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Gard alert: Sulphur cap ahead!

Hong Kong and Taiwan are aligning their emission regulations with the Chinese ECA requirements.

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Maritime insurance agency Gard on Thursday published the following article informing parties of local 0.50% sulphur caps being introduced at Hong Kong and Taiwan.

While all eyes are on 2020 and the introduction of the IMO’s global sulphur cap, Hong Kong and Taiwan are aligning their emission regulations with the Chinese ECA requirements and will implement a local 0.50% sulphur cap from 1 January 2019.

The 2020 global sulphur cap

The IMO Marine Environment Protection Committee’s 73rd session (MEPC73) has just ended, and with it, so did all speculations about a potential delay of the global 0.50% sulphur cap. The rules apply from 1 January 2020 – and they will be enforced.

To ensure a consistent implementation and enforcement, the MEPC73 also adopted the ‘carriage ban’, a complementary MARPOL amendment that will prohibit the carriage of fuel with a sulphur content of more than 0.50%  for combustion purposes for propulsion or operation on board a ship – unless the ship is equipped with an exhaust gas cleaning system, such as a SOx scrubber. The carriage ban is expected to enter into force on 1 March 2020 but does not alter the 1 January 2020 deadline for the 0.50% sulphur cap.

Meanwhile, ship operators, in their preparations for the global sulphur cap, must not overlook the designated areas in which different sulphur limits already apply. Come 1 January 2020, the 0.10% sulphur limit continue to apply inside the North American, US Caribbean, North Sea and Baltic emission control areas (ECAs) designated under MARPOL Annex VI, as does the 0.10% sulphur limit for ships at berth in EU ports. China has designated its own domestic ECAs and implemented more stringent emission requirements in these areas. Hong Kong and Taiwan have now announced that they will move in a similar direction and will implement a 0.50% sulphur cap one year ahead of the IMO.

Other governments and port authorities may also choose to implement local air pollution regulations that are stricter than the IMO requirements. One example is California and the California Air Resource Board’s enforcement of very stringent environmental regulations in the state’s waters and ports.

Hong Kong

Hong Kong’s current Fuel at Berth Regulation requiring ships to burn fuel with a sulphur content not exceeding 0.50% while at berth is soon to be replaced by one that will extend the standard to ships operating in Hong Kong waters. In a press release dated 26 October 2018, Hong Kong’s Environmental Protection Department (EPD) notified the industry of its approval of the new “Air Pollution Control (Fuel for Vessels) Regulation”. This will mean that from 1 January 2019, ships not fitted with scrubbers will be required to burn fuel with a sulphur content not exceeding 0.50% within Hong Kong waters, irrespective of whether they are sailing or at berth.

Taiwan

Taiwan’s Ministry of Transport and Communication (MOTC) has also announced it will implement a 0.50% sulphur cap one year ahead of the IMO. According to Gard’s local correspondent, there will be no designated domestic ECAs in Taiwan but from 1 January 2019, ships not fitted with scrubbers must burn fuel with a sulphur content not exceeding 0.50% when entering its international commercial port areas.

The extent of the international commercial port areas can be found by following the hyperlinks included below and the correspondent explains that the areas within the red dotted line must be regarded as the commercial port areas in which the 0.50% sulphur cap applies.

Chinese: https://www.twport.com.tw/chinese/Form.aspx?n=3FDB9008DF19C02B
English: https://www.twport.com.tw/en/cp.aspx?n=24926B8167A3C236
We are grateful to Taiwan Maritime Services Ltd. for providing this information.

China Mainland

In September 2015, China designated the Pearl River and Yangtze River Deltas, and Bohai-rim Waters as domestic ECAs and announced a plan for implementing a 0.50% sulphur cap in these areas. 1 January 2019 marks the final step in China’s ECA timeline and from this date ships not fitted with scrubbers must burn fuel with a sulphur content not exceeding 0.50% while operating anywhere within the ECAs. Details of the geographical extent of the three domestic ECAs is available HERE.

