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IMO 2020

Gard: Beware local restrictions before discharging washwater from scrubbers

Although gas scrubbers are considered acceptable to meet IMO2020’s SOx emission rules, it is not globally accepted in all states.
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Norweigian maritime insurance company Gard on Wednesday (29 January) published an article warning shippers to heed local restrictions before discharging washwater from exhaust gas scrubbing:

The IMO considers exhaust gas scrubbers to be an acceptable means of reducing vessels’ sulphur emissions and ensuring compliance with MARPOL Annex VI.  A separate guideline, Resolution MEPC.259(68), specifies the requirements for the verification, testing, survey and certification of scrubber systems and sets out the criteria for discharging scrubber washwater into the sea.

However, some coastal states and ports have implemented local regulations with more stringent requirements that restrict or completely prohibit the discharge of washwater from open loop scrubbers or prohibit the use of scrubbers. We are currently aware of the following regions/states/ports with local regulations that have an effect on the discharge of exhaust gas scrubber washwater, although the list should not be considered as complete.

AFRICA Egypt Discharge of washwater from open loop scrubbers is prohibited in the Suez Canal. The attached clarification to circular 08/2019 also states that Egypt is in the process of ratifying MARPOL Annex VI. It should be mentioned that although use of fuel with a sulphur content greater than 0.5% sulphur may be allowed without the use of scrubbers, vessels should always refer to their flag state regulations which may not allow this.
AMERICAS

 

 Bermuda

 

 Use of open loop scrubbers is not permitted. Environmental Policy for Ships states: “Washwater and residue from the EGCS shall be not disposed of in Bermuda or discharged into Bermuda’s waters but shall be stored on board the ship until outside of Bermuda’s waters”. If a vessel has to use closed loop scrubber in territorial waters of Bermuda, permission needs to be sought from the authorities.
Panama

 

 Notice to Shipping No. 01 of 2019 states that discharging EGCS washwater into bodies of water under the responsibility of Panama Canal is not permitted. Use of closed loop systems is permitted.
USA

 

 Hawaii: Conditional section 401 WQC (Water Quality Certification) as mentioned in section 6.7 of 2013 VGP allows for discharge of washwater subject to certain requirements being fulfilled. These requirements can be found in the same section.
Connecticut: Connecticut has laid down specific conditions as part of the 2013 Vessel General Permit (VGP) requirements. In accordance with section 6.5.9[UK1]  of the 2013 VGP, discharge of exhaust gas scrubber washwater into Connecticut waters from any vessel covered under the VGP is prohibited. Please see CGS section 22a-427, and Connecticut Water Quality Standards (CT WQS).
California: The CARB OGV (California Air Resource Board for Ocean Going Vessels) regulations do not permit the use of abatement technologies such as scrubbers, hence their use as well as any discharge of washwater is prohibited. Vessel discharge regulations for Port of Long Beach also state that it is prohibited to discharge washwater from scrubbers in port waters. However, pursuant to CARB’s Marine Notice 2017-1 discharge is permitted if the vessel has an experimental or temporary research permit.
US Coast Guard has informed that it will use the IMO’s Global Integrated Shipping Information System (GISIS) database to confirm that foreign flagged ships are using approved scrubbers. Notification to IMO’s GISIS shall be submitted by the Flag State of the vessel. The USCG has also published a guidance document on enforcement of the sulphur cap regulations.
ASIA

 

 Bahrain According to marine notice PMA/03/2019, discharge of washwater from open loop scrubbers is prohibited within port limits including anchorage area(s). The circular also states that vessels should obtain a permit from the Marine Safety & Environment Protection Directorate before discharging washwater anywhere in Bahrain waters. 
China China MSA in its “Implementation Scheme of 2020 Global Marine Fuel Oil Sulphur Cap” has mentioned that washwater discharge from open loop scrubbers is prohibited in domestic emission control areas, which includes coastal control areas and inland river control areas. Members can refer to a circular by Huatai to know the coordinates of these areas. In another circular, Huatai set out the inspection procedure which may be adopted by the authorities on ships installed with scrubbers.
Hong Kong

