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IBIA: IMO sub-committee fails to improve clarity of 0.50% sulphur limit enforcement

Debunkering should only be required when it has been established, beyond reasonable doubt, that a ship is carrying fuel oil that exceeds the 0.50% sulphur limit.
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The International Bunker Industry Association on Monday (19 July) issued a statement encouraging clarity of the 0.50% sulphur limit enforcement:.

The seventh session of the IMO’s Sub-Committee on Implementation of IMO Instruments (III 7) has brought no further clarity regarding on what basis authorities can determine that a ship’s fuel is non-compliant with MARPOL Annex VI sulphur limits.

IBIA had put in a paper, III 7/5/8, co-sponsored by Jamaica to III 7, seeking primarily to protect ships from unreasonable debunkering demands by relevant authorities, as there is presently room for doubt about on which grounds that may happen. (Click here to see the document).

Our submission urged member states to implement the amended sulphur verification procedures in appendix VI of MARPOL Annex VI, adopted by MEPC 75, to ensure consistent implementation of the 0.50% sulphur limit which has been in force since the start of 2020.

Appendix VI of the adopted amendment, “Verification procedures for a MARPOL Annex VI fuel oil sample” states that “The following relevant verification procedure shall be used to determine whether the fuel oil delivered to, in use or carried for use on board a ship has met the applicable sulphur limit of regulation 14 of this Annex.”

Appendix VI goes on to provide two distinctly different procedures: Part 1 for the MARPOL delivered sample which it says “shall be used to verify the sulphur content of the fuel oil delivered to a ship” and Part 2 for in-use and onboard samples which it says “shall be used to verify the sulphur content of the fuel oil as represented by that sample of fuel oil at the point of sampling.”

Part 2 of the verification procedure for in-use and onboard sample takes into account the inherent uncertainty of the sulphur test method by recognising samples as having met the regulatory requirement as long as the test result does not exceed the limit +0.59R – also known as the 95% confidence interval.

If those procedures were always followed, we would have clarity. However, there have been cases where ships have been required to debunker after reporting to authorities that they have received a test result from their own fuel oil testing programme against ISO 8217 parameters, on the ship’s own sample, indicating a sulphur content marginally above 0.50%.

There have also been reports of authorities obtaining and testing in-use samples from ships and treating it as a non-compliant on the basis of a single test result above 0.50% sulphur, but within the 95% confidence interval, for example 0.51% or 0.52% sulphur.

For these reasons, our submission asked for assurance that port State control (PSC) authorities, if seeking to verify compliance with the 0.50% sulphur limit and the associated carriage ban, would follow the sulphur verification procedure in appendix VI adopted by MEPC 75. 

Debunkering should only be required when it has been established, beyond reasonable doubt, that a ship is carrying fuel oil that exceeds the 0.50% sulphur limit. This is why we also sought recognition that the 95% confidence principle should apply to fuel oil used and carried for use if, for any reason, an authority seeks to assess the ship’s compliance on the basis of a MARPOL delivered sample only, without obtaining an in-use or onboard sample to verify the ship’s compliance. This would provide the ship with the benefit of doubt against what remains a fairly arbitrary outcome, because a fuel which does in fact meet the limit may test marginally above that limit (as per 0.59R or 95% confidence limits).

However, we stressed that if the MARPOL delivered sample is above 0.50% sulphur, the fuel oil supplier would still be considered as not having met the requirement for the fuel as delivered, and could face enforcement action. The supplier does not get this “benefit of doubt” and therefore needs to use the limit minus 0.59R as the blend target to be 95% certain that a single laboratory won’t return an analysis result that is fractionally above the limit. For a 0.50% sulphur limit, this means the suppliers blend target must be 0.47% sulphur or less.

Parties to MARPOL Annex VI have an obligation to “take action as appropriate against fuel oil suppliers that have been found to deliver fuel oil that does not comply with that stated on the bunker delivery note”.

When the document was discussed at III 7, some delegations were of the opinion that asking for the outcome of testing a MARPOL delivered sample – in the case of the ship only – to be viewed in the same way as if an in-use or onboard sample had been tested, would interfere with the decisions made by MEPC on this issue and would lead to the use of fuels with 0.53% sulphur.

When IBIA pressed for clarity on the legal question as to what basis PSC might take enforcement action against the ship, the view was that the issues we raised in document III 7/5/8 concerning discrepancies in the enforcement of the 0.50% sulphur limit were not under the purview of the III Sub-Committee and should be referred to an appropriate IMO body.

We are disappointed that we could not get the legal certainty we were seeking, in particular regarding the basis for demanding debunkering of fuel that may, if tested again at a different laboratory, prove to be compliant given the inherent uncertainty of the test method.

Ideally, there should be legal certainty that PSC must verify the ship’s non-compliance on the basis of obtaining and testing and in-use or onboard sample. However, we do not have that certainty. While this uncertainty is not helpful for the industry, there are some positives. When speaking to member states about the issue prior to III 7, we found that many were supportive of the principle that debunkering should only be required when it has been established, beyond reasonable doubt, that a ship is carrying fuel oil that exceeds the 0.50% sulphur limit. Moreover, while some ships have faced debunkering demands that seem poorly justified, it does not appear to be widespread. Nevertheless, even a few such cases have caused considerable anxiety in the market.

On a final note, best practice for the bunker producer/supplier is to ensure that the product meets the specification limit with 95% confidence by using the limit minus 0.59R as the blend target, rather than the limit value. This should minimise the number of cases where a ship’s own initial test result indicates potential non-compliance with the mandatory sulphur limits, and the subsequent concerns about what kind of enforcement actions the ship may face.

 

Photo credit and source: International Bunker Industry Association
Published: 21 July, 2021

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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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