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IMO 2020

2020: Voyage to the Bottom of the Tank

Cautious and quality approach required to deal with complexities in an ordered fashion, writes GAC.

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Nick Browne, the Global Director at GAC Bunker Fuels, on Friday (28 June) published an article which discusses the management of various complexities that IMO 2020 introduce. The article, shared with Manifold Times, first appeared in GAC WORLD magazine, Issue No.3 of 2019. You can download your copy at www.gac.com/magazine/

On 1 January 2020, the International Maritime Organisation’s (IMO) new sulphur limit for marine fuels will come into force.

Sulphur emissions are the main source of acid rain. They also acidify waterways and corrode buildings and infrastructure. Noxious sulphur particles affect the respiratory health of every human that lives near a shipping channel or port. The IMO’s new sulphur limit for bunker fuels is just 0.5%, giving us all a clear message about the seriousness of the sulphur emission problem. For the majority of shipping companies that are still burning fuel with 3.5% sulphur content, it’s going to be a big adjustment, affecting costs and equipment.

The IMO has been working to reduce the harmful impacts of shipping on the environment since the 1960s; think ballast contaminants and anti-fouling rules. The upcoming lowering of sulphur oxide emissions is expected to have a significant benefit on the environment and on human health, particularly for people living in port cities and coastal communities. The Yale School of Forestry & Environmental Studies reckons that once the new sulphur cap takes effect, it will prevent roughly 150,000 premature deaths and 7.6 million childhood asthma cases globally each year.

The essential points

· From 1 January 2020, vessels taking on fuel oil for use on board must obtain a bunker delivery note stating the sulphur content of the fuel oil supplied.
· Samples may be taken for verification.
· Vessels must have an International Air Pollution Prevention (IAPP) Certificate issued by their Flag State.
· The certificate must include a section stating that the fuel oil’s sulphur content does not exceed the applicable limit.

The switch over is a complex matter since a lot of transitional issues need to be taken into consideration by both Owners and Charterers. Among these issues are two that I believe are critical:

1.  Where the burden of responsibility lies for ensuring a vessel is compliant
2.  What to do if no compliant fuel is available in the port where you are calling.

Customer is responsible
Since 1 January 2019, changes have been made to the Bunker Delivery Note (BDN) through Marpol Annex VI appendix V. There is now a declaration required, signed by the fuel oil supplier’s representative, to certify that the fuel oil supplied by the supplier conforms with the regulation 14(1) or (4)(a) and regulation 18 (1) within the Annex. This implies that the bunker supplier is responsible for getting confirmation that the vessel has an approved Exhaust Gas Cleaning System (EGCS) but this is not the case. Notification is required but no proof.

This means that the weight of responsibility for compliance rests with the vessel owner/charterer, not the supplier. This doesn’t preclude the supplier or bunker trader from enhancing its own Know Your Customer (KYC) process and asking for evidence that there is an approved EGCS on board.

What if the fuel you need is not available?

Although more and more suppliers are confirming availability of the new 0.5% fuel oil, some shipowners will discover that compliant fuel may not be available in their chosen bunkering port.

The good news is that the IMO has thought this issue through. The bad news is that the solution requires substantial documentation via the IMO Fuel Oil Non Availability Report (FONAR). The IMO states:

‘The ship shall present a record of the actions taken to attempt to achieve compliance; and provide evidence that it attempted to purchase compliant fuel oil in accordance with its voyage plan and, if it was not made available where planned, that attempts were made to locate alternative sources for such fuel oil and that despite best efforts to obtain compliant fuel oil, no such fuel oil was made available for purchase.’

The point to be taken from all the challenges involved in the new sulphur cap is that a cautious and quality approach is required to deal with all the complexities in an ordered fashion.

Discussions deep

GAC Bunker Fuels has been in deep discussions with our clients regarding the various options and timings for complying with the new sulphur content rules. We are now working with clients on their bespoke Fuel Changeover Plans. We may act as consultants or work directly with providers to arrange key services such as de-bunkering, tank cleaning and re-bunkering with compliant fuel.

If you think you might benefit from a conversation with us about the 2020 sulphur cap or your bunker procurement needs, drop us a line at [email protected].

Photo credit: GAC Bunker Fuels
Published: 2 July, 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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