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DNV: Mediterranean SOx ECA, and heavy fuel oil ban in the Arctic

DNV dives into two new MARPOL regulations dictating fuel properties that are due to take effect in 2024 and 2025 – Mediterranean SOx ECA and the Arctic banning use and carriage for use of HFO.




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Classification society DNV on Wednesday (15 November) released a statutory news for ship owners and managers on the upcoming regulations dictating bunker fuel properties including the Mediterranean Sea becoming an ECA for SOx in 2025:

Two new MARPOL regulations dictating fuel properties are due to take effect in 2024 and 2025. This includes the Mediterranean Sea becoming an ECA for SOx in 2025, and the Arctic banning the use and carriage for use of HFO, which will take effect in 2024. More about this in this statutory news.

Mediterranean Sea – new ECA for SOx

As of 1 May 2025, the Mediterranean Sea will effectively become an Emission Control Area (ECA) for sulphur oxides (SOx) under MARPOL Annex VI Regulation 14. This implies that from then on when operating in the Mediterranean Sea, the sulphur content of the fuel used on board shall not exceed 0.10%, unless using an exhaust gas cleaning system (EGCS) ensuring an equivalent SOx emission level. 

This is believed to significantly reduce ambient levels of air pollution in the Mediterranean Sea and in the Mediterranean coastal states, providing benefits to human health and the environment.

At present, the other SOx ECAs under MARPOL are the Baltic Sea, the North Sea, the North American and the United States Caribbean Sea ECAs. In the future, we may see the designation of other SOx ECAs as well. One candidate may be a North-East Atlantic Ocean ECA linking the existing ECAs in the Baltic Sea and North Sea with the Mediterranean ECA.

Arctic waters – prohibition on the use and carriage for use of HFO

From 1 July 2024, heavy fuel oil (HFO) may no longer be used or carried as domestic fuel in bunker tanks when in Arctic waters, with some exceptions:

  • Ships engaged in securing the safety of ships, search and rescue operations, or dedicated to oil spill preparedness and response are exempted.
  • Ships subject to Regulation 12A of MARPOL Annex I (oil fuel tank protection) or Regulation 1.2.1* of Part II-A of the Polar Code may use and carry HFO until 1 July 2029.
  • when operating in domestic waters under the sovereignty or jurisdiction of their flag state may be temporarily waived until 1 July 2029.

HFO in this context implies fuel oil having a density at 15°C higher than 900 kg/m3 or a kinematic viscosity at 50°C higher than 180 mm2/s. It has been discussed whether to also include the pour point as an additional qualifier in the future, but this has not yet been concluded.

The cleaning or flushing of bunker tanks or pipelines is not required after using HFO to prepare for operation within Arctic waters. HFO carried as cargo on tankers is not affected by this regulation.


To stay compliant, it is important to ensure that sufficient fuel with the appropriate sulphur content is available and that proper fuel changeover procedures are in place and implemented before entering the Mediterranean Sea. For ships entering Artic waters, it is essential to ensure that any remaining HFO is disposed of before entering unless the ship is exempted.


Photo credit: Venti Views on Unsplash
Published: 17 November, 2023

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FOBAS: Update on Mediterranean Sulphur Oxides Emission Control Area (ECA-SOx)

FOBAS reminded ship operators that on 1 May, MARPOL Annex VI has been updated with addition of regulation 14.3.5 referring to Mediterranean Emission Control Areas, officially came into force on the same date.





Louis Reed from Unsplash

Lloyd’s Register Fuel Oil Bunkering Analysis and Advisory Service (FOBAS) on Tuesday (7 May) released a bulletin reminding ship operators that on 1 May, MARPOL Annex VI has been updated with addition of regulation 14.3.5 referring to Mediterranean Emission Control Areas:

This bulletin serves as a reminder to ship operators that on 1st of May 2024, MARPOL Annex VI has been updated with addition of regulation 14.3.5 referring to Mediterranean Emission Control Areas, officially came into force on aforementioned date. This confirms that ships operating in Mediterranean Sea need to comply with regulation 14.4 of MARPOL Annex VI i.e., the sulphur content of the fuel used onboard ships operating in emission control area shall not exceed 0.10% m/m (unless ship is using a sulphur oxides abatement technology such as exhaust gas scrubbers).

Currently, ships are exempt from this requirement until 1st May 2025 as per regulation 14.7 of MARPOL Annex VI which states that during the first 12 months of any amendment to the specified emission control area, ships operating in that area are exempt from the requirements of paragraph 4, 5 and 6 of regulation 14.

This may mean a significant change for many ships and could also affect the types of fuel available at certain ports so it will be essential to carefully plan for this change in advance of 1st May 2025.