Although some media reports have indicated that China may, as of 1 January 2019, expand the geographical coverage of the 0.50% sulphur cap to apply to ships sailing within its entire territorial sea, we are, at the time of writing, not aware that the Chinese government has issued any formal notice to this effect.

Recommendations

Members and clients with ships trading to Asia Pacific should plan for compliance with the local 0.50% sulphur cap that enters into force in Hong Kong, Taiwan and Mainland China on 1 January 2019, and ensure that appropriate procedures have been implemented onboard and that the crew is familiar with them. Ship owners and operators should:

  • emphasise that a ship’s fuel changeover operations must be completed prior to the entry into or commenced after exit from a designated area;
  • in order to avoid contamination, ensure that the written changeover procedure allow sufficient time for the fuel oil service system to be fully flushed of all fuel oils exceeding the applicable sulphur content prior to entry into the designated area;
  • highlight the importance of correctly completing ships’ log books, by including items such as the time when fuel changeover operations are performed, the volume of low sulphur fuel oils in each tank, as well as the date, time, and position of the ship when any fuel oil changeover operation has been completed prior to the entry into the designated area or commenced after exit from such an area;
  • ensure that the quality of fuel purchased can be documented, e.g. by obtaining and retaining onboard bunker delivery notes (BDNs) and representative samples of the low sulphur fuel oil delivered; and
  • verify the applicable sulphur emission requirements at any given time with the local agent or port authorities well before arrival as local cities and relevant authorities continue to evaluate the implementation of the new regulation and the control measures to be taken.

We also take this opportunity to remind Members and clients that, with less than 14 months left until the global sulphur cap enters into force, it is particularly important to start preparations now. And – although it is not a mandatory requirement – we support the IMO’s recommendation to develop ship implementation plans (SIP). A SIP will help shipowners and operators to plan and demonstrate the steps taken by ships to prepare for compliance with the 0.50% sulphur limit on 1 January 2020, and should include items such as:

  • risk assessment and mitigation (impact of new fuels);
  • fuel oil system modifications and tank cleaning (if needed);
  • fuel oil capacity and segregation capability;
  • procurement of compliant fuel;
  • fuel oil changeover plan (conventional residual fuel oils to 0.50% sulphur compliant fuel oil); and
  • documentation and reporting.

An IMO guidance on the development of a SIP was approved during MEPC73 and will soon be issued as MEPC.1/Circ.878. The guidelines prepared by International Chamber of Shipping should also be taken into account.

Source: Gard
Published: 7 November, 2018

 

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Bunker Fuel

Alkagesta highlights key insights of Malta bunkering market in 2026

Darren Lee Axisa discusses the key trends influencing Malta’s bunkering market and the factors that will determine Malta’s long-term competitiveness as a regional bunkering hub.

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Alkagesta highlights key insights of Malta bunkering market in 2026

In an article published on Alkagesta Market Insights, Darren Lee Axisa, Malta Country Manager of Alkagesta, on Monday (20 July) discussed the key trends influencing Malta’s bunkering market and the factors that will determine Malta’s long-term competitiveness as a regional bunkering hub: 

Malta’s bunkering and energy market is moving through a period of structural adjustment. The disruptions that defined the first half of 2026 have accelerated shifts in product demand, terminal strategy, and the competitive dynamics of one of the Mediterranean’s most strategically positioned bunkering hubs. For Alkagesta, whose storage footprint on the island approaches 300,000 cubic metres, the period has tested operational flexibility while reinforcing the value of diversified infrastructure access.

A Market Shifting in Two Directions

Malta’s broader economy has remained resilient — GDP growth reached 3.9% in Q1 2026 — but the bunkering market has undergone a significant product mix shift, the roots of which predate the current geopolitical disruption.

The Mediterranean Emission Control Area, which came into force on 1 May 2025, triggered an immediate and measurable realignment in fuel demand across the region. VPS data covering the first six months post-ECA implementation shows that across the top ten Mediterranean bunkering ports, VLSFO volumes fell 23%, MGO more than doubled, ULSFO quadrupled, and biofuels increased fivefold. In Valletta specifically, the shift was even more pronounced: VLSFO dropped 57% from 111,641 mt to 47,732 mt, while MGO volumes more than tripled from 33,299 mt to 103,445 mt, and ULSFO rose from 2,821 mt to 34,535 mt over the same period.

