Scrubbers

Gard updates list of ports with restrictions to scrubber washwater discharge

‘We advise clients to monitor the situation and ensure that crew onboard vessels fitted with open loop scrubbers are aware of any local discharge requirements,’ it said.

Published

6 years ago

August 21, 2020

Admin

Norwegian maritime insurance company Gard on Wednesday (19 August) updated its list of ports that have prohibited or implemented local/more stringent criteria for discharging scrubber washwater, it also provides some guidelines on how shipowners can ensure compliance when trading in these areas:

The IMO considers exhaust gas scrubbers to be an acceptable means of reducing vessels’ sulphur emissions and ensuring compliance with MARPOL Annex VI. A separate guideline, Resolution MEPC.259(68), specifies the requirements for the verification, testing, survey and certification of scrubber systems and sets out the criteria for discharging scrubber washwater into the sea.

However, some coastal states and ports have implemented local regulations with more stringent requirements that restrict or completely prohibit the discharge of washwater from open loop scrubbers or prohibit the use of scrubbers. We are currently aware of the following regions/states/ports with local regulations that have an effect on the discharge of exhaust gas scrubber washwater, although the list should not be considered as complete.

AFRICA	Egypt	Discharge of washwater from open loop scrubbers is prohibited in the Suez Canal. The attached clarification to circular 08/2019 also states that Egypt is in the process of ratifying MARPOL Annex VI. It should be mentioned that though use of fuel with a sulphur content greater than 0.5% sulphur may be allowed without the use of scrubbers, vessels should always refer to their flag state regulations which may not allow this.
AMERICAS	Argentina	We have been informed that although Argentina has not ratified MARPOL Annex VI, the authorities have nonetheless prohibited discharge of wash water from open loop scrubbers in the country’s jurisdictional waters following the enactment of Disposition 15/2020 which came into effect on 10 August 2020.
	Bermuda	Use of open loop scrubbers is not permitted. Environmental Policy for Ships states: “Washwater and residue from the EGCS shall not be disposed of in Bermuda or discharged into Bermuda’s waters but shall be stored on board the ship until outside of Bermuda’s waters”. If a vessel has to use a closed loop scrubber in territorial waters of Bermuda, permission needs to be sought from the authorities.
	Panama	Notice to Shipping No. 01 of 2020 states that discharging EGCS washwater into bodies of water under the responsibility of Panama Canal is not permitted. Use of closed loop systems is permitted.
	USA	Hawaii: Conditional section 401 WQC (Water Quality Certification) as mentioned in section 6.7 of 2013 VGP allows for discharge of washwater subject to certain requirements being fulfilled. These requirements can be found in the same section.
		Connecticut: Connecticut has laid down specific conditions as part of the 2013 Vessel General Permit (VGP) requirements. In accordance with section 6.5.9 of the 2013 VGP, discharge of exhaust gas scrubber washwater into Connecticut waters from any vessel covered under the VGP is prohibited. Please see CGS section 22a-427, and Connecticut Water Quality Standards (CT WQS).
		California: The CARB OGV (California Air Resource Board for Ocean Going Vessels) regulations do not permit the use of abatement technologies such as scrubbers in lieu of distillate compliant fuel. This has been clarified in Marine Notice 2020-1 issued by California Air Resource Board.
		US Coast Guard has informed that it will use the IMO’s Global Integrated Shipping Information System (GISIS) database to confirm that foreign flagged ships are using approved scrubbers. Notification to IMO’s GISIS shall be submitted by the Flag State of the vessel. The USCG has also published a guidance document on enforcement of the sulphur cap regulations.