Appendix VII of MARPOL Annex VI has also been updated with paragraph 4 which outlines the area and exact coordinates of the new Mediterranean emission control area as per following;

In respect of the application of regulation 14.4, the Mediterranean Sea Emission Control Area for Sulphur Oxides and Particulate Matter includes all waters bounded by the coasts of Europe, Africa and Asia, and is described by the following coordinates:

  1. the western entrance to the Straits of Gibraltar, defined as a line joining the extremities of Cap Trafalgar, Spain (36°11'.00 N, 6°02'.00 W) and Cape Spartel, Morocco (35°48'.00 N, 5°55'.00 W);
  2. the Strait of Canakkale, defined as a line joining Mehmetcik Burnu (40°03'N, 26°11'E) and Kumkale Burnu (40°01'.00 N, 26°12'.00 E); and
  3. the northern entrance to the Suez Canal excluding the area enclosed by geodesic lines connecting points 1-4 with the following coordinates:

Screenshot 2024 05 08 at 12.57.46 PM

Photo credit: Louis Reed from Unsplash
Published: 8 May 2024

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Port & Regulatory

DNV on IMO MEPC 81: Negotiations on new GHG reduction requirements continue

MEPC 81 continued its negotiation of GHG fuel intensity requirements, potentially in combination with a GHG pricing mechanism; approved proposals to designate Canadian Arctic and Norwegian Sea as ECAs for NOx, SOx and PM.





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Classification society DNV on Saturday (23 March) published a technical regulatory news titled ‘IMO MEPC 81: Negotiations On New Ghg Reduction Requirements Continue’. The following are excerpts from the update related to bunker fuel:

The 81st session of the IMO’s Marine Environment Protection Committee (MEPC 81) continued its negotiation of GHG fuel intensity requirements, potentially in combination with a GHG pricing mechanism. 

Other important decisions include the reporting of transport work and more granular fuel consumption data in the data collection system, and approval of proposals to designate the Canadian Arctic and the Norwegian Sea as NOx, SOx and PM Emission Control Areas.

Energy efficiency

Use of ShaPoLi/EPL systems in the EEXI framework

To ensure a consistent and uniform approach to the immediate availability of power, including the power reserve, when using overridable shaft/engine power limitation (ShaPoLi/EPL), MEPC 81 revised the ShaPoLi/EPL guidelines. The revisions are based on provisions set out in IACS Recommendation 172 for systems which do not physically limit shaft or engine power and where the override of shaft power limitation can be indicated by giving an alarm. In this context, manual shaft power limitation systems can inhibit the initiation of the exceedance alarm for up to 5 minutes.

Review of the Carbon Intensity Indicator (CII)

MEPC 81 did not agree on a resolution stating that the CII rating system is currently within an experience building phase and that key elements of the system should be considered interim. Although recognizing that there are shortcomings in the CII framework, it was agreed that the CII is not a provisional measure and that such a resolution would undermine the CII. The concerns raised should be considered as part of the upcoming CII review.

Revision of the Data Collection System (DCS)

MEPC 81 adopted revised guidelines on SEEMP related to reporting fuel oil consumption per consumer type and transport work. This supports the adopted amendments to MARPOL Annex VI mandating the reporting of additional data elements through the DCS.

Carriage of biofuel blends

A proposal to allow for carriage of blends of up to 30% biofuel on bunker barges certified according to MARPOL Annex I was forwarded to the ESPH (Evaluation of Safety and Pollution Hazards of Chemicals) Working Group for further consideration.

Unified Interpretations

MEPC 81 agreed on Unified Interpretations to MARPOL Annex VI regarding:

  • the definition of heavy load carriers and
  • the application of the required EEDI to LNG carriers, cruise passenger ships, ro-ro passenger ships, ro-ro cargo ships (vehicle carrier) and ro-ro cargo ships, delivered on or after 1 September 2019.

Reduction of GHG emissions

Mid and long-term measures to reduce GHG emissions

To ensure shipping achieves the ambitions of the 2023 IMO GHG Strategy, the MEPC 80 decided to implement a basket of measures consisting of two parts:

  • A technical element,which will be a goal-based marine fuel standard regulating the phased reduction of marine fuel GHG intensity
  • An economic element,which will be GHG emissions pricing mechanism, linked directly to the GHG intensity mechanism or as a stand-alone mechanism

The measures are scheduled to be adopted in 2025 and enter into force around mid-2027.

At MEPC 81, several regulatory proposals were on the table. While there was no agreement on the package of measures, there was convergence between member states, along with agreement on an overarching structure for the needed regulatory amendments, the “IMO net-zero framework”, in MARPOL Annex VI. This is intended to form the basis for refined proposals, including possible legal language, to be discussed at MEPC 82 in October 2024.