This structural rotation has been further accelerated by the broader regulatory environment. FuelEU Maritime and EU ETS requirements are pushing shipowners toward cleaner, verifiable fuel options at every port call — a direction Alkagesta had already positioned itself ahead of, having been among the first movers in the Mediterranean to support the transition to 0.1% sulphur fuel oil following the ECA’s introduction.

Layered on top of this regulatory shift has been a period of reduced terminal capacity affecting bunkering market availability across the island. Fuel oil volumes dropped roughly 35% year-on-year between January and May 2026, falling from approximately 382,000 mt in 2025 to 247,000 mt. DMA demand moved sharply in the opposite direction, rising from around 150,000 mt in January to April 2025 to 247,000 mt over the same period in 2026 — a trend consistent with both the ECA-driven product mix shift and the disruption to heavier fuel availability during the constrained period.

Note: The full article can be read here

 

Photo credit: Alkagesta
Published: 22 July, 2026

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ECA

NorthStandard issues operational guidance for vessels entering ECAs

Jordan Hatch, Loss Prevention Executive, issued guidance for vessels operating in Emission Control Areas (ECAs).

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Jordan Hatch, Loss Prevention Executive of global marine insurer NorthStandard, on Thursday (2 July) issued guidance for vessels operating in Emission Control Areas (ECAs):

The IMO addresses air pollution through MARPOL Annex VI, regulating the emissions of sulphur oxides (SOx), nitrogen oxides (NOx), and particulate matter from ships.

NOx requirements set limits on emissions from marine diesel engines through certification and tiered standards, whilst SOx regulations limit the sulphur content of fuel used onboard ships.

On 1 January 2020, the global sulphur limit for marine fuel was reduced from 3.50% to 0.50% by mass (m/m). However, some areas, known as SOx Emission Control Areas (ECAs), enforce stricter limits of 0.10% sulphur content. There are also dedicated NOx ECAs which impose tighter NOx emission standards for marine engines, particularly on newer vessels.

To meet the stricter SOx limits, ships must ensure they are burning compliant 0.10% sulphur fuel before entering an ECA. If a vessel is changing over from a 0.50% sulphur fuel, this requires a ship-specific calculation based on system volume, sulphur content, and current consumption to determine changeover time. Fuel changeover details, including quantities, date, time, and position, must be logged. Switching back to higher sulphur fuel should only begin after exiting the ECA.

To meet NOx requirements, vessels must demonstrate that their marine engines are certified to the applicable emission tier, and that they continue to operate within those limits through proper maintenance of combustion-related components.

Local Requirements

Some countries apply stricter local requirements in addition to MARPOL Annex VI. For example, Türkiye and Iceland have introduced a 0.10% sulphur limit in their territorial waters, while China has established its own dedicated ECAs.  

Members should check all applicable local requirements before entry and ensure that compliant fuel is available onboard, with sufficient time allowed for fuel changeover.

Scrubber Use

MARPOL allows for equivalent measures in the SOx regulations which means vessels can use exhaust gas cleaning systems (scrubbers) to meet both the global and ECA sulphur caps. Scrubbers remove sulphur from exhaust gases, with wash water as a byproduct, allowing the use of higher-sulphur fuels when operated and maintained according to IMO guidelines in MEPC.340(77).

Scrubbers are available as open-loop (discharging wash water directly into the sea), closed-loop (treating and recirculating the wash water) or hybrid systems. Local regulations vary by country, so members should consult specific guidelines on open or closed-loop usage; our resource here can be used as a guide.

New ECAs

The coverage of ECAs continues to expand, with MEPC 84 adopting the largest ECA to date in the North-East Atlantic.

Mediterranean Sea ECA

Entering into force on 1 May 2025, the Mediterranean Sea is now designated as an ECA, with the 0.10% sulphur limit in effect. Further details can be found here.