ASIA	Bahrain	According to marine notice PMA/03/2019, discharge of washwater from open loop scrubbers is prohibited within port limits including anchorage area(s). The circular also states that vessels should obtain a permit from the Marine Safety & Environment Protection Directorate before discharging washwater anywhere in Bahrain waters.
	China	China MSA in its “Implementation Scheme of 2020 Global Marine Fuel Oil Sulphur Cap” has mentioned that washwater discharge from open loop scrubbers is prohibited in domestic emission control areas, which includes coastal control areas and inland river control areas. Members can refer to a circular by Huatai to know the coordinates of these areas. In another circular, Huatai set out the inspection procedure which may be adopted by the authorities on ships installed with scrubbers.
	Hong Kong	If a ship intends to use scrubbers in Hong Kong waters, to meet the sulphur cap requirements, application must be made to the Hong Kong authorities requesting for an exemption from using compliant fuel. The exemption application must be made at least 14 days prior to a ship’s first visit to Hong Kong after 1 January 2019. For details of the exemption application process, please refer to Sections 7 to 11 of the new ‘Air Pollution Control (Fuel for Vessels) Regulation’.
	India	In DG Engineering Circular 02 of 2019, India appears to indicate that scrubber washwater discharges are allowed if the criteria set out in MEPC.259(68) are met. However, this is qualified with a requirement that local regulations should also be followed. As of now, it is not clear if local restrictions will be imposed in some areas
	Malaysia	In circular MSN 07/2019 Marine Department of Malaysia has indicated that discharge from open loop scrubbers is prohibited within the country’s waters (12 nm from nearest land). They have also issued MSN 08/2019 to clarify that the regulation does not apply to ships transiting the Malacca and Singapore straits.
	Pakistan	In their circular no. 001/2020, the Ministry of Maritime Affairs has prohibited the discharge of washwater from open loop scrubbers in Pakistani port waters. The circular advises vessels to either change over to closed loop mode of operation or switch to compliant fuel well in advance of the vessel’s arrival in port waters.
	Singapore	According to the Maritime and Port Authority of Singapore (MPA), discharge is prohibited in Singapore port waters from 1 January 2020. This has been done to maintain Singapore Port’s marine water quality standard. The prohibition does not apply to ships transiting the Traffic Separation Scheme (TSS) without calling into the Port of Singapore. MPA has published useful guidance on IMO’s 2020 Sulphur limits which can be accessed here. The document advises ships fitted with open loop scrubbers to ‘carry out the switch to either closed-loop mode or to compliant fuel well in advance of the vessel’s arrival at the port waters’. Residues from scrubbers have been classified as toxic industrial waste under Singapore’s Environmental Public Health (Toxic Industrial Waste) Regulations. It can only be collected by licensed Toxic Industrial Waste Collectors.
	UAE	Abu Dhabi: In 2013 Abu Dhabi authorities issued ‘Vessel Discharge and Maintenance Guidelines For Owners, Masters And Agents’. It was amended in 2018 and states that scrubber washwater can be discharged in port waters if free from pollutants whilst scrubber sludge should be discharged from the vessel to an Abu Dhabi Ports Company (ADPC) licensed waste disposal contractor.
	UAE	Fujairah: As per notice to mariners no. 252, Harbour Master of Fujairah has announced that use of open loop scrubbers will be banned in port waters. The circular can be found here.
EUROPE	Belgium	The European Commission’s 2016 note on discharge of scrubber washwater, bans the discharge in ports and inland waters. Relevant legislation is ‘Wet van 26 maart 1971 op de bescherming van de oppervlaktewateren tegen verontreiniging (Vlaams Gewest)’.
	Estonia	As per circular no.4 by Estonian Maritime Administration, use of open loop scrubbers is allowed if the owner can demonstrate that the washwater meets IMO’s requirements. However, port authorization is required if scrubber washwater is discharged in the port area.
