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IBIA: IMO sub-committee fails to improve clarity of 0.50% sulphur limit enforcement

Debunkering should only be required when it has been established, beyond reasonable doubt, that a ship is carrying fuel oil that exceeds the 0.50% sulphur limit.
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The International Bunker Industry Association on Monday (19 July) issued a statement encouraging clarity of the 0.50% sulphur limit enforcement:.

The seventh session of the IMO’s Sub-Committee on Implementation of IMO Instruments (III 7) has brought no further clarity regarding on what basis authorities can determine that a ship’s fuel is non-compliant with MARPOL Annex VI sulphur limits.

IBIA had put in a paper, III 7/5/8, co-sponsored by Jamaica to III 7, seeking primarily to protect ships from unreasonable debunkering demands by relevant authorities, as there is presently room for doubt about on which grounds that may happen. (Click here to see the document).

Our submission urged member states to implement the amended sulphur verification procedures in appendix VI of MARPOL Annex VI, adopted by MEPC 75, to ensure consistent implementation of the 0.50% sulphur limit which has been in force since the start of 2020.

Appendix VI of the adopted amendment, “Verification procedures for a MARPOL Annex VI fuel oil sample” states that “The following relevant verification procedure shall be used to determine whether the fuel oil delivered to, in use or carried for use on board a ship has met the applicable sulphur limit of regulation 14 of this Annex.”

Appendix VI goes on to provide two distinctly different procedures: Part 1 for the MARPOL delivered sample which it says “shall be used to verify the sulphur content of the fuel oil delivered to a ship” and Part 2 for in-use and onboard samples which it says “shall be used to verify the sulphur content of the fuel oil as represented by that sample of fuel oil at the point of sampling.”

Part 2 of the verification procedure for in-use and onboard sample takes into account the inherent uncertainty of the sulphur test method by recognising samples as having met the regulatory requirement as long as the test result does not exceed the limit +0.59R – also known as the 95% confidence interval.

If those procedures were always followed, we would have clarity. However, there have been cases where ships have been required to debunker after reporting to authorities that they have received a test result from their own fuel oil testing programme against ISO 8217 parameters, on the ship’s own sample, indicating a sulphur content marginally above 0.50%.

There have also been reports of authorities obtaining and testing in-use samples from ships and treating it as a non-compliant on the basis of a single test result above 0.50% sulphur, but within the 95% confidence interval, for example 0.51% or 0.52% sulphur.

For these reasons, our submission asked for assurance that port State control (PSC) authorities, if seeking to verify compliance with the 0.50% sulphur limit and the associated carriage ban, would follow the sulphur verification procedure in appendix VI adopted by MEPC 75. 

Debunkering should only be required when it has been established, beyond reasonable doubt, that a ship is carrying fuel oil that exceeds the 0.50% sulphur limit. This is why we also sought recognition that the 95% confidence principle should apply to fuel oil used and carried for use if, for any reason, an authority seeks to assess the ship’s compliance on the basis of a MARPOL delivered sample only, without obtaining an in-use or onboard sample to verify the ship’s compliance. This would provide the ship with the benefit of doubt against what remains a fairly arbitrary outcome, because a fuel which does in fact meet the limit may test marginally above that limit (as per 0.59R or 95% confidence limits).

However, we stressed that if the MARPOL delivered sample is above 0.50% sulphur, the fuel oil supplier would still be considered as not having met the requirement for the fuel as delivered, and could face enforcement action. The supplier does not get this “benefit of doubt” and therefore needs to use the limit minus 0.59R as the blend target to be 95% certain that a single laboratory won’t return an analysis result that is fractionally above the limit. For a 0.50% sulphur limit, this means the suppliers blend target must be 0.47% sulphur or less.

Parties to MARPOL Annex VI have an obligation to “take action as appropriate against fuel oil suppliers that have been found to deliver fuel oil that does not comply with that stated on the bunker delivery note”.

When the document was discussed at III 7, some delegations were of the opinion that asking for the outcome of testing a MARPOL delivered sample – in the case of the ship only – to be viewed in the same way as if an in-use or onboard sample had been tested, would interfere with the decisions made by MEPC on this issue and would lead to the use of fuels with 0.53% sulphur.

When IBIA pressed for clarity on the legal question as to what basis PSC might take enforcement action against the ship, the view was that the issues we raised in document III 7/5/8 concerning discrepancies in the enforcement of the 0.50% sulphur limit were not under the purview of the III Sub-Committee and should be referred to an appropriate IMO body.