The Canadian Arctic and the Norwegian Sea ECA

The amendments to MARPOL Annex VI that designated the Canadian Arctic and the Norwegian Sea as new ECAs entered in to force on 1 March 2026. Both the Canadian Arctic and the Norwegian Sea ECAs for SOx will take effect on 1 March 2027, one year after these amendments came into force.

North-East Atlantic Ocean ECA

At MEPC 84 in 2026, the IMO adopted the North-East Atlantic Ocean as a new Emission Control Area, now the largest ECA designated to date.

This ECA covers a wide area including the waters of Greenland, Iceland, the Faroe Islands, and the western coasts of the United Kingdom and Ireland, extending south to Spain and Portugal, and effectively linking existing ECAs across Europe with the Canadian Arctic region.

The amendments enter into force on 1 September 2027, with SOx limits of 0.10% applying from 1 September 2028. NOx requirements will apply to new ships constructed on or after 1 January 2027 when operating within the area.

With most European and North American waters now designated as ECAs, ship operators should ensure that fuel procurement, changeover procedures, and crew awareness remain aligned with evolving MARPOL requirements when trading in these regions.

A useful infographic and further guidance on ECAs can be found here.

 

Photo credit: Venti Views on Unsplash
Published: 7 July, 2026

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Bunker Fuel

FOBAS: Summary of marine fuel oil sulphur requirements

FOBAS publishes a bulletin to provide ship operators with an updated reminder of marine fuel oil sulphur regulations under various regulatory frameworks.

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Lloyd’s Register Fuel Oil Bunkering Analysis and Advisory Service (FOBAS) on Wednesday (24 June) published a bulletin to provide ship operators with an updated reminder of marine fuel oil sulphur regulations under various regulatory frameworks: 

MARPOL Annex VI

Ships operating inside or outside Emission Control Areas (ECA) for Sulphur Oxides (SOx) i.e., ECA-SOx, are

required to comply with specific sulphur limits in respect of the fuel oils as used unless the particular

combustion systems (engine, boiler, other) in use have in operation an approved exhaust gas cleaning system as per MARPOL Annex VI regulation 4. These fuel oil limits are as follows;

  • Inside ECA-SOx: Max sulphur content of 0.10% m/m
  • Outside ECA-SOx: Max sulphur content of 0.50% m/m

MARPOL Annex VI regulation 14.3 currently gives the following as ECA-SOx together with the respective geographic limits:

  • Baltic Sea;
  • North Sea;
  • North American (which includes an area around the Hawaiian Islands);
  • US Caribbean Sea;
  • Mediterranean Sea;
  • Canadian Arctic; and
  • Norwegian Sea

Additionally, MEPC 84 adopted the North-East Atlantic as an ECA-SOx which will come into effect from 1 September 2028.

European initiatives

For EU, UK, and Turkish ports situated outside ECA-SOx, ships must switchover to a fuel with a maximum sulphur content of 0.10% m/m when at berth. Similarly, Norway and Iceland have also 0.10% m/m requirements for ships at berth and operating in Fjords (territorial / internal waters).

Other initiatives

Due to increasing concerns around the environmental impact from shipping on local air quality, there are a number of national and local regulations which require the use of low sulphur fuel oils, typically maximum sulphur content 0.10% m/m, or other measures by all or certain ships within defined areas. Examples of these are China, California (CARB), South Korea and Sydney. Furthermore, there can be other related restrictions, for example, on the discharges to sea from exhaust gas cleaning systems.

However, whereas with the MARPOL Annex VI ECA-SOx, there is a single point of reference as to which areas are covered, there is no such central registry for these regional, national or local initiatives taken outside MARPOL Annex VI. Consequently, in all the cases, it is important for ships to check with the relevant authorities beforehand in order to confirm the current status as regards SOx and related emission requirements in order to avoid any penalties – which can be substantial.

 

Photo credit: Louis Reed from Unsplash
Published: 25 June, 2026

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