SOx・PM regulations

Outline of the regulations

The regulations limiting the sulphur content of marine fuels for ships are specified in Regulation 14 (Sulphur Oxides (SOx) and Particulate Matter (PM)) of Annex VI of MARPOL 73/78, in which the sulphur content limit has been gradually strengthened. The limit for open sea area will be strengthened from 3.5% to 0.5% on 1 January 2020.
In this situation, shipping companies and shipyards are considering by which means they will comply with the regulations: using marine fuel oil with a sulphur content complying with the regulations (compliant fuel), installing SOx scrubber, or converting to alternative fuels such as LNG.

1. Schedule of implementation of sulphur cap and requirements

The limit of the sulphur content has been gradually strengthened in open sea area as shown in below figure.

      Figure Sulphur content limits (Open Sea Area)

For any ship of 400 gross tons or above engaged in international voyages, bunker delivery notes and the corresponding fuel oil samples (more than 400ml) are to be retained on board ships for more than 3 years and for more than 12 months respectively in accordance with Regulation 18 of MARPOL Annex VI. Guidelines for sampling and storage of fuel oil are provided in IMO Resolution MEPC.182(59).

From 1 March 2020, the carriage of fuel oil with a sulphur content higher than 0.5 % (excluding ships operating scrubbers) will be prohibited.

Also, the limit of the sulphur content has been gradually strengthened in Emission Control Area (ECA) as shown in below figure.

        Figure Sulphur content limits (ECA)

At present, the following sea areas are designated as the ECAs.

  • The Baltic Sea area
  • The North Sea area
  • The sea area within 200 nautical miles of the United States/Canadian coast
  • The United States Caribbean Sea area
The Baltic Sea and North Sea area in Europe     The US/Canadian Coast and the Caribbean Sea area

The regulations stipulate that ships that enter and exit the ECA and that use two or more marine fuel oils should have written procedures for completing the switch of the fuel oils in accordance with the regulations on board. When switching the marine fuel oils, it is necessary to record the amount of low sulphur fuel oil in the tank together with the date, time and location in the logbook as prescribed by the Flag Administration at the time of the completion of switching before entering the ECA area as well as at the time of the start of switching after the leaving ECA area.

Planning for change to compliant fuel oil toward 2020

The guidance which recommends for ships to develop and keep on board implementation plans (Ship Implementation Plan) outlining how the ship may prepare in order to comply with the required fuel oil sulphur content limit of 0.50% by 1 January 2020 has been issued as IMO Circular (MEPC.1/Circ.878).

1. Sample of implementation plans

ClassNK has developed a sample of description in the implementation plan. If you would like to receive the sample, please submit this application to ClassNK Machinery Department by using E-mail or mail.

2. Appraisal of implementation plans

ClassNK provides appraisal services related to implementation plans* developed by ship side on a voluntary basis as requested. In case where you request the appraisal services, please submit this application and the plans to ClassNK Machinery Department by E-mail, NK-PASS or mail (please send minimum two sets for hard copy).

* In the appraisal, ClassNK just confirms whether the plan includes the indicative example in IMO Circular “MEPC.1/Circ.878” and does not verify appropriateness of the content of the plan.

3. Appraisal facts of fuel oil tank cleanings, etc.

ClassNK provides appraisal services related to change to the fuel oil with 0.50% sulphur limit e.g. such as fuel oil tank cleaning before bunkering the 0.50% compliant fuel oil, etc. according to the request. In case where you request the appraisal facts, please contact ClassNK Survey Department.

4. Designation of fuel oil sampling point

ClassNK conducts the approval of the plans (e.g. Piping Diagram in E/R) in which fuel sampling points are designated. In case where you request the approval, please submit the plans to ClassNK Machinery Department by E-mail, NK-PASS or mail with the information of mailing address and billing address (please send minimum three sets for hard copy).

5. Precautions having the preventive and response measures to mitigate the potential risks

ClassNK issued a booklet titled “Precautions concerning change-over to 0.50% sulphur compliant fuel oils”.
The purpose of this booklet is to provide crew members on board ships going to bunker and use the compliant fuel oils with information focusing on the "compatibility" and "cold flow properties" of such fuels as well as the risks associated with such fuels and the measures to be taken to mitigate such risks.
The booklet can be downloaded from the below.

Booklet download (PDF) (6.41MB)

Exhaust Gas Cleaning Systems

While the sulphur content of marine fuel oil is limited in Regulation 14 of the Annex VI as described above, Regulation 4 of the Annex VI allows compliance with SOx and PM regulations by using equivalent measures such as Exhaust Gas Cleaning Systems (EGCS).

1. Guidelines for Exhaust Gas Cleaning Systems

Consequently, ClassNK issued the third version Guidelines for Exhaust Gas Cleaning Systems to add the explanation of “2015 Guidelines for Exhaust Gas Cleaning Systems (resolution MEPC.259(68))”, class requirements for EGCS and relevant equipment, class notations for EGCS and local/regional regulations for fuel oil sulphur content.

The Guidelines can be downloaded from “ClassNK MyPage” after the registration.
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Guidance for onboard use of Compliant Fuel Oil with SOx regulation from 2020

ClassNK assessed the needs for further implications for the safe use of the compliant fuel oil from the perspectives of five properties, that is, Compatibility, Low viscosity, Cold flow properties, Cat-fines, and Ignition/Combustion quality. ClassNK wrapped up the potential changes and potential risks associated with the five properties, and also reviewed mitigation measures against these risks, and issued as this Guidance.