	Finland	Our local correspondent reports that Finnish legislation does not impose any restrictions on the use of open loop scrubbers, however ports can make their own rules. Neste Porvoo Harbour is currently the only port in Finland where washwater discharge from open loop scrubbers is prohibited.
	France	Our correspondent informs us that there are restrictions in place on the use of open loop scrubbers in Port Jérôme-sur-Seine, Seine, Le Havre, Montoir, Nantes Saint-Nazaire and Bordeaux
	Germany	Discharge is not allowed in inland waterways and the Rhine, pursuant to Articles 1 and 3 of the CDNI Convention (Convention on the Collection, Deposit and Reception of Waste Produced during Navigation on the Rhine and Inland Waterways).
	Gibraltar	We have been informed by our correspondent that open loop scrubbers are temporarily not permitted as a precautionary measure until the Gibraltar Government arrives at a definitive policy decision on this issue.
	Ireland	Dublin: The Irish authorities’ Notice No. 37 of 2018 ‘Prohibition on the Discharge of Exhaust Gas Scrubber Wash Water’ stipulates that discharge of washwater is prohibited in waters under Dublin port jurisdiction. Dublin port jurisdiction includes waters from the Matt Talbot Memorial Bridge eastwards to a line from the Baily Lighthouse through the North and South Burford buoys and through Sorrento Point.
		Waterford: As per Port of Waterford’s marine notice ‘Prohibition on the Discharge of Exhaust Gas Scrubber Wash Water’, discharge of scrubber washwater is prohibited in port limits from the start of January 2019.
		Cork: Port notice No. 15 of 2018 states that given the potential for impact on sensitive ecosystems, and the abundance of Natura 2000 sites within the jurisdiction of the port company, discharge of scrubber washwater is prohibited in port waters.
	Latvia	General position, as mentioned in the European Commission’s 2016 note, is that discharge is not allowed in territorial and port waters. Discussions are currently ongoing within the European Commission, on improving the regulations and to provide more clarity.
	Lithuania	The authorities are currently studying the impact of scrubber washwater on the marine environment and will provide its conclusions upon completion of the study. Meanwhile, the current position seems to be that discharge is not allowed in port waters, according to port rules and conditions of use approved by the Ministry of Transport. Reference is made to the European Commission’s 2016 note on discharge of scrubber washwater.
	Norway	Under the amendments of 1 March 2019 to Regulation No.488 on the environmental safety of ships and mobile offshore units, use of open loop scrubbers is prohibited in the Norwegian fjords. Also, for ships using closed or hybrid type scrubbers, a device for reducing visible emissions to air is required.
	Portugal	According to our local correspondent, local laws prohibit the discharge into port waters any harmful waters or waste substances, as well as any other substances or residues that may in any way pollute the waters, beaches or shores, such as scrubber washwater.
	Russia	According to our correspondent, discharge of washwater from open loop scrubbers is prohibited in St. Petersburg and Primorsk. This is based on the requirements laid down in “General Rules of navigation and mooring of vessels in and on approaches to seaports of the Russian Federation” which restricts the discharge of any contaminated water in port. However there is no official notice published by authorities as yet.
	Scotland	According to Notice to Mariners No. 45 of 2019, use of open loop scrubbers is prohibited in the ports on the Forth and Tay. The Notice states that this measure is being implemented since there has been no confirmation at a National level in Scotland that the constituent parts of the washwater discharge has no impact on the Marine environment and in particular the effect on the local ecosystems within the Forth and Tay.
	Spain	Our correspondent informs us that the Harbour Master of Port of Algeciras has confirmed there is a prohibition on discharge of washwater from open loop scrubbers in port waters.
	Sweden	Port of Brofjorden does not allow the use of open loop scrubbers. Our correspondent informs us that port regulations will be updated to reflect this.

