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IBIA: An overview of IMO’s 2020 implementation guidelines

Guidelines developed by PPR 6 in February will be sent for approval by MEPC 74 in May, it says.

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The International Bunker Industry Association (IBIA) has provided an industry update on developments affecting the marine fuels industry from the 6th meeting of the International Maritime Organization (IMO) Sub-Committee on Pollution Prevention and Response (PPR 6):

The IMO has developed a comprehensive package of guidelines to assist industry and Administrations to effectively and uniformly implement the 0.50% sulphur limit that takes effect form 1 January, 2020. Guidelines developed by the 6th meeting of the IMO’s Sub-Committee on Pollution Prevention and Response (PPR 6) in February will be sent for approval by the Marine Environment Protection Committee in May (MEPC 74). Here is an overview.

Consistent implementation guidelines

The main part of the package is the so-called Guidelines on consistent implementation of the 0.50% sulphur limit under MARPOL Annex VI. These guidelines consist of the following sections:

Definitions. This section helps to clarify the language for fuel oils, referring to distillate marine (DM) and residual marine (RM) fuels as specified in ISO 8217, as well as defining fuels by sulphur content. Fuels at or below 0.10% sulphur are defined as ULSFO, fuels with maximum 0.50% sulphur as VLSFO, and any fuels with sulphur above 0.50% as HSHFO. These are largely in line with nomenclature previously explained by IBIA (click here for details).

Ship implementation planning for 2020. This was already finalised at MEPC 73 as MEPC.1/Circ.878 on Guidance on the development of a ship implementation plan for the consistent implementation of the 0.50% sulphur limit under MARPOL Annex VI. This includes an appendix on tank cleaning based on a submission from IBIA, and an appendix addressing the impact on machinery systems with advice on how to prepare for use of a variety of fuels, which IBIA also contributed to (click here for more information).

Impact on fuel & machinery systems. This section contains advice on handling various fuels (DM, RM, DM containing FAME), and repeats messages seen in the SIP regarding impact on machinery systems.
Verification issues and control mechanism and actions. This section deals with how administrations should undertake ship inspections, possible compliance monitoring tools, sulphur analysis, controls on fuel oil suppliers and sharing of information about non-compliant ships and suppliers.   

Fuel oil non-availability.  This section is about how to deal with situations where a ship could not, despite its best efforts, obtain compliant fuel oil and about who this information needs to be shared with. PPR 6 agreed on a Fuel Oil Non-Availability Report (FONAR) format the ship should use and , and set out guidelines for how a Party should investigate FONARs.  (Click here for more information)

Possible safety implications relating to 0.50%S fuels. This section lists parameters that have been identified as a potential cause for concern, including stability, compatibility, cold flow properties, acid number, flash point, ignition and combustion quality, cat fines, low viscosity, and unusual components. There is an appendix that sets out more information on each of these. Reference is also made to general industry guidance.

In this context, PPR 6 was provided with an update on progress of the Joint Industry Project which is developing a comprehensive set of guidelines on potential safety and operational issues related to the supply and use of fuel oils with a 0.50% sulphur limit. This will be made available to all industry stakeholders once the relevant ISO Publicly Available Specifications (PAS) have been released, so the JIP document can incorporate appropriate references to it.

The PAS is being developed by the ISO 8217 working group to provide detailed guidance to fuel suppliers and users on the type of fuel blends that are anticipated to dominate the global bunker market in 2020. The PAS and the JIP guidance are anticipated to be ready during the second half of 2019. The JIP, which is organised by OCIMF and IPIECA, has broad participation from marine fuel industry experts across a range of organisations, including IBIA.

Additional guidelines associated with 2020

PPR 6 drafted several MEPC Circulars associated with ensuring sulphur limits are met. They include the following:

Draft circular on delivery of compliant fuel oil by suppliers.  This will be a joint MSC-MEPC circular addressing the delivery of compliant fuel oil by suppliers, for approval at MEPC 74 in May and at the Maritime Safety Committee (MSC 101) in June. The draft circular is aimed at Members States to take appropriate action against suppliers under their jurisdiction to ensure they deliver compliant fuel oil. They are also told to urge fuel oil suppliers to take into account, as relevant, Guidance developed by the IMO on best practice for fuel oil suppliers and fuel oil purchasers/users for assuring the quality of fuel oil delivered to and used ships.  (Click here for more information)

Draft amendments to on board sampling guidance. PPR 6 agreed draft 2019 Guidelines for on board sampling for the verification of the sulphur content of the fuel oil used on board ships, updating the current version, MEPC.1/Circ.864, which will be superseded if the update is approved by MEPC 74.

