The mere act of commissioning a scrubber system before the end of 2019 will not be enough to be in compliance with the new MARPOL 2020 sulphur cap rules, legal firm CMS Cameron McKenna Nabarro Olswang LLP has warned.
Ship owners, ship operators and ship managers who are busy preparing for the upcoming high sulphur fuel oil (HSFO) ban appeared, at least in part, to be confused as to whether it will be sufficient to commission a scrubber by the end of the year.
CMS Cameron McKenna has issued an update which clarifies the position with regard to relevant international, European and UK law and guidance.
In summary the update states that any ship owners, managers and operators who had been operating on a false premise that commissioning a scrubber by the compliance deadline will be sufficient to demonstrate compliance should review their position. Those vessel owners/operators who were planning to meet the MARPOL Annex VI requirements by opting for scrubbers should take heed if they have merely commissioned a scrubber system and know for certain that they will not be installed in time for December 31st 2019. If this is the case then those ships must ensure that they seek to either have the scrubbers installed by the set deadline or source LSFO in time for January 1st 2020.