Summary and recommendations

Although exhaust gas scrubbers are an accepted abatement technology to meet IMO’s SOx emission rules for 2020, their use is not accepted globally in all states. If a members’ vessel is trading in area(s) where the discharge of scrubber washwater is not permitted, vessel operators have two options to choose from to ensure compliance with the sulphur limits:

switch over to closed loop mode of scrubber operation, in which case it will be necessary to convert currently installed open loop scrubber systems to closed loop or hybrid systems, if not already done; or
changeover to compliant fuel.

Any changeover should be carried out well in advance of the vessel entering the areas with prohibition or restrictions in place, and proper records should be maintained of such changeover. Early changeover will help in identifying operational issues, if any, after the changeover, and will allow for sufficient time to rectify such before the vessel enters the area.Owners’ and managers’ safety management procedures should contain guidelines on how to carry out the changeover safely and outline the recordkeeping requirements. It is also recommended that a vessel’s passage plan incorporates information on when to carry out the changeover, taking into account things such as duration of passage, time needed for changeover, density of traffic, proximity to hazards etc.

We advise Members and clients to monitor the situation closely and ensure that crew members onboard vessels fitted with open loop scrubbers are made aware of any relevant local discharge requirements in force. In general, vessels with any kind of scrubber installed should check with local authorities whether there are any applicable regulations in relation to the use of scrubbers, such as washwater discharge restrictions, and requirements to seek permission from authorities to use scrubbers.

Photo credit and source: Gard
Published: 21 August, 2020

ECA

VPS examines North-East Atlantic ECA on current bunker fuel mix and testing

Impact of this new ECA, will not only affect bunker fuel selection and testing, but it will also require a review of, voyage planning, bunker procurement and scrubber strategy, amongst others.

Published

2 months ago

May 14, 2026

Admin

Steve Bee, Group Marketing and Strategic Projects Director, and Emilian Buksak, Decarbonisation Advisor of marine fuels testing company VPS, on Wednesday (8 April) highlighted MEPC 84 approved a new emission control area (ECA) covering the North-East Atlantic Ocean, with agreements reached on adopted amendments to MARPOL Annex VI.

The new ECA, which will become the world’s largest emission control area, will be implemented on 1st September 2027

In a recent article, VPS outlined how VPS testing, data, CEM systems and advisory services can support vessels in both their operational and compliance challenges associated with this new ECA:

The recent International Maritime Organisation’s (IMO), Maritime Environmental Protection Committee (MEPC) meeting in London, had its main focus on setting binding greenhouse gas emission reduction targets for the global shipping sector. In keeping with the Committee’s continuing drive to decarbonise shipping and reduce the pollutant emissions from the global fleet, one major outcome from the MEPC-84 meeting was the approval of a new emission control area (ECA) covering the North East Atlantic Ocean, with agreements reached on adopted amendments to MARPOL Annex VI.

This new ECA, which will become the world’s largest emission control area, will be implemented on 1st September 2027, with the ECA requirements taking effect on 1st September 2028. It will cover the territorial seas and exclusive economic zones of Greenland, Iceland, the Faroe Islands, Ireland, the United Kingdom, France, Spain and Portugal, extending up to 200 nautical miles from their baselines:

VPS examines North-East Atlantic ECA impact on current bunker fuel mix and testing

A key advantage of the new NE Atlantic ECA is that it will close the gap between the existing ECAs in the North and Baltic Sea, plus the Mediterranean, creating an almost continuous zone of reduced shipping emissions. It will also connect to the newly approved ECAs in the Canadian Arctic and Norwegian Sea, which are scheduled for implementation in 2026 and 2027 respectively. Together these ECAs will cover almost half of all Arctic coastal waters, improving air quality, by reducing SOx, NOx and Particulate Matter (PM), protecting public health, and reducing the environmental impacts from shipping.

The sulphur limit for the marine fuels allowed to be burnt within this new ECA will reduce from the current 0.50% to 0.10%. This will force vessels to use either effective abatement technology (scrubbers), or alternatively burn marine distillates, ultra-low-sulphur fuels (ULSFOs), or biofuels with a sulphur content of less than 0.10%.

Without doubt this new ECA will cause a significant change to the current fuel mix, probably on an even greater scale than was witnessed with the introduction of the Mediterranean ECA back in May 2025. The fuel mix in the Mediterranean Pre-ECA implementation was, 53% VLSFO, 28% HSFO, 16% MGO, 2% ULSFO and 1% Biofuels. But from the 1st May 2025, the fuel mix changed to, 30% VLSFO, 29% HSFO, 30% MGO, 8% ULSFO and 4% Biofuels.

