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Hill Dickinson: Sulphur regs going smoothly, but plan ahead to meet March debunkering deadline

Some issues arising over the margin for error in testing for sulphur content and presence of sediment is causing concern in some areas, highlights lawyer.
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London-based Beth Bradley of the Hill Dickinson marine legal team on Thursday (30 January) published an article reviewing potential issues for ship owners to meet the 1 March deadline for part two of IMO’s Regulation 14.1.3 of Marpol Annex VI: 

The transition to low sulphur fuels has so far been smooth, thanks to the efforts of shipping industry stakeholders in preparing for the change, which entered into force on 1 January this year.

However, there are some issues arising over the margin for error in testing the sulphur content and the presence of sediment is causing concern in some areas, warns maritime law specialist Hill Dickinson.

And, as the 1 March deadline for part two of the regulations looms, the legal expert advises ship operators to start planning now to debunker any remaining high sulphur fuel in good time.

Beth Bradley, a London-based partner with Hill Dickinson marine team, explains: ‘It is nearly a month from the implementation date of Regulation 14.1.3 of Marpol Annex VI and, while it is too early to draw firm conclusions, a couple of themes are emerging as a result of the change.’

Regulation 14.1.3 Marpol Annex VI, lowers the sulphur content for marine fuel for use on board vessels not fitted with exhaust gas cleaning equipment from 3.5% m/m to 0.50% m/m and took effect of 1 January 2020 (the ‘sulphur cap’). Regulation 14.4.3 Marpol Annex VI limiting sulphur content to 0.10% m/m in Emission Control Areas remains in place.

In the opening weeks of 2020 there have been very few reports of enforcement action taken against vessels for non-compliance with the sulphur cap. Consequently, the transition has been smoother than expected from a port state control perspective. This is in no small amount attributable to the efforts of the key stakeholders (owners, charterers, insurers and bunker suppliers) to prepare to be compliant as of 1 January 2020. 

While this suggests a high level of compliance, it is only part of the picture, warns Ms Bradley, explaining that issues relating to the sulphur content of fuel, as well as the quality of some blended low sulphur fuels, are already arising. 

Compliance with Regulation 14.1.3 means using a fuel with a sulphur content of 0.50% m/m maximum. If the sulphur content exceeds that threshold, owners may be exposed to enforcement action. Consequently, the frequency of owners having samples tested for sulphur content has increased. 

Where the bunkers are found to be marginally in excess of the limit, problems are arising largely owing to the difference between Regulation 14.3.1 and most supply contracts. An on-specification supply for sulphur content will, usually, from a suppliers’ point of view be deemed to be up to 0.53% m/m, since that reflects the laboratory margin of confidence for testing. 

‘As a result, a time consuming and costly stand-off can occur while the sulphur content issue is resolved and decisions made regarding whether to de-bunker and obtain alternative bunkers,’ says Ms Bradley.

In addition, over the past four weeks there have been a number of alerts issued concerning sediment issues, in particular, in low sulphur fuels supplied in Singapore, Piraeus, Amsterdam, Rotterdam, Miami and San Vincente. The propensity to sediment can cause engine problems, from sludging of filters to engine damage and blackouts in the worst circumstances.

Ms Bradley warns: ‘Quality claims relating to bunkers are not a new phenomenon but, in the past, they have tended to be localised. The spread of alerts concerning sediment suggests a potentially wider issue concerning the stability of some blended low sulphur fuel.’

She cautions: ‘Liability, depending on the reasons for sedimentation, may not be straightforward. While charterparties and bunker supply contracts will contain a specification for the fuel, usually by reference to the ISO 8217 standard, some organic compounds which cause sedimentation may not be caught by the Table Two parameters (although the issue may be caught by clause 5.3 of ISO 8217).’

Where shipowners have devolved the responsibility to provide bunkers to the vessel to their time charterers, the time charterers’ obligation as a matter of English law is twofold; (a) to provide bunkers in accordance with the contractual specification and (b) to provide bunkers which are fit for purpose. 

‘As such, if the bunkers are within specification but are causing sedimentation, or are otherwise not fit to be consumed by the vessel, owners may have recourse against their time charterers,’ counsels Ms Bradley, adding: ‘The position is not necessarily the same under bunker supply contracts, particularly if there are clear provisions excluding claims relating to fitness for purpose, which can make it difficult to pursue the supplier.’

