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North P&I Club: No Scrubs- countries & ports with restrictions on EGCS discharges

16 Apr 2021

The North P&I Club on Thursday (15 April) published an update on the stands taken by international ports on the use of scrubbers and the allowance of EGCS discharge. Based on the earlier published chart, the following are countries that have been added to the list: 

Exhaust gas cleaning systems (EGCS) – more commonly referred to as scrubbers – are an accepted equivalent measure in complying with the IMO 2020 global sulphur cap. The use of scrubbers has split the shipping industry. Ports around the world are looking at the impact of scrubber use in their waters.

A number of ports and regions have already stated that they will not allow the discharge of washwater from scrubbers. 

The table below summarises North’s understanding of the positions taken by ports that have or will prohibit the use of scrubbers, or have placed conditions on their use.

This information is to the best of our knowledge and is for guidance only. For up to date and definitive information, contact the local authorities or agents. 

Country Port Open loop EGCS discharge allowed? Comments
Belize All No The Clean Shipping Alliance advise:

 Discharge of Exhaust Gas Cleaning Wash Water prohibited in territorial waters and port areas (Marine Circular 01/2018 – BPA/MS/23-1/2018(98) dated 12/12/2018)

Cyprus All Yes – Conditional The Clean Shipping Alliance advise:

In accordance with  CPA Regulations of CA 373/2016 Part II – Cyprus Port Authority, ships requiring to use ECGS at Cyprus’ ports or anchorage area must submit a written request for assessment and approval by the CPA at least 48 hours prior to the arrival of the ship. The written request shall provide the following detailed information:

·   the location that EGCS will be used (port, anchor); and

·   the type of EGCS.

Finland Port of Porvoo No The Clean Shipping Alliance advise:

·   Open loop discharge not permitted in harbour area of port of Porvoo

·   Ministry of Transport and Communications informs: Under Finnish legislation, the discharge of wash waters from open-loop scrubbers is allowed in Finnish ports and territorial waters. However, some ports have restricted the discharge in the port area under their own competence.

France Ports of Cannes, Marseille, Nantes-St Nazaire, La



Rouen, Bordeaux and Le Havre


No Direction des Affaires Maritimes issued document on 4 March 2020: Projet de modification de la division 213 – Prevention de la pollution – Interdiction de rejet des epurateurs de fumees en systeme ouvert dans Tenceinte des ports frangais et au mouillage

It states that in France, some large seaports such as Marseille, Nantes-St Nazaire and La Rochelle have already amended their port regulations to include a ban on

open-loop scrubber discharges, and the port of Rouen is preparing to do the same. Other ports such as Bordeaux and Le Havre have a prohibition in principle.

The Clean Shipping Alliance advise:

In Cannes, as per the Cannes Bay Sustainability Charter, the restriction applies to the cruise ships only.

Ghana All No The Clean Shipping Alliance advise:

Ghana Maritime Authority informed the CSA that the Administration does not allow the operation of open-loop scrubbers in Ghanaian waters

Kenya All No The Clean Shipping Alliance advise:

Kenya’s National Guidelines for Implementation of IMO 2020 December 2019 include:

7.1. The  discharge  of  wash-water  from  open-loop  scrubbers  is prohibited in  the Kenyan Ports limits. This is to maintain the standard of Kenya marine water quality.

7.2 While in the port of Mombasa, ships fitted with hybrid type of scrubbers shall switch to  the  closed-loop  mode  of  operation.  Ships  fitted  with  open-loop  scrubbers  shall switch over to compliant fuel oil.

Mauritius All No The Clean Shipping Alliance advise:

Merchant Shipping Notice 2 of 2019 includes:

3.9 …except in the case of innocent passage, ships proceeding to Mauritius or other islands forming part of  the territory of  Mauritius that use high sulphur fuel oil (HSFO) in combination with open-loop scrubber shall changeover from HSFO to compliant fuel oil whenever they enter the territorial waters of Mauritius i.e. within 12 nms from the shore.

 Environmental legislation presently in force in Mauritius prohibits the discharge of wash water from open-loop scrubber.

Pakistan Port of Karachi and Port Bin Qasim No The Government of Pakistan Ministry of Maritime Affairs (Ports and Shipping) Circular 001/2020 prohibits the discharge of wash-water from open loop scrubbers. If closed loop scrubbers are not in use then compliant fuel should be used and changed over before arriving in port waters.
Qatar Qatar Petroleum MIC (Mesaieed Industrial City) No The Clean Shipping Alliance advise:

Qatar Petroleum MIC [Mesaieed Industrial City] Port Information and Regulations Guide – January 2020 states:

“Also, as per Qatari Environmental Law, wash water originated from the open loop scrubbers, containing chemicals and /or metals are PROHIBITED to be discharged in Qatari waters.”

Saudi Arabia All Ports No Saudi Port Authorities have now banned exhaust wash water discharges from open loop EGCS systems in Saudi ports until an environmental standard is issued in this regard.
Turkey All No Vitsan Mümessillik ve Müşavirlik A.Ş advise that the Ministry of Environment and Urbanization of Turkey announced on 6 April 2021 that washwater discharge of open-loop scrubbers is prohibited in Turkish waters. Vessels operating with open-loop scrubber must switch sulphur-compliant fuels when entering / sailing in Turkish waters.  Turkish authorities may impose a pollution fine on vessels that do not comply with the regulation.

Vitsan circular regarding the scrubber usage in Turkey can be read here.

The Turkish Chamber of Shipping Circular on the subject can be read here.

United Kingdom – Scotland Forth and Tay ports No Forth Ports Circular No 45 of 2019 states: “Forth Ports and Port of Dundee Byelaw 59 specifically prohibits the discharge of materials into the Forth and Tay. This applies to discharge water from an “Open Loop” scrubber. Therefore, as a precaution the use of “Open Loop” scrubbers on the Forth and Tay is prohibited until further notice.”

See:  https://www.forthports.co.uk/wp-content/uploads/2019/12/Notice-to-Mariners-No-45-of-2019-Use-of-Scubbers.pdf

United States Port of Seattle No The Clean Shipping Alliance advise:

Port of Seattle Terminals Tariff No. 5, Item 4001 states that passenger cruise ships will not discharge graywater, blackwater, or exhaust gas cleaning system wash water, whether treated or not while at berth in Port Terminals.

United Arab Emirates Dubai No The Clean Shipping Alliance advise:

Guidelines for Vessels Calling to Dubai Territorial Waters states that the use of EGCS is prohibited within Dubai territorial waters.

A full copy of the chart can be accessed

Related: North P&I Club: No Scrubs: More ports declare ban on EGCS discharges *Update*
Related: North P&I Club: No Scrubs: More ports declare ban on EGCS discharges *Update*

Photo credit: Manifold Times (Scrubber)
Published: 16 April, 2021


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