Draft 2019 port State control guidelines. PPR 6 agreed, in principle, to draft 2019 Guidelines for port State control under MARPOL Annex VI, updating the 2009 guidelines, for MEPC 74 to adopt. There are, however, some areas that were not fully resolved. One is regarding the situation when a ship has BDN that says the fuel is compliant, but the ship’s own test results suggest it is not. This is not covered by the FONAR because the ship thought it had procured compliant fuel oil. Also not resolved was how to deal with non-compliant fuel oil remaining onboard a ship, hence interested parties have been invited to submit proposals to MEPC 74.  (Click here for more information)

Unni Einemo
[email protected]

Source: International Bunker Industry Association
Published: 21 March, 2019

 

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Ammonia

AM Green plans to build green ammonia plant at Indian port

Initiative also includes development of green ammonia handling, storage and bunkering infrastructure, pilot bunkering operations, safety procedures and training programmes, says VOC Port Authority.

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VO Chidambaranar (VOC) Port Authority on Friday (29 May) said it has signed a Memorandum of Understanding (MoU) with India’s ammonia producer AM Green Ammonia to collaborate in the development of a green ammonia production plant.

The plant will have a capacity of one million tonnes per annum (MTPA) at Tuticorin.

The initiative also includes development of green ammonia handling, storage and bunkering infrastructure, pilot bunkering operations, safety procedures and training programmes. 

The project is expected to support the development of green fuel corridors connecting VOC Port with major ports in Europe and Asia, thereby strengthening India’s position in the global green fuels value chain.

VOC Port also signed a Memorandum of Understanding (MoU) with Bureau Veritas (India) Pvt. Ltd., to collaborate on Green Port certification, emissions accounting, ESG reporting, safety validation, development of green bunkering practices, and establishment of a Centre of Excellence for green fuels and sustainability.

The port also plans for an upcoming 750 m³ green methanol bunkering facility.

 

Photo credit: Naveed Ahmed on Unsplash
Published: 3 June, 2026

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Port & Regulatory

Study: Major drop in ship sulphur emissions confirmed following IMO regulations

National Centre for Atmospheric Science study found that the average sulphur content in ship fuel dropped nearly tenfold in open ocean areas following IMO’s 2020 regulation.

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Recent global regulations have significantly reduced sulphur emissions from ships, helping to improve air quality in coastal regions – confirmed by a recent international study led by researchers at the National Centre for Atmospheric Science. 

The research, published in Environmental Science: Atmospheres, used aircraft and ground-based instruments to measure sulphur dioxide and nitrogen oxides emitted by ships in the North-East Atlantic and European coastal waters between 2019 and 2023.

The team found that the average sulphur content in ship fuel dropped nearly tenfold in open ocean areas following the International Maritime Organization’s 2020 regulation, which capped sulphur content in marine fuel at 0.5%. 

Before the change, many ships exceeded the previous 3.5% limit. After 2020, only a small number of ships were found to breach the new standard.

In European sulphur Emission Control Areas (SECAs), such as the English Channel and the Port of Tyne, sulphur levels were even lower – well below the stricter 0.1% limit. Interestingly, ports outside these zones, like Valencia in Spain, also showed low sulphur levels, likely due to EU rules requiring cleaner fuel when ships are docked for extended periods.

This is the first study to use aircraft-based measurements and predictions from the Ship Traffic Emission Assessment Model (STEAM3) to assess ship emissions outside of sulphur control zones since the 2020 regulation came into effect. The findings support the widely held view that ships now emit around seven times less sulphur than before the rule change – an important step toward cleaner air and healthier coastal environments.

Note: The research, titled ‘SO2 and NOx emissions from ships in North-East Atlantic waters: in situ measurements and comparison with an emission model’ can be found here. 

 

Photo credit: shraga kopstein on Unsplash
Published: 8 December, 2025

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Interview

IBIA Annual Convention 2025: ‘Exciting times’ for post IMO 2020 bunker suppliers, states Equatorial

Choong Sheen Mao, Chief Operating Officer, Equatorial, describes to Manifold Times the pre/post IMO 2020 challenges and evolution of bunker suppliers.

