Global shift to cutting sulphur oxide emissions
From 1 January 2020, the limit of sulphur in fuel oil used on board ships operating outside designated emission control areas will be reduced to 0.50% m/m (mass by mass), as part of the global implementation of the International Convention for the Prevention of Pollution from Ships (MARPOL) Annex VI. This will significantly reduce the amount of sulphur oxides emanating from ships and should have major health and environmental benefits, globally.
From 1 March 2020, ships cannot carry fuel oil with a sulphur content of more than 0.50 per cent m/m unless the fuel is being carried as cargo.
The following information is provided as general guidance only and should be read in conjunction with MARPOL Annex VI and associated guidelines, relevant Acts, and Marine orders.
Who does it apply to?
All ships and vessels globally, including those operating domestically in Australia.
What does it mean?
The low sulphur limit applies to all fuel used by a ship for propulsion or operation, including all gas, petrol, distillates, residual and blended fuels.
Ships can carry fuel oil with a sulphur content of more than 0.50 per cent m/m until 1 March 2020, however it cannot be used from 1 January 2020, unless an approved exhaust gas cleaning system is in operation.
To comply with the 1 January 2020 low sulphur limit, ships can use:
- fuel oil with a maximum sulphur content of 0.50 per cent m/m;
- alternative fuels such as liquefied natural gas (LNG), or compliant marine diesel oil that have a sulphur content of 0.50 per cent m/m or less;
- an alternative measure to reduce sulphur oxide emissions approved by the ship’s flag State Administration in accordance with International Maritime Organization (IMO) requirements—provided the resulting emissions are equivalent.
An Exhaust Gas Cleaning System (EGCS) or “scrubber” is the only alternative measure currently approved for use.
In addition to the 1 January 2020 requirement, vessels will be prohibited from carrying fuel oil with a sulphur content of more than 0.50 per cent m/m from 1 March 2020—unless an EGCS is fitted.
The requirement does not change in any way the entry into force date of the 0.50 per cent m/m limit from 1 January 2020 (ie non-compliant fuel may be carried on board the vessel between 1 January and 1 March 2020, but it cannot be used unless in conjunction with an EGCS.
Who is going to enforce it in Australia?
The Australian Maritime Safety Authority (AMSA) are the responsible regulatory body for the enforcement of Low Sulphur 2020 in Australia.
AMSA’s approach to compliance and enforcement of the sulphur limit will be in line with Australia’s existing port State control (PSC) regime and IMO guidelines: 2019 Guidelines for port State control under MARPOL Annex VI and 2019 Guidelines for consistent implementation of the 0.50% sulphur limit under MARPOL Annex VI.
For initial PSC inspections, AMSA will rely on documentation, such as bunker delivery notes and oil record books, as well as shipboard procedures. The initial inspection is intended to check if the ship is compliant with its documentation and the low sulphur fuel requirements.
Based on the outcomes of the initial inspection, AMSA may conduct a more detailed inspection, which may include fuel oil sample analysis, to verify compliance.
Penalties apply for failing to comply with the 2020 low sulphur fuel regulation, as set out in the Protection of the Sea (Prevention of Pollution from Ships) Act 1983. In line with existing PSC policy, where a ship is found to be non-compliant it may be subject to detention, refused access or granted conditional entry to Australian ports.
Further information on Australia’s approach to compliance with the 2020 low sulphur limit can be found in Marine Notice 4/2019.
Where can I access more information?
Updated information on the sulphur requirements and how to comply can be found on AMSA’s website. AMSA has also published a new Marine Notice to help ensure that vessel owners and operators and other stakeholders are aware of their obligations under the new requirements and to advise on AMSA’s approach to compliance. This can be accessed at: 4/2019—Implementation of the 1 January 2020 low sulphur fuel requirement.
An additional Marine Notice has also been published on Australia’s requirements for the use of exhaust gas cleaning systems to comply with the 0.50% m/m sulphur limit when operating in Australian waters. This Marine Notice can be accessed at: 5/2019—Requirements for the use of Exhaust Gas Cleaning Systems in Australian Waters and reporting to AMSA. Further information on the use of exhaust gas cleaning systems, including the discharge of wash water from these systems in Australian waters, can be found on the AMSA website.
Updated fuel oil supplier lists are also available online. These pages provide information on the availability of low sulphur fuel oil (LSFO) at Australian ports within each State and the Northern Territory (NT) and will be updated with any new information provided by suppliers.