So, in terms of actual tonnage, the Mediterranean ECA witnessed a decrease in VLSFOs by 23%, whilst MGO usage increased by 107%. At the same time, ULSFO and biofuels supply increased 4-fold.

Regarding fuel quality within the Mediterranean post-ECA implementation, MGO off-specification rates increased to 4%. However, the most worrying off-specification rates were for ULSFOs which saw a 10-times increase from 2% to 20% from the start of the ECA, with the main off-specification parameters being pour point, sulphur, TSP, CCAI, water and viscosity.

Therefore, it is fair to assume we’ll witness a similar dramatic fuel mix change upon the implementation of the NE Atlantic ECA, with possibly similar fuel off-specification issues, highlighting the continuing need for proactive fuel testing to protect vessels, crew and the environment.

Whilst the focus on fuel quality is essential, the multi-pollutant nature of this new ECA, covering SOx, PM and NOx, also brings the role of continuous emissions monitoring increasingly to the fore. Therefore, a further consideration relating to the impact of this new ECA relates to vessel newbuilds and the stricter NOx Tier III requirements. For newbuilds subject to the stricter NOx Tier III requirements, compliance depends not only on engine certification at delivery, but on demonstrating that exhaust after-treatment systems, typically Selective Catalytic Reduction (SCR) or Exhaust Gas Recirculation (EGR), continue to perform as designed throughout the service life of the vessel.

For scrubber-equipped ships, real-time SO₂ measurement provides the operational evidence of equivalency that Port State Control inspections increasingly expect to see. Plus, for vessels operating under multiple overlapping regulatory regimes, including the new NE Atlantic ECA, EU MRV, EU ETS and FuelEU Maritime, continuous emissions monitoring via the VPS EMSYS CEM system delivers a single, verified source of emissions data that can be applied across all of them.

As noted by DNV in their MEPC 84 technical and regulatory update, the newly adopted IMO measurement guidelines can also be used for determining actual methane and nitrous oxide under the EU ETS and FuelEU Maritime, confirming the direct route from IMO-recognised measurement to EU compliance reporting.

At an operational level, the new ECA will introduce considerable complexity in the way fuel consumption is attributed across voyage segments, with VLSFOs burnt outside the zone and compliant fuels inside, all of which carry implications for consumption reporting, charterparty allocation and EU MRV alignment. VPS Maress can provide the underlying fuel and energy data into one auditable platform, helping crews manage the operational complexity that the new ECA introduces, including voyage segmentation, fuel changeover and emissions accounting, plus providing the consolidated data foundation that feeds existing EU MRV and IMO DCS reporting obligations.

VPS PortStats via the VPS Verisphere eco-system, (VeriSphere | VPS), further supports bunker procurement planning with port-by-port intelligence on compliant fuel availability and price spreads. Such intelligence and insights, will prove particularly valuable in the months immediately following 1st September 2028, when the supply pressure on 0.10% sulphur fuels is likely to peak.

Regarding the more strategic decisions ahead, including Tier III engine selection for newbuilds, retrofit feasibility for existing tonnage, and charterparty clauses allocating the ECA fuel cost premium between owners and charterers, VPS Advisory Services can provide the integrated commercial and technical perspective needed to navigate this transition with confidence.

Therefore, its clear the impact of this new ECA, will not only affect the choice of fuel to be burnt onboard and its subsequent quality testing, but it will also require a review of, voyage planning, bunker procurement, scrubber strategy, engine certification, compliance documentation and charterparty exposure.

Photo credit: VPS
Published: 14 May, 2026

Scrubbers

No open-loop EGCS with HSFO bunker fuel allowed in Saudi Arabian ports

Use of HSFO with an Open-Loop Exhaust Gas Cleaning System at 0.5% or 0.1% sulphur mode setting is prohibited until further notice for the ships entering Saudi Arabian ports, says GAC.