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The International Bunkering Industry Association (IBIA) will be hosting its flagship Annual Convention in Hong Kong at the Hong Kong Convention Exhibition & Convention Centre between 18 to 20 November 2025, as part of Hong Kong Maritime Week.

Choong Sheen Mao, Chief Operating Officer, Equatorial Marine Fuel Management Services (Equatorial), speaks to bunkering publication Manifold Times about the challenges of a post IMO 2020 bunker supplier.

MT: How does Equatorial continue to offer customer assurance and maintenance of marine fuel quality to ISO8217 standards despite increasing complexity of bunker fuel blends?

We maintain our focus to provide compliant, quality and competitively priced products to our customers. There is no shortcut. We source our products from a wide range of cargo producers and suppliers. We continue to be strict and vigilant with our testing programme for our products before delivering them to our customers. Equatorial has deepened our engagement with the wider industry to have a better and up-to-date understanding of the existing and new marine fuels.

MT: Can you share the evolution of commercial marine fuel procurement, blending and trading strategies on the back of increasing fuel types (pre/post IMO 2020)?

Pre IMO 2020, the main types of marine fuel procured and consumed by vessels were high-sulphur fuel oil, marine diesel oil and marine gas oil. Trading strategies were therefore closely linked to that within the oil industry.

However, many of the new fuel types are from other industries. For example, biofuels, methanol and ammonia are mainly products from the chemical and agriculture industries. There are marked differences between these industries and the energy industry (in particular, the marine fuels industry). LNG is from the gas industry which is distinct from the oil industry.

Without an existing liquid paper market for many of these commodities (especially as a marine fuel), the price risk management is less straightforward. Furthermore, commodity prices are no longer the sole consideration for price itself. The price of compliance must be considered. This could range from guaranteeing the origin of the marine fuel, its sulphur properties as well as its carbon intensity. The list goes on.

MT: Operational wise, what are the changing role and responsibilities of a bunker supplier to date, compared to before IMO 2020?

The role and responsibility of a bunker supplier have evolved. Fundamentally, it has been about providing quality marine fuels at competitive prices. Quantity assurance has been a critical concern which led to the mandatory implementation of the mass flow meter system for bunkering in the Port of Singapore. Interestingly, due to the nature of credit terms in the bunker industry, bunker suppliers also performed the role of “bankers” by extending favourable credit terms to shipowners and charterers.

These days, post IMO 2020, things have become even more complicated. Today, a bunker supplier retains the abovementioned roles and responsibilities, and much more – it has to ensure compliance with a plethora of rules and regulations. Compliance not only with sulphur cap requirements, but with international and regional sanctions and restrictions unrelated to the quality of the marine fuel itself. In fact, especially with alternative low- and zero-carbon marine fuels, this means compliance with standards, rules and regulations on sustainability such as the European Renewable Energy Directive and/or International Sustainability and Carbon Certification. There is also the need to comply with increasingly stringent safety regulations on both conventional and alternative marine fuels.

In addition to the above, a post IMO 2020 bunker supplier is still expected to supply compliant and quality fuel at competitive prices.

MT: Equatorial is Singapore’s largest local-born supplier; what is the next big thing for the company?

Equatorial continues to adapt and improve with the times, while maintaining its core values – Integrity, Teamwork, Commitment, Proficiency and Quality, and Safety and Environment. The bunker industry is a highly competitive one, and it is our intention to keep our competitive edge and remain relevant. This means that we have had to step out of our comfort zone and embrace the two mega trends of our time – digitalisation and decarbonisation.

We have been early adopters and developers of the electronic bunkering note as part of our own digital bunkering efforts. We have diversified our product offering to include low carbon marine fuels and are proud to be one of the pioneers for bunkering B100 biofuels earlier this year. This was made possible by the arrival of our IMO Type II chemical and oil bunker tankers. These same bunker tankers are also capable for carrying and delivering methanol. Equatorial has invested in an LNG bunkering vessel (LBV) newbuilding that is set to be delivered in Q3 2027. We are also involved in a study to develop low- or zero-carbon ammonia bunkering in Singapore.

These are exciting times.

Note: Choong Sheen Mao is amongst panellists featured in ‘Session Three: Bunker Sellers Panel’ at the IBIA Annual Convention 2025.

Join the Conversation

With over 300 delegates expected, the IBIA Annual Convention 2025 is set to be a defining moment for the marine fuels industry. Registration is now open via the IBIA Annual Convention website.

 

Photo credit: Manifold Times
Published: 31 October 2025

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