Legal

Beware of ‘perfect storm’ when complying with IMO 2020 regulations

IMO 2020 is gearing up to the perfect storm for litigators, warns Hill Dickinson partner in the marine team.

Published

7 years ago

December 4, 2019

Admin

The following article discussing potential legal issues from IMO 2020 has been written by Beth Bradley of international legal firm Hill Dickinson:

Low sulphur fuel regulations, set to come into force on 1 January 2020, have the potential to present ‘the perfect storm’ for litigators dealing with disputes between owners, charterers and bunker suppliers in cases of non-compliance, warns a senior lawyer at international maritime law specialist Hill Dickinson.

As the shipping industry prepares for the introduction of the global cap on sulphur content in fuel to be burned on board at 0.50% max, there are concerns around the practical and contractual challenges presented.

Shipowners bear the responsibility for complying with the global sulphur cap and are the target for enforcement by the Marpol ???(the International Convention for the Prevention of Pollution from Ships) authorities. Where a vessel is not fitted with a scrubber, ensuring compliance presents a number of complicated practical issues for shipowners, ranging from availability of compliant bunkers, completeness of paperwork on board, tank and line cleaning through to a detailed understanding of fuel stability, compatibility and fuel segregation issues.

Contractually, shipowners tend to devolve the responsibility for suppling the vessel’s bunkers to their time charterers and this may give rise to contractual disputes, particularly where fuel supplied is found to be marginally above the 0.50% sulphur content absolute limit set by the International Maritime Organization (IMO).

There is presently little guidance available as to the attitude which will be taken by the Marpol authorities to marginal breaches of the sulphur cap. Each authority is able to set its own regulations, and potentially enforcement, and the fines associated with breaches will be uneven.

Stressing the importance of having detailed and careful charter party arrangements post Jan 1, Beth Bradley, a Hill Dickinson partner in the marine team, says: ‘There are a great number of issues which may radically impact on the liability situation. It’s gearing up to the perfect storm for litigators.

‘The interesting area is what happens where you’ve ordered a compliant fuel, it looks like a compliant fuel, but when it’s tested it’s just off-spec, just slightly over the 0.50% – whose responsibility is that?

‘We know how bunker quality disputes usually work out between owners and time charterers and time charterers and bunker suppliers – there is always a fight about whether the problem arose from the fuel supplied or how it was handled on board. The sulphur cap adds a further layer of complication. If the relevant authority concludes that the vessel has to de-bunker, who is going to pay the costs? There will be a lot more focus on what has happened onboard. Such as, were the lines completely clean? Were the tanks completely clean? Further, the potential disparity between the Marpol sample and commercial samples will come into sharper focus – owners will be fined on the basis of the Marpol sample and contractual disputes are likely to focus on the commercial sample and arguments around the applicable margin of error to test results as charterers and bunker suppliers seek to show that they delivered compliant fuel’.

Hill Dickinson strongly recommends that time charterparties and related bunker supply contracts should contain carefully worded provisions to clarify bunker specifications, sampling procedures and how the potential loss of time owing to inspections and de-bunkering operations is to be shared.

Ms Bradley concluded: ‘The shipping industry has come a long way in terms of preparing for the introduction of the global sulphur cap, but there is a great deal of uncertainty around the availability of compliant fuel away from the main bunker hubs and how the cap will be enforced. A lot of the associated risks can be managed contractually and through on-board procedures, but when disputes arise they are likely to be more complicated’.

Photo credit and source: Hill Dickinson
Published: 4 December, 2019

Winding up

Singapore: Final general meetings scheduled for Dromond Shipping, related firms

A member is entitled to attend the meetings and should notify the liquidators’ team office via email no later than 48 hours prior to the meeting.

Published

6 hours ago

September 21, 2026

Admin

The final general meetings of Dromond Shipping Pte Ltd and related companies have been scheduled to take place on 19 October, according to the company’s liquidator on a notice posted on Friday (18 September) on the Government Gazette.

The other companies are Tidewater Emergency Response Services Pte Ltd, Tidewater Production Solutions Pte Ltd and Tidewater Salvage Pte Ltd.

The final general meetings of the members of the companies will be held via electronic means on 19 October 2026 at 2.00 pm, 2.30 pm, 3.00 pm and 3.30 pm (Singapore time), respectively.

The meetings are being held for the purpose of having accounts laid before the members showing the manner in which the winding up of the respective companies has been conducted and how the property of the respective companies has been disposed of and to hear any explanation that may be given by the liquidators.

The details of the liquidator is as follows:

Tan Kim Han
Joint and Several Liquidators
137 Amoy Street, #02-03, Far East Square
Singapore 049965

Note: A member is entitled to attend the above meeting and should notify the Liquidators’ team office via email to [email protected] or [email protected] no later than 48 hours prior to the meeting.