The Guidelines can be downloaded from “ClassNK MyPage” after the registration.
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Regulation and the relevant guidelines / guidance

1. AMENDMENTS TO MARPOL ANNEX VI (SOx・PM REGULATIONS)

No. Name Download
RESOLUTION MEPC.132(53) Amendments to the Annex of the Protocol of 1997 to Amend the International Convention for the Prevention of Pollution from ships、 1973、 as modified by the Protocol of 1978 relating thereto (Amendments to MARPOL Annex VI and the NOx Technical Code) Original
RESOLUTION MEPC.176(58) Amendments to the Annex of the Protocol of 1997 to Amend the International Convention for the Prevention of Pollution from ships、 1973、 as modified by the Protocol of 1978 relating thereto (Revised MARPOL Annex VI) Original
RESOLUTION MEPC.190(60) Amendments to the Annex of the Protocol of 1997 to Amend the International Convention for the Prevention of Pollution from ships、 1973、 as modified by the Protocol of 1978 relating thereto (North American Emission Control Area) Original
RESOLUTION MEPC.194(61) Amendments to the Annex of the Protocol of 1997 to Amend the International Convention for the Prevention of Pollution from ships、 1973、 as modified by the Protocol of 1978 relating thereto (Revised form of Supplement to the lAPP Certificate) Original
RESOLUTION MEPC.202(62) Amendments to the Annex of the Protocol of 1997 to amend the International Convention for the Prevention of Pollution from ships、 1973、 as modified by the Protocol of 1978 relating thereto (Designation of the United States Caribbean Sea Emission Control Area and exemption of certain ships operating in the North American Emission Control Area and the United States Caribbean Sea Emission Control Area under regulations 13 and 14 and Appendix VII of MARPOL Annex VI) Original
RESOLUTION MEPC.286(71) Amendments to the Annex of the Protocol of 1997 to Amend the International Convention for the Prevention of Pollution from ships,1973, as modified by the Protocol of 1978 relating thereto (Designation of the Baltic Sea and the North Sea Emission Control Areas for NOX Tier III control) (Information to be included in the bunker delivery note) Original
RESOLUTION MEPC.305(73) Amendments to the Annex of the Protocol of 1997 to Amend the International Convention for the Prevention of Pollution from ships、 1973、 as modified by the Protocol of 1978 relating thereto (Prohibition on the Carriage of Non-Compliant Fuel Oil for Combustion Purposes for Propulsion or Operation on board a ship) Original

2. IMO guidelines and guidance (SOx・PM REGULATIONS)

No. Name Download
RESOLUTION MEPC.181(59) 2009 Guidelines for port State control under the revised MARPOL Annex VI Original
RESOLUTION MEPC.182(59) 2009 Guidelines for the sampling of fuel oil for determination of compliance with the revised MARPOL ANNEX VI Original
RESOLUTION MEPC.192(61),
its corrigendum
and its amendments
(MEPC.273(69))
2010 Guidelines for monitoring the worldwide average sulphur content of fuel oils supplied for use on board ships (Consolidated text: MEPC.1/Circ.862) Original
RESOLUTION MEPC.259(68)
and its corrigendum
2015 Guidelines for Exhaust Gas Cleaning Systems Original
RESOLUTION MEPC.280(70) Effective date of implementation of the fuel oil standard in regulation 14.1.3 of MARPOL Annex VI Original
RESOLUTION MEPC.320(74) 2019 Guidelines for consistent implementation of the 0.50% sulphur limit under MARPOL Annex VI Original
RESOLUTION MEPC.321(74) 2019 Guidelines for port State control under MARPOL Annex VI Chapter 3 Original
MEPC.1/Circ.795
/Rev.4
Unified Interpretations to MARPOL Annex VI Original
MEPC.1/Circ.864
/Rev.1
Guidelines for onboard sampling for the verification of the sulphur content of the fuel oil used on board ships Original
MEPC.1/Circ.875 Guidance on Best Practice for fuel oil Purchasers/Users for assuring the quality of fuel oil used on board ships Original
MEPC.1/Circ.875
/Add.1
Guidance on Best Practice for fuel oil suppliers for assuring the quality of fuel oil used on board ships Original
MEPC.1/Circ.878 Guidance on the development of a ship implementation plan for the consistent implementation of the 0.50% sulphur limit under MARPOL Annex VI Original
MEPC.1/Circ.880 Reporting of Availability of compliant fuel oils in accordance with Regulation 18.1 of MARPOL Annex VI Original
MEPC.1/Circ.881 Guidance for port State control on contingency measures for addressing non-compliant fuel oil Original
MEPC.1/Circ.882 Early application of the verification procedures for a MARPOL Annex VI fuel oil sample (regulation 18.8.2 or regulation 14.8) Original
MEPC.1/Circ.883 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 (resolution MEPC.259(68)) Original
MEPC.1/Circ.884 Guidance for best practice for Member State/coastal State Original

Contacts

Inquiries about newbuildings

Machinery Department

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+81-3-5226-2023
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+81-3-5226-2024
Email: 
mcd@classnk.or.jp
Inquiries about ships in service

Survey Department

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+81-3-5226-2027
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+81-3-5226-2029
Email: 
svd@classnk.or.jp