We are disappointed that we could not get the legal certainty we were seeking, in particular regarding the basis for demanding debunkering of fuel that may, if tested again at a different laboratory, prove to be compliant given the inherent uncertainty of the test method.

Ideally, there should be legal certainty that PSC must verify the ship’s non-compliance on the basis of obtaining and testing and in-use or onboard sample. However, we do not have that certainty. While this uncertainty is not helpful for the industry, there are some positives. When speaking to member states about the issue prior to III 7, we found that many were supportive of the principle that debunkering should only be required when it has been established, beyond reasonable doubt, that a ship is carrying fuel oil that exceeds the 0.50% sulphur limit. Moreover, while some ships have faced debunkering demands that seem poorly justified, it does not appear to be widespread. Nevertheless, even a few such cases have caused considerable anxiety in the market.

On a final note, best practice for the bunker producer/supplier is to ensure that the product meets the specification limit with 95% confidence by using the limit minus 0.59R as the blend target, rather than the limit value. This should minimise the number of cases where a ship’s own initial test result indicates potential non-compliance with the mandatory sulphur limits, and the subsequent concerns about what kind of enforcement actions the ship may face.

 

Photo credit and source: International Bunker Industry Association
Published: 21 July, 2021

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Yang Ming orders six LNG dual-fuel, ammonia-ready containerships from Hanwha Ocean

Each of the six new vessels will have a capacity of up to 13,650 TEU and feature LNG dual-fuel propulsion and Ammonia Fuel Ready specifications.
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Yang Ming orders six LNG dual-fuel, ammonia-ready containerships from Hanwha Ocean

Taiwanese shipping firm Yang Ming Marine Transport Corporation (Yang Ming) and South Korean shipbuilder Hanwha Ocean on Wednesday (2 September) signed a shipbuilding contract for six 13,000 TEU class LNG dual-fuel container vessels. 

The contract was signed by Dr. Chuck Tsai, Chairman of Yang Ming, and Mr. Charles Kim, CEO of Hanwha Ocean. The vessels are scheduled for delivery between 2028 and 2029. 

They will complement Yang Ming’s existing fleet of 10,000+ TEU vessels and serve as key vessels on East-West services, with deployment flexibility across trade lanes connecting Asia with the East and West Coasts of North America, South America, and the Mediterranean. 

Each of the six new vessels will have a capacity of up to 13,650 TEU and feature LNG dual-fuel propulsion and Ammonia Fuel Ready specifications.

“As Yang Ming transitions toward net-zero emissions, LNG provides a relatively mature and economically viable alternative fuel solution, capable of reducing greenhouse gas emissions by approximately 20%,” the company said. 

“At the same time, ammonia can serve as a carbon-free fuel by utilising converted LNG storage facilities, while offering relatively lower conversion costs and comparatively well-developed supply chains and infrastructure. The Ammonia Fuel Ready design will therefore provide Yang Ming with greater flexibility in responding to increasingly stringent international regulations on greenhouse gas emissions.”

In addition, the vessels will be equipped with Type B LNG fuel tanks with a design pressure of 1.0 bar to enhance the safety and efficiency of LNG operations, together with a range of energy-saving technologies, including Wind Shields, Rudder Bulbs, Pre-Swirl Stators, and Shore Power Systems. Smart ship technologies and cybersecurity protection features will also be incorporated to enhance operational efficiency, safety, and reliability while effectively reducing fuel consumption and greenhouse gas emissions.

Deliveries under Yang Ming’s next-generation fleet optimization plan commenced earlier this year. By 2030, a total of 24 new vessels are expected to enter service. 

This includes 18 LNG dual-fuel vessels—comprising five 15,500 TEU, seven 16,000 TEU, and the six 13,000 TEU vessels under this contract—alongside six 8,000 TEU methanol dual-fuel-ready ships. 

 

Photo credit: Yang Ming Marine Transport
Published: 4 September, 2026

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Alternative Fuels

LR, China’s MARIC unveil tanker concept ready for three future bunker fuels

Both secured AiP for a new 114,000 DWT product and crude oil tanker designed to accommodate future conversion to LNG, methanol or ammonia.
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September 4, 2026

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LR, China’s MARIC unveil tanker concept ready for three future bunker fuels

Lloyd’s Register (LR) and the Marine Design and Research Institute of China (MARIC) on Thursday (3 September) have secured Approval in Principle (AiP) for a new 114,000 DWT product and crude oil tanker designed to accommodate future conversion to LNG, methanol or ammonia.