 

 If a ship intends to use scrubbers in Hong Kong waters, to meet the sulphur cap requirements, application must be made to the Hong Kong authorities requesting for an exemption from using compliant fuel. The exemption application must be made at least 14 days prior to a ship’s first visit to Hong Kong after 1 January 2019. For details of the exemption application process, please refer to Sections 7 to 11 of the new ‘Air Pollution Control (Fuel for Vessels) Regulation’ 
India

 

 In DG Engineering Circular 02 of 2019, India appear to indicate that scrubber washwater discharges are allowed if the criteria set out in MEPC.259(68) are met. However, this is qualified with a requirement that local regulations should also be followed. As of now, it is not clear if local restrictions will be imposed in some areas
Malaysia

 

 In circular MSN 07/2019 Marine Department of Malaysia has indicated that discharge from open loop scrubbers is prohibited within the country’s waters (12 nm from nearest land). They have also issued MSN 08/2019 to clarify that the regulation does not apply to ships transiting the Malacca and Singapore straits.
Pakistan In their circular no. 001/2020, the Ministry of Maritime Affairs has prohibited the discharge of washwater from open loop scrubbers in Pakistani port waters. The circular advises vessels to either change over to closed loop mode of operation or switch to compliant fuel well in advance of the vessel’s arrival in port waters.
Singapore

 

 According to the Maritime and Port Authority of Singapore (MPA), discharge is prohibited in Singapore port waters from 1 January 2020. The prohibition does not apply to ships transiting the Traffic Separation Scheme (TSS) without calling into the Port of Singapore. MPA has published useful guidance on IMO’s 2020 Sulphur limits which can be accessed here. The document advises ships fitted with open loop scrubbers to ‘carry out the switch to either closed-loop mode or to compliant fuel well in advance of the vessel’s arrival at the port waters’. Residues from scrubbers have been classified as toxic industrial waste under Singapore’s Environmental Public Health (Toxic Industrial Waste) Regulations. It can only be collected by licensed Toxic Industrial Waste Collectors.
UAE Abu Dhabi: In 2013 Abu Dhabi authorities issued ‘Vessel Discharge and Maintenance Guidelines For Owners, Masters And Agents’. It states that scrubber washwater can be discharged in port waters if free form pollutants whilst scrubber sludge should be discharged from the vessel to an Abu Dhabi Ports Company (ADPC) licensed waste disposal contractor.
Fujairah: As per notice to mariners no. 252, Harbour Master of Fujairah has announced that use of open loop scrubbers will be banned in port waters. The circular can be found here.
EUROPE

 

 Belgium

 

 The European Commission’s 2016 note on discharge of scrubber washwater, bans the discharge in ports and inland waters. Relevant legislation is ‘Wet van 26 maart 1971 op de bescherming van de oppervlaktewateren tegen verontreiniging (Vlaams Gewest)’.
Estonia According to circular no.4 by Estonian Maritime Administration, use of open loop scrubbers is permitted if the owner can demonstrate that the washwater meets IMO’s requirements. However, port authorization is required if scrubber washwater is discharged in the port area.
France Our correspondent informs us that there are restrictions in place on use of open loop scrubbers in Port Jérôme-sur-Seine, Seine, Le Havre , Montoir, Nantes Saint-Nazaire and Bordeaux.
Germany

 

 Discharge is not allowed in inland waterways and the Rhine, pursuant to Articles 1 and 3 of the CDNI Convention (Convention on the Collection, Deposit and Reception of Waste Produced during Navigation on the Rhine and Inland Waterways).
Gibraltar We have been informed by our correspondent that open loop scrubbers are temporarily not permitted as a precautionary measure until the Gibraltar Government arrives at a definitive policy decision on this issue.
Ireland

 