MEPC 81 also agreed to organise the expert workshop on the further development of the basket of mid-term measures, intended to facilitate the understanding of the preliminary findings of the comprehensive impact assessment, which are expected to be available by mid-summer.

Life cycle GHG/carbon intensity for marine fuels

MEPC 81 adopted amendments to the “Guidelines on Life Cycle GHG Intensity of Marine Fuels” (LCA Guidelines), which set out methods for calculating well-to-wake and tank-to-wake GHG emissions for all fuels and other energy carriers (e.g. electricity) used on board a ship. The amendments included the quantification of parameters related to biofuel production, the evaluation of GHG intensity of electricity and the actual tank-to-wake methodologies for actual/onboard emission factors, amongst others.

The LCA Guidelines do not include any provisions for application nor requirements; they are intended to support the GHG Fuel Intensity regulation under development. 

A GESAMP Working Group was established to consider new default fuel pathway values, certification of actual well-to-tank and tank-to-well emission factors, and more general methodological LCA issues. A Correspondence Group was established to address other social and economic sustainability topics and aspects of marine fuels, for possible later inclusion in the LCA Guidelines.

MEPC 81 considered how to develop a framework for the measurement and verification of tank-to-wake emissions of methane (CH4) and nitrous oxide (N2O) in the context of the LCA Guidelines. A separate Correspondence Group was established to further progress the matter.

On-board carbon capture

MEPC 81 discussed the issue of on-board carbon capture and established a Correspondence Group to further discuss the matter and develop a working plan on the development of a regulatory framework for the use of on-board carbon capture systems.

Identification and protection of Emission Control Areas (ECAs)

MEPC 81 approved proposals to designate the Canadian Arctic and the Norwegian Sea as ECAs for nitrogen oxides (NOx), sulphur oxides (SOx) and particulate matter (PM).

For the Canadian Arctic, assuming adoption at MEPC 82, the requirements take effect as follows:

  • The 0.10% fuel sulphur content requirement takes effect from1 March 2027.
  • TierIII NOx requirements will apply to ships constructed on or after 1 January 2025, although the requirements will enter into force at the earliest on 1 March 2026.

For the Norwegian Sea, also assuming adoption at MEPC 82, the requirements take effect as follows:

  • The 0.10% fuel sulphur content requirement takes effect from 1 March 2027.
  • TierIIINOx requirements will apply to ships contracted on or after 1 March 2026; or, in the absence of a contract, keel-laid on or after 1 September 2026; or delivered on or after 1 March 2030.


DNV recommends that our customers take into account the work on new GHG reduction ambitions when considering energy efficiency, alternative fuels and other GHG reduction options for their existing fleet and newbuilds, and note the requirements with expected entry into force around mid-2027.

Companies operating in the Canadian Arctic and Norwegian Sea are advised to note the establishment of ECAs and the attendant effective dates of the requirements.

We also recommend signing up for our dedicated webinar, discussing the outcome of MEPC 81, taking place on 3 April 2024: emissions-regulations-and-more/ 

Note: The full TECHNICAL REGULATORY NEWS No. 07/2024 – STATUTORY can be downloaded here.


Photo credit: shraga kopstein on Unsplash
Published: 25 March 2024

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Argus Media: Norway, Canada propose ECAs for Arctic waters

Both countries submitted proposals to designate their Arctic Ocean waters as emissions control areas during MPEC 81; both areas are not covered by existing North Sea and North America ECAs.





resized argusmedia

Delegates from Canada and Norway submitted proposals to designate their Arctic Ocean waters as emissions control areas (ECAs) during the International Maritime Organisation's (IMO) 81st Marine Environment Protection Committee (MEPC) meeting.

19 March 2024

Canada's proposal would regulate its Arctic waters as an ECA for nitrogen oxide (NOX), sulphur oxide (SOX), and particular matter (PM), while Norway proposes an ECA for NOX and SOX emissions. The two areas are not covered by the existing North Sea and North America ECAs.

The proposals were met positively by most other groups at the meeting, including delegates from the Cook Islands, Finland, the US, Mexico, Panama, and Ireland — all of whom supported the proposals going into consideration by the technical committee.

But the proposals faced resistance from the Russian Federation, whose delegate said the proposals do not meet the "specified requirements for ECA designation" under MARPOL regulations — pointing to insignificant navigation networks in those areas, lack of a major port, and a sparse population in the two areas under the proposal. The delegate from Russia added that the control measures against NOX and SOX emissions in those areas can be introduced on a national legislative level, rather than being proposed under MARPOL regulations.

The session concluded with MEPC agreeing to establish a technical group on the designation of ECAs to evaluate the two proposals.

By Hussein Al-Khalisy

Related: IMO MPEC 81st session to be held between 18 to 22 March


Photo credit and source: Argus Media
Published: 19 March 2024

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