IMO 2020 sulphur cap – issues to consider pre-March 1st 2020

Standard Club has said that, with the IMO 2020 global sulphur cap now in force, members should bear in mind another significant date in relation to the ‘carriage ban’ – coming into force on March 1st 2020. The ban mandates that fuel oil used and carried on board ships must not exceed the 0.50% sulphur limit, unless the ship is provided with ‘equivalent’ compliance mechanism such as exhaust gas cleaning system (EGCS), also known as ‘scrubbers’.

The Club warned that the carriage ban might prompt increased enforcement action in the coming months, as any breach would be evident to authorities, and it would be relatively straightforward for port state control officers (PSCOs) to pursue action against ships (without scrubbers) that are found to have fuel oil above the 0.50% limit in any of its tanks.

There could also be potential disputes and/or claims arising due to complaints about bunker quality, or when the MARPOL bunker sample tests generate results which exceed the prescribed 0.50% limit, the Club said.

In order to comply with the carriage ban, Standard Club said that members with ships without scrubbers would need to ensure that any supplied fuel was in compliance with the sulphur limits set out in MARPOL Annex VI, and that any residual high sulphur fuel in the tanks did not push the limit above 0.50%.