Hill Dickinson outlines that, from a practical point of view, the usual advice to owners applies:

  • ensure that they have clean bunker tanks 
  • avoid co-mingling of bunkers, and  
  • monitor sampling during the supply 

Time charterers arranging the supply of bunkers (or owners if dealing direct with the suppliers) need to ensure that they understand the supply contract and have the time bar and sampling provisions firmly in mind in order to preserve their rights of recourse against the supplier, if available. 

It also warns that, while the use on board of high sulphur fuel is now impermissible unless the vessel is fitted with exhaust gas cleaning systems, high sulphur fuel may be carried until 1 March. 

Ms Bradley predicts: ‘Looking ahead, enforcement action and quality issues will remain live topics as the shipping industry adjusts to the sulphur cap. The next pinch point will be 1 March 2020 when the carriage ban takes effect. 

‘Owners have a little over a month in which to arrange to de-bunker high sulphur fuel and would be best advised to start planning those operations (if not already in hand) now, so as to avoid the consequences of missing the deadline,’ she advises.

 

Source: Hill Dickinson
Published: 4 February, 2020

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Mass Flowmeter

Hong Kong backs MFM adoption with voluntary scheme to boost bunkering competitiveness

Hong Kong’s Marine Department launched the Quality Bunker Operator Scheme to encourage bunker operators to install and use mass flow meter systems on their bunker vessels.
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Hong Kong’s Marine Department (MD) on Wednesday (3 June) launched the Quality Bunker Operator Scheme to encourage bunker operators to install and use mass flow meter systems (MFM systems) on their bunker vessels.

MD said the scheme aims to enhance Hong Kong’s bunkering service quality and the competitiveness of Hong Kong ports, thereby further consolidating Hong Kong’s position as an international maritime centre and a major bunkering port.

Under the Scheme, bunker operators of traditional maritime fuel and biodiesel that install and use MFM systems on their bunker vessels, with the MFM systems inspected and certified by an accredited body in accordance with the International Organization for Standardization’s ISO 22192 Standard or equivalent requirements, can apply to the MD for inclusion in the scheme’s “List of Quality Bunker Vessels”, provided they meet the relevant technical and operational requirements. 

Details of the bunker vessels successfully included in the List will be published on a dedicated page on the MD’s website for reference by shipping companies and relevant stakeholders.

Participation in the Scheme is voluntary. In addition to receiving recognition from the MD, participating bunker operators will benefit from enhanced corporate image and competitiveness through the adoption of MFM systems, thereby boosting customers’ confidence and helping to create new business opportunities.

 A spokesman for the MD, said: “As an international maritime centre supported by our country, Hong Kong has a strategic location adjacent to major international fairways. Coupled with years of development in marine fuel bunkering, Hong Kong possesses rich experience and talent in the field. For many years, Hong Kong has consistently ranked as the seventh-largest bunkering port globally, the second-largest in our country, and the largest in the Greater Bay Area, providing reliable and competitive fuel bunkering services to ocean-going vessels from around the world. 

“As the international shipping industry has an increasing demand for accuracy and transparency in bunkering services, service quality and measurement precision in bunkering operations have become important indicators of a bunkering port’s competitiveness. The Scheme will enhance bunkering accuracy and transparency, further enhancing the quality of Hong Kong’s bunkering services.

The spokesman added that comprehensive port services are one of Hong Kong’s key advantages as an international maritime centre.

“We will also mandate the use of MFM systems on all methanol bunker vessels this year to ensure that Hong Kong continues to provide high-quality bunkering services in the era of green maritime fuels.” 

Note: The application form for the Scheme can be found on the MD’s website. Interested bunker operators can download the application form from the website or contact the MD’s Green Maritime Fuel Team via email ([email protected]) for details.

 

Photo credit: Manifold Times
Published: 4 June, 2026

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Alternative Fuels

MPA and MSC ink MoU to support adoption of alternative bunker fuels

MPA and MSC will explore new routes and services to strengthen connectivity, support the adoption of alternative marine fuels such as bio-LNG, and advance technologies to improve vessel energy efficiency.
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MPA and MSC ink MoU to support adoption of alternative bunker fuels

The Maritime and Port Authority of Singapore (MPA) on Wednesday (3 June) said it signed a Memorandum of Understanding (MoU) with MSC Mediterranean Shipping Company to strengthen collaboration in maritime decarbonisation, digitalisation, innovation, and manpower development. 

The MoU was signed on 25 May 2026 by Mr Ang Wee Keong, Chief Executive of MPA, and Mr Soren Toft, Chief Executive Officer of MSC.

