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IMO 2020

INSIGHT 2020: Refining the Issue

Chris Hudson of Freight Investor Services outlines the looming regulatory changes, how they will be implemented and the solutions the shipping sector could adopt.

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In the first of two articles, Chris Hudson of Freight Investor Services (FIS) outlines the looming regulatory changes, how they will be implemented and the solutions the shipping sector could adopt.

2020 is the 1066 of the shipping world; a date that is etched into our minds accompanied with a vague understanding of its significance. With Armageddon day around a year and a half away, the regulations that will have a dramatic effect on the shipping industry are clear, but how to deal with them and their lasting effects are about as certain as who will win the World Cup.

Bringing about change in the shipping industry is usually glacially-paced at best. That said, there are significant financial challenges, as well as the potential of operational risk, which could make inaction a costly choice.

The first thing to note is that the IMO has been very clear that there is going to be no delay in the introduction of the regulations. Come January 1st 2020 any fuel oil with more than 0.5% sulphur for any normal vessel is banned. There was a point in the legislative process where it could have been delayed, but that has come and gone. If you do not comply, expect a fine (though whether this is enough to deter non-compliance is questionable) or detention while the transgression is remedied.

With 65 out of the 153 coastal states (including all those in the EU) currently signed up, and with 30 of these nations already operating low sulphur restrictions, the likelihood of compliance, at least in the IMO’s opinion, looks good. It’s true that there are non-signatories but the economic and social advantages from cleaner air and seas, as well as higher premiums for refineries from selling 0.5% fuel oil should add weight to compliance.

But what about if there is not enough of the compliant fuel? Well, there will be a non-availability reporting system similar to that used by the U.S. Coast Guard, known as FONAR, which will allow ships to report lack of compliant fuel which can be used as evidence if any cases are brought against them for using High Sulphur Fuel Oil. Phew. There will, of course, also be an exemption for those vessels fitted with scrubbers to make their ships compliant. Double phew.

Further to the main legislation banning the combustion of fuel oil over 0.5% sulphur, there is also a ban on the carriage of the High Sulphur Fuel Oil except as cargo or on a ship fitted with a scrubber. This is pending approval in October of this year but, like a Venezuelan election, we already know the outcome of the vote. This ban will come in slightly later and will begin in March 2020, adding to the likelihood of regulatory compliance.

In trying to deal with the new regulations, there are several options open to shipowners/operators: wait and hope for 0.5% fuel specification, use MGO until a compliant fuel oil is more readily available, or install a scrubber.

Choosing the first option would require the least effort on the part of the shipowner/operator, as well as the smallest financial outlay, but relies heavily on the refining industry to get things right.

The flip side of this solution is that it opens up the possibility of operational risk. The prospect of several different 0.5% grades, or not enough compliant fuel being available, could make bunkering a challenge, though from conversations with refiners, these fears appear overplayed. Although, let’s be honest, you do not want to be the only person with egg on their face in two years’ time.

Using MGO will be akin to buying an Audi. Yes, you will have guaranteed quality and reliability, but rather than just settling for an Audi car with a Skoda badge, you will have to pay for the privilege. It is a fair assessment of the future to see MGO as a legitimate stop gap until the 0.5% conundrum is solved.

There is a projected premium of around $350 over High Sulphur Fuel Oil, but one thing to remember is that this would put bunker prices at around 2011-2014 levels, when prices of IFO 380 were over the $600 mark. If you survived that, then there’s a pretty good chance you will survive this, providing vessels are profitably employed. Once the refineries have got past their meltdown, rushed to get LSFO ready and distributed it globally, you can switch over from contingency MGO. Easy.

Scrubbers have not proved a hugely popular option up to this point. It was reported in February that only 450 scrubbers had been fitted and Mercuria, which has been offering financing help for scrubber installations, had received no orders. There are several considerations to take into account when considering scrubbers: whether there will be the necessary High Sulphur Fuel Oil will be available to make them a financially viable investment and whether the outlay for retrofitting or premium in ordering pre-fitted newbuilds adds up, as well as how long before the technology becomes obsolete or even illegal.

Scrubbers are a great choice for those who trade predictable routes where they can source contracted supplies of lower cost High Sulphur Fuel Oil. For Liners and Ferries, for example, this is a no brainer, and it will come as no surprise that data suggests that these shipping sectors have had the greatest uptake of scrubber orders so far. Where shipping operations are unpredictable, owners have to ask whether they want to risk the scenario where they cannot source cheaper fuel and end up burning 0.5% fuel, totally negating any advantage from the scrubbers.

There could be a significant financial advantage after a short payback period for the scrubber installation. Retrofit costs are currently in the region of $1.5–3 million, and for newbuilds in the region of $1–2 million. Using the predicted spread between the High Sulphur and the Low Sulphur fuel oils owners could achieve payback in as little as nine months for a non-eco VLCC and 15 months for a non-eco MR (basis $250 fuel spread). After this period vessel operations (fuel) will be cheaper, and the asset more desirable to charterers, providing an advantage over non-scrubber-equipped vessels.

The last thing to consider is for how long scrubber technology will be effective. Increasing political and public pressure means there will be no let up in ‘green’ regulation and if new regulation reduces the sulphur content further and as the drive towards low/no carbon fuels picks up pace after 2030, additional financial outlay could be needed. Not all scrubbers are equal and open loop in particular are heading for obsolescence as pressure builds for regulations to counter increasing ocean acidification.

Like anything in life, it costs money to reduce risk, be it using scrubbers or MGO, the cleaning of fuel tanks or the contracting of specific fuels. A lot of the responsibility for a smooth transition in 2020 rests on the refining industry’s ability to solving the industry’s problems. The question is whether they can deliver with a minimum of problems or whether owners need to invest in some back up.

Chris Hudson is a Fuel Oil & Tanker FFA Broker at Freight Investor Services (FIS).

Founded in 2002, Freight Investor Services is a specialist in dry bulk and commodity derivatives, including freight, iron ore, fertilizer and bunker fuel. The company has offices in London, Dubai, Singapore and Shanghai.

For further details about fuel oil swaps or to discuss trading opportunities, please contact the fuel oil desk on +44 207 090 1134 or [email protected].

Published: 4 July, 2018
 

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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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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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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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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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