Photo credit: steve pb from Pixabay
Published: 21 September, 2026

Winding up

Singapore: Liquidator of Da Xin Tankers, Nan Chiau Maritime issues notices of dividend

Da Xin Tankers’s second interim dividend and Nan Chiau Maritime’s third interim dividend are payable from 17 September, according to Government Gazette notices.

Published

3 days ago

September 18, 2026

Admin

Notices of dividend for Da Xin Tankers Pte Ltd and Nan Chiau Maritime Pte Ltd, which are currently in creditors’ voluntary liquidation, were published on the Government Gazette on Thursday (17 September).

The following are the details of the notice for Da Xin Tankers:

Name of Company : Da Xin Tankers (Pte) Ltd (In Creditor’s Voluntary Liquidation)
Unique Entity No. / Registration No. : 198400895W
Address of Registered Office : c/o Grant Thornton Singapore Private Limited, 8 Marina View, #40-04/05 Asia Square Tower 1, Singapore 018960
Amount per centum (US$) : 5.00 cents to a dollar of admitted unsecured claims
First and Final or otherwise : Second Interim Dividend
When payable : 17 September 2026
Where payable : Entitlements will be made either by way of telegraphic transfer or by cheque, to be collected from the Company’s registered address as above

The following are the details of the notice for Nan Chiau Maritime:

Name of Company : Nan Chiau Maritime (Pte.) Ltd. (In Creditors’ Voluntary Liquidation)
Unique Entity No. / Registration No.: 200814296Z
Address of Registered Office : c/o Grant Thornton Singapore Private Limited, 8 Marina View, #40-04/05 Asia Square Tower 1, Singapore 018960
Amount per centum (US$) : 7.00 cents to a dollar of admitted unsecured claims
First and Final or otherwise : Third Interim Dividend
When payable : 17 September 2026
Where payable : Entitlements will be made either by way of telegraphic transfer or by cheque, to be collected from the Company’s registered address as above.

Photo credit: Benjamin Child
Published: 18 September, 2026

Winding up

Singapore: Marine fuel testing firm CCIC Singapore faces winding up application

Application for the winding up of CCIC Singapore Pte Ltd was filed by Hong Kong-registered CCIC International Holding Limited on 7 September, according to Government Gazette notice.

Published

6 days ago

September 15, 2026

Admin

An application for the winding up of marine fuel testing and surveying firm CCIC Singapore Pte Ltd (CCIC Singapore) was filed by Hong Kong-registered CCIC International Holding Limited on 7 September, according to a Monday (14 September) notice on the Government Gazette.

It noted the winding up application is directed to be heard before the Judge sitting in the General Division of the High Court at 10am on 2 October.

Manifold Times previously reported US Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned nearly two dozen firms operating in multiple jurisdictions, including CCIC Singapore.

OFAC alleged that Sepehr Energy “consistently relied” on CCIC Singapore to accomplish not only the necessary pre-delivery cargo inspections required before oil is transferred to China, but also to conceal the oil’s Iranian origins.

In late 2024, CCIC Singapore provided inspection services during a ship-to-ship transfer of approximately two million barrels of Iranian oil from the sanctioned vessel and Sepehr Energy-affiliated SIRI (IMO 9281683), formerly known as the ANTHEA.

In June 2025, CNA reported that the company laid off hundreds of workers after it was hit with the sanctions. Later, the CCIC Singapore told CNA that the layoffs were due to the impact of the sanctions which was greater than expected, and that it has ceased operations in Singapore.

According to the Government Gazette notice, any creditor or contributory of the company desiring to support or oppose the making of an order on the winding up application may appear at the time of hearing by himself or his counsel for that purpose.

A copy of the winding up application will be furnished to any creditor or contributory of the company requiring the copy of the winding up application by the solicitors of the applicant’s, Oon & Bazul LLC, on payment of the regulated charge for the same.

The Applicant’s address is 29/F, East Tower, Shun Tak Centre, 168-200 Connaught, Rd Central, Hong Kong, China.

The Applicant’s solicitors are TKQP Law LLP of 1 Wallich Street, #07-02 Guoco Tower, Singapore 078881.

Note: Any person who intends to appear at the hearing of the winding up application must send notice of such intention to the abovenamed TKQP Law LLP, the Claimant’s solicitors, within the time and in the manner set out in rule 70 of the Insolvency, Restructuring and Dissolution (Corporate Insolvency and Restructuring) Rules 2020. The notice must be in Form CIR-15 and state the name and address of the person, or, if a firm, the name and address of the firm, and must be signed by the person, firm, or his or their solicitor (if any) and must be served and, if sent by post, must be posted in such time as in the ordinary course of post to reach the address of the Claimant’s abovenamed solicitors, at least 3 clear working days before 2 October 2026 (the day appointed for the hearing of the application).

Photo credit: Manifold Times
Published: 15 September, 2026