The MoU underscores the shared commitment of MPA and MSC to foster a sustainable, digital, and future-ready maritime sector, while enhancing MSC’s operational and business activities in Singapore. This year also marks the 30th anniversary of MSC establishing its Asia Regional Office and local office in Singapore.

Under the MoU, MPA and MSC will explore new routes and services to strengthen connectivity, support the adoption of alternative marine fuels such as bio-LNG, and advance technologies to improve vessel energy efficiency and operational performance.

MPA and MSC will also collaborate on maritime digitalisation initiatives to improve operational efficiency, including streamlining vessel arrivals and port operations. 

On manpower development, MSC will support internship and scholarship opportunities through Singapore Maritime Foundation’s Maritime Outreach Network (MaritimeONE) platform, an industry-led tripartite partnership comprising industry, government and institutes of higher learning that aims to raise awareness of the maritime industry and attract quality talent into the maritime sector.

Mr Ang Wee Keong, Chief Executive of MPA, said: “This partnership reflects the strong collaboration between MPA and MSC in driving sustainability and digitalisation in the maritime sector. By working together on decarbonisation, operational efficiency and talent development, we aim to strengthen Maritime Singapore’s position as a trusted and future-ready global maritime hub.”

Mr Soren Toft, Chief Executive Officer of MSC, said: “Singapore is a strategically important hub for MSC and a key gateway to the broader Asia region. As we mark 30 years in Singapore, this MOU reinforces our long-term commitment to strengthening our presence here. MSC and Singapore are closely aligned on the priorities shaping the future of global shipping, and we look forward to deepening this partnership to drive the continued growth and resilience of the maritime industry.”

 

Photo credit: Maritime and Port Authority of Singapore
Published: 4 June, 2026

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Emissions reporting

StormGeo and OceanScore link emissions data, compliance workflows

Cooperation combines StormGeo’s expertise in operational vessel and emissions data with OceanScore’s expertise in emissions compliance workflows across EU ETS, FuelEU Maritime and UK ETS requirements.
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StormGeo and OceanScore link emissions data, compliance workflows

Weather intelligence and decision support solutions provider StormGeo and Hamburg-based technology platform OceanScore on Wednesday (3 June) said they have deepened their ongoing cooperation through the signing of a collaboration agreement during Posidonia 2026 in Athens on 2 June.

The cooperation combines StormGeo’s expertise in operational vessel and emissions data with OceanScore’s expertise in emissions compliance workflows across EU ETS, FuelEU Maritime and upcoming UK ETS requirements.

Together, the companies aim to help shipping companies seamlessly navigate increasing regulatory complexity more efficiently — from emissions reporting and data validation to compliance exposure management, pooling and financial settlement.

As emissions regulation becomes an increasingly important part of commercial shipping operations, the need for reliable operational data and streamlined compliance processes continues to grow. The cooperation between StormGeo and OceanScore is designed to support shipping companies with more connected, transparent and actionable processes across operational and commercial teams.

“From the outside, companies like StormGeo and OceanScore may sometimes be perceived as competitors because both operate around emissions and compliance workflows,” said Albrecht Grell, Managing Director at OceanScore. 

“But in reality, the industry increasingly needs both perspectives working together: trusted operational emissions data on one side and commercial compliance execution on the other. Our cooperation reflects that shipping companies are no longer looking for isolated solutions — they need connected processes, automated across different systems and reliable decision-making throughout the full compliance chain.”

By connecting validated operational emissions data with commercial compliance management, the cooperation supports workflows across:

  • emissions reporting and validation 
  • compliance management across EU ETS, FuelEU Maritime and upcoming UK ETS requirements
  • exposure visibility and cost transparency
  • pooling, settlement and financial processes 

The cooperation also aims to improve commercial transparency and coordination across operational and commercial stakeholders.

“StormGeo plays a central role in helping shipping companies turn operational vessel and emissions data into trusted, decision-ready insights,” said Espen Martinsen, Chief Commercial Officer at StormGeo. 

“As emissions regulations become more complex, this data is essential for transparent and efficient compliance management. By working with OceanScore, we can help customers connect StormGeo’s validated operational data with commercial compliance processes, creating a more integrated and practical approach to emissions management.”

The signing ceremony took place at the StormGeo booth during Posidonia 2026 in Athens and was attended by representatives from both companies.

Both companies expect the cooperation to continue evolving alongside upcoming regulatory developments, including FuelEU Maritime, EU ETS, the upcoming UK ETS and future emissions-related frameworks affecting global shipping.

 

Photo credit: StormGeo
Published: 4 June, 2026

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