Published

8 months ago

December 8, 2025

Admin

Aramco: Ras Tanura Port, Eastern Province of Saudi Arabia, on the Arabian Gulf.

The use of High Sulphur Fuel Oil (HSFO) with an Open-Loop Exhaust Gas Cleaning System (EGCS) at 0.5% or 0.1% sulphur mode setting is prohibited until further notice for the ships entering Saudi Arabian ports, according to GAC Hot Port News on Wednesday (3 December).

All ships entering Aramco ports shall comply with one of the following options:

Use compliant fuel oil (≤ 0.50% m/m Sulphur, or ≤ 0.10% when operating in ECAs, if applicable).
Operate the EGCS in Closed-Loop mode (or Hybrid system in Closed mode), with strict prohibition on the discharge of wash water into the sea.

Photo credit: Aramco
Published: 8 December, 2025

Bunker Fuel

Equatorial navigates through sanctions and green transition amid shifting bunkering landscape

Shipowners’ demand for ‘cheapest compliant fuel’ suggests a potentially more competitive and shrinking market for LSFO, forecasts Choong Sheen Mao, COO at Equatorial.

Published

8 months ago

December 1, 2025

Admin

Equatorial navigates through sanctions and green transition amid shifting bunkering landscape

Singapore-based physical bunker supplier Equatorial Marine Fuel Management Services Pte Ltd (Equatorial) is adapting to a dynamic global bunker market shaped by regulatory shifts, geopolitical tensions, and the push for decarbonisation, states its Chief Operating Officer.

Choong Sheen Mao was amongst panellists of the Bunker Sellers Panel at IBIA Annual Convention 2025 in Hong Kong on Tuesday (18 November) when he shared a significant trend of shipowners increasingly opting for high sulphur fuel oil (HSFO) paired with scrubbers, driven by the pursuit of the “cheapest compliant fuel”.

Despite a narrowing spread between high and low sulphur fuels – from approximately USD 125 to USD 80, and occasionally below USD 70 – shipowners continue to see long-term investment returns from scrubbers. This shift suggests a potentially more competitive and shrinking market for low sulphur fuel oil (LSFO).

“Geopolitical instabilities, particularly armed conflicts, sanctions and trade wars, are creating considerable market distortions. These instabilities lead to supply disruptions, cargo rerouting, and impact bunker prices,” added Choong.

“Compliance has become a paramount concern, with recent substantial fines underscoring the risks involved. The current economic slowdown, compounded by sanctions and self-sanctioning, presents a ‘double pain’ for the market.

“The market’s daily volatility is also heavily influenced by global politics, making it challenging to assess without a deep understanding of geopolitical events.”

To ensure marine fuel quality, Equatorial emphasises managing its own supply chain and operating its own fleet of bunkering vessels, allowing for direct control from delivery to the customer, he stated.

This approach prioritises transparency and security, fostering long-term relationships where quality issues can be collaboratively addressed. Knowledge sharing, especially concerning parameters from new bunker fuel testing methods such as Gas Chromatography Mass Spectrometry (GC-MS), is also deemed crucial.

Supporting the transition to alternative marine fuels, while acknowledging the uncertainty surrounding the dominant future fuel, Equatorial has strategically invested in IMO Type 2 chemical tankers capable of handling methanol, biofuel, and conventional bunker fuels.

“Biofuel is identified as the most effective short-term solution, offering favourable pricing and operational costs compared to other green alternatives,” explained Choong.

“However, challenges include feedstock availability and potential export quotas from key producing nations like China.

“The adoption of alternative marine fuels necessitates a closer, more collaborative relationship between buyers and sellers.

“This involves detailed discussions on specific fuel specifications beyond standard ISO requirements, extensive lab sampling, and long-term commitments from both parties, particularly given the absence of a liquid hedging market for biofuels.

“Collaboration across safety, quality, and commercial aspects is essential for the successful implementation of bio bunker fuels to the future maritime market.”

Photo credit: International Bunker Industry Association
Published: 1 December, 2025