Announced at SMM 2026, the concept addresses one of the biggest investment challenges facing shipping today: the need to develop vessels and capabilities that can support a range of alternative fuel options and pathways as technologies, infrastructure and regulations evolve.

While LNG is already a mature fuel pathway, methanol and ammonia remain at an earlier stage of development, with questions around global fuel availability, infrastructure development, economics and long-term adoption.

The 114,000 DWT tanker concept has been designed as a product and crude oil carrier that can accommodate future conversion to LNG, methanol or ammonia as technologies, regulations and fuel supply chains mature. By incorporating conversion readiness at the design stage, the concept aims to reduce future retrofit complexity and provide owners with greater confidence when planning long-term fleet investments.

The design concept was reviewed against LR’s July 2026 class rules and regulations, including requirements relating to ships using gases and other low-flashpoint fuels, alongside relevant IACS Common Structural Rules for oil tankers. Final classification and statutory approval remain subject to full compliance with all applicable rules and regulations.

Theo Kourmpelis, Global Business Director for Tankers, Lloyd’s Register, said: “Shipowners are being asked to make major investment decisions today despite continued uncertainty around which fuels will dominate in the decades ahead. Alternative fuel solutions each offer potential pathways to compliance, but fuel infrastructure, regulation and economics continue to evolve at different speeds around the world.

“Designs that preserve flexibility will be critical in helping owners manage risk while preparing for multiple future scenarios.”

Si Nan, Marine & Offshore Marketing Department Vice Director, MARIC, said: “As the industry explores different decarbonisation pathways, shipowners need vessel designs that can adapt alongside technological and regulatory developments. This concept was developed specifically to provide greater fuel flexibility and long-term resilience, allowing owners to respond to changing market requirements without being locked into a single fuel strategy.

“Receiving Approval in Principle from Lloyd’s Register is an important milestone that validates the design concept and supports its future development.”

 

Photo credit: Lloyd’s Register
Published: 4 September, 2026

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Alternative Fuels

DNV: Alternative-fuelled vessel orders hit highest monthly level since October 2024

LNG-fuelled vessels accounted for the vast majority of August activity while the strong summer performance marked a significant acceleration in ordering activity after a relatively slow start to the year.
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September 4, 2026

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DNV: Alternative-fuelled vessel orders hit highest monthly level since October 2024

Latest data from classification society DNV’s Alternative Fuels Insight (AFI) platform alternative-fuelled vessel ordering was strong in August, with 52 new vessels added to the platform.

This is the highest monthly total since October 2024 and follows another active month in July, when 47 vessels were added to the database.

LNG-fuelled vessels accounted for the vast majority of August activity, with 46 orders recorded. The container segment led the way with 30 orders, while the car carrier segment contributed a further 12 LNG-fuelled vessels. In addition, four ethanol-fuelled bulk carriers and two hydrogen-powered bulk carriers were added during the month, as well as one LNG bunker vessel.

The strong summer performance marked a significant acceleration in ordering activity after a relatively slow start to the year. In total, 242 alternative-fuelled vessel orders have been placed in the first eight months of 2026, representing a 27% increase compared with the same period in 2025.

LNG remains the dominant fuel choice, accounting for 63% of all alternative-fuelled vessel orders registered so far this year. Container vessels represent the largest share of these LNG orders (59%), followed by car carriers (30%).

Jason Stefanatos, Global Decarbonization Director at DNV Maritime, said: “The past two months have been particularly strong for alternative-fuelled vessel ordering, with August recording the highest monthly total we’ve seen since October 2024. This has helped lift year-to-date orders to a level well above the same period last year.

“LNG remains the leading fuel choice, driven largely by activity in the container and car carrier segments. These sectors have been among the earliest adopters of alternative fuels, supported by predictable liner operations and increasing demand from cargo owners to reduce emissions across supply chains. 

“For many owners, LNG offers a combination of emissions reductions, fuel availability and future flexibility while the longer-term fuel landscape continues to evolve. 

“At the same time, the latest figures include orders for ethanol- and hydrogen-fuelled vessels, highlighting that owners continue to explore a range of decarbonization pathways. Different segments are making different fuel choices, but the overall level of activity demonstrates continued investment in lower-emission shipping.”

Screenshot 2026 09 04 at 12.29.26 PM Screenshot 2026 09 04 at 12.29.36 PM

 

Photo credit: DNV
Published: 4 September, 2026

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