 Dublin: The Irish authorities’ Notice No. 37 of 2018 ‘Prohibition on the Discharge of Exhaust Gas Scrubber Wash Water’ stipulates that discharge of washwater is prohibited in waters under Dublin port jurisdiction. Dublin port jurisdiction includes waters from the Matt Talbot Memorial Bridge eastwards to a line from the Baily Lighthouse through the North and South Burford buoys and through Sorrento Point.
Waterford: As per Port of Waterford’s marine notice ‘Prohibition on the Discharge of Exhaust Gas Scrubber Wash Water’, discharge of scrubber washwater is prohibited in port limits from the start of January 2019.
Cork: Port notice No. 15 of 2018 states that given the potential for impact on sensitive ecosystems, and the abundance of Natura 2000 sites within the jurisdiction of the port company, discharge of scrubber washwater is prohibited in port waters.
Latvia

 

 General position, as mentioned in the European Commission’s 2016 note, is that discharge is not allowed in territorial and port waters. Discussions are currently ongoing within the European Commission, on improving the regulations and to provide more clarity.
Lithuania The authorities are currently studying the impact of scrubber washwater  

on the marine environment and will provide its conclusions upon completion of the study. Meanwhile, the current position seems to be that discharge is not allowed in port waters, according to port rules and conditions of use approved by the Ministry of Transport. Reference is made to the European Commission’s 2016 note on discharge of scrubber washwater.
Norway

 

 Under the amendments of 1 March 2019 to Regulation No.488 on the environmental safety of ships and mobile offshore units, use of open loop scrubbers is prohibited in the Norwegian fjords. Also, for ships using closed or hybrid type scrubbers, a device for reducing visible emissions to air is required.
Spain Our correspondent informs us that Harbour Master of Port of Algeciras has confirmed there is a prohibition on discharge of washwater from open loop scrubbers in port waters.  
Sweden Port of Brofjorden does not allow the use of open loop scrubbers. Our correspondent informs us that port regulations will be updated to reflect this.
OCEANIA

 

 Australia

 

 Ships can use an EGCS in Australian waters to comply with the sulphur limit according to marine notice 05/2019. Vessels will have to notify AMSA before first arrival at an Australian port after 1 January 2020, and provide information related to the scrubber. AMSA stresses that data related to the testing of washwater in accordance with Appendix 3 of IMO resolution MEPC.259(68) should be made available to AMSA. As otherwise there may be restrictions on the discharge of washwater from scrubbers. 

 

Summary and recommendations

Although exhaust gas scrubbers are an accepted abatement technology to meet IMO’s SOx emission rules for 2020, their use is not accepted globally in all states. If a members’ vessel is trading in area(s) where the discharge of scrubber washwater is not permitted, vessel operators have two options to choose from to ensure compliance with the sulphur limits:

  • switch over to closed loop mode of scrubber operation, in which case it will be necessary to convert currently installed open loop scrubber systems to closed loop or hybrid systems, if not already done; or
  • changeover to compliant fuel.

Any changeover should be carried out well in advance of the vessel entering the areas with prohibition or restrictions in place. Early changeover will help in identifying operational issues, if any, after the changeover, and will allow for sufficient time to rectify such before the vessel enters the area.Owners’ and managers’ safety management procedures should contain guidelines on how to carry out the changeover safely and outline the recordkeeping requirements. It is also recommended that a vessel’s passage plan incorporates information on when to carry out the changeover, taking into account things such as duration of passage, time needed for changeover, density of traffic, proximity to hazards etc.

We advise Members and clients to monitor the situation closely and ensure that crew members onboard vessels fitted with open loop scrubbers are made aware of any relevant local discharge requirements in force. In general, vessels with any kind of scrubber installed should check with local authorities whether there are any applicable regulations in relation to the use of scrubbers, such as washwater discharge restrictions, and requirements to seek permission from authorities to use scrubbers.


Source: Gard
Photo credit: Manifold Times
Published:  7 February, 2020

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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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June 3, 2026

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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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December 8, 2025

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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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October 31, 2025

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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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