphur content fuel not exceeding 0.10% m/m when entering parts of the Yangtze and Xi Jiang Rivers – Inland Water ECAs
• From 1 January 2022, ships must use low sulphur content fuel not exceeding 0.10% m/m when entering the territorial sea including the province of Hainan – Hainan Coastal ECA.

So far, alternative means such as ECGS have been accepted. However, the use of open scrubbers has been banned in certain parts of the Coastal ECAs. Ships equipped with onboard shore power systems must connect to and utilise them when berthing at ports with operational shore power facilities. Non-compliance may lead to penalties under local regulations.

European Union (EU)

EU sulphur emissions from ships are regulated by Directive (EU) 2016/802 ‘Sulphur Directive’. Since 1 January 2010, ships of all flags berthed in EU ports are required to use fuels with a maximum sulphur content of 0.10% by mass. The transition to low-sulphur fuel must begin as soon as possible after berthing and revert as close to departure as possible. Ships scheduled to berth for less than two hours, according to a published timetable, are exempt from this requirement, as are ships fully switching to a shoreside electricity supply. For the purposes of this regulation, a ship is considered “berthed” when securely moored or anchored in an EU port while loading, unloading, or hotelling, including any time spent idle without cargo operations (Directive (EU) 2016/802).

Iceland

From 1 January 2020, the permissible sulphur content in fuels used in Iceland’s territorial sea and internal waters (also in fjords and bays) is 0.10% by mass, aligning them with the MARPOL required limit for fuels used in ECAs. The territorial waters of Iceland extend 12nm from its coastline.

Israel

Since 23 February 2023, Israel has required all ships berthed or anchored within its port limits to use marine fuels with a sulphur content not exceeding 0.10% by mass (aligning with practices under EU Sulphur Directive and consistent with the broader goals of MARPOL Annex VI). Ships equipped with EGCS approved by the flag state may use non-compliant fuels; however, the discharge of scrubber wash water within port limits is prohibited.

Fuel changeover must be completed within one hour after arrival at berth or anchorage and reverted as late as possible before departure.

Members are encouraged to review the Israeli government’s Notice MP 27 for comprehensive guidance and ensure compliance before entering Israeli ports.

Norway

Since 1 March 2019, the Norwegian World Heritage Fjord region in Western Norway was incorporated into the North Sea ECA, applying the strict 0.10% m/m sulphur limit. The boundaries of these areas and designated fjords include Geirangerfjord, Sunnylvsfjord, Tafjord, Nærøyfjord and Aurlandsfjord. Norway’s adoption of the EU Sulphur Directive since 1 January 2020 also means that all ships calling at Norwegian ports are mandated to use marine fuels with a sulphur content not exceeding 0.10% m/m.

Additionally, Norway plans to introduce zero-emission regulations for cruise ships, tourist vessels, and ferries operating within the UNESCO-listed fjords by 2026. These forthcoming regulations aim to preserve the pristine environment of these globally recognised sites.

Section 14 of the Norwegian Regulation on Environmental Safety for Ships and Mobile Offshore Units also states that ships of 10,000 GT or more operating in these fjords are required to carry an environmental instruction (technical solutions, operational strategies and crew training) tailored to the ship and its operations. This document must outline measures to minimise environmental impact, such as reducing particulate emissions, visible smoke and implementing speed adjustments to lower emissions and discharges. For further guidance, we recommend reaching out to the Norwegian Maritime Administration.

Panama Canal

Panama is not located within any of the MARPOL Annex VI defined ECAs and therefore the global limit of 0.50% m/m maximum sulphur fuel applies. However, the Panama Canal Authority (ACP) has specific fuel rules given in Notice to Shipping No. N-1-2020 – Vessel Requirements.

Section 31 of the Vessel Requirements stipulates that ships arriving at Panama Canal waters switch their main propulsion engines, boilers, auxiliary generator engines, and other ancillary equipment from residual fuels to marine distillate fuels. Panama Canal waters consist of its freshwater reservoirs and the Pacific and Atlantic Anchorage areas, as outlined in Nautical Charts DMA No. 21603 and DMA No. 26068, respectively.

Ships only making a local port call and not transiting will not be required to switch to marine distillate fuel. These ships may use a marine residual fuel with a maximum sulphur content of 0.50% m/m and viscosity higher than 70 cSt at 50°C or a closed loop scrubber or hybrid scrubber in closed loop and zero discharge mode.

Ships proceeding to port terminals or anchorages within Panama Canal waters immediately after completing their transit will be permitted to switch back to residual marine fuel with a maximum sulphur content of 0.50% m/m, once the ship is moored alongside the dock or is anchored.

As these regulations are subject to change, it remains advisable to consult the relevant authorities for the most up-to-date information to ensure compliance.

South Korea

The South Korean Ministry of Oceans and Fisheries (“MOF”) has announced an air quality control programme that defines selected South Korean ports and areas as ECAs, where a maximum sulphur limit of 0.10% m/m will apply. The following ports and areas are covered by the air quality control programme:

• Incheon, Pyeongtaek, Dangjin Area
• Yeosu, Gwangyang area
• Busan
• Busan(west) area
• Ulsan area.

Since 1 September 2020 it has been mandatory to use fuel with max. 0.10% m/m sulphur content berthing or anchoring for the times set out below:

• Berthing: 1 hour after completion of berthing until 1 hour before de-berthing
• Anchoring: 1 hour after completion of anchoring until 1 hour before heaving anchor.

Since 1 January 2022: It is mandatory to use fuel with max. 0.10% m/m sulphur content while navigating within these ECAs.

Alternative compliance methods, such as ECGS, are reportedly still permitted. However, it is advisable to confirm this with a local representative before arrival, as acceptance and specific requirements can vary between ports and regions.

Turkey

Turkey has adopted rules to harmonise requirements with the EU. Meaning that ships at berth or at anchor should use bunkers with a maximum Sulphur content of 0.10% by mass.

Ships transiting the Turkish straits, the Bosphorus, the Dardanelles and the Marmara Sea are exempt from these regulations unless they remain at anchor for more than two hours, in which case the 0.10% by mass sulphur limit applies. Furthermore, the use of open loop EGCS is prohibited in Turkish waters.

USA – State of California

Although part of the ‘North American’ ECA zone, California imposes additional local requirements under the California Ocean-Going Vessel Fuel Regulation issued by the California Air Resources Board (CARB). These apply when ships are within 24 nautical miles of the California coastline and, in contrast to the ECA regulations, prohibit the use of residual fuels and thereby also EGCS. Only distillate fuels (e.g. MGO or MDO) with 0.10% m/m sulphur content limit are allowed when operating in Californian waters.

Furthermore, California also has its ‘At Berth Ocean Going Vessels Regulations’ which previously only applied to container, refrigerated cargo, and cruise (passenger) ships, but has now been expanded to include roll-on/roll-off ships state-wide and tanker ships at the ports of Los Angeles and Long Beach from 1 January 2025. The regulations are planned to apply state-wide for all tanker terminals from 1 January 2027. Emissions control must be operational within two hours of being deemed ‘Ready to Work,’ as defined by California regulations, and must not be disconnected more than one hour prior to the outbound pilot boarding. Compliance can be achieved by either connecting to an Onshore Power Supply (OPS) or employing a ‘CARB-approved Emission Control Strategy’ (CAECS).

The full text of these regulations can be found here.

Members operating in California should review the latest CARB requirements to ensure compliance.

For further information, please do not hesitate to contact our loss prevention department at lossprevention@tindallriley.com.

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