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IMO 2020

Shipowners: the 2020 scenarios we can plan for and those we can’t

BIMCO Bulletin speaks with BW Group and Load Line Marine representatives about IMO 2020 preparations.
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The following article entitled ‘Shipowners: the 2020 scenarios we can plan for and those we can’t’ first appeared in the September edition of the BIMCO Bulletin here; it has been shared with Manifold Times:

Shipowners can take many steps to prepare themselves, the crew and the fleet for 1 January 2020. But not all scenarios can be prepared for, or even controlled, and having to debunker tonnes of non-compliant fuel is something everyone fears. The Bulletin spoke to BW Group’s Kapil Berry and Load Line Marine’s George Souravlas about what they believe could disrupt even the best laid plans:

How can you prepare for authorities telling you that you are not compliant at the port of arrival?

Berry:
“Looking at it from a legal standpoint, the only document that has legal validity is a Bunker Delivery Note (BDN). In addition, fuel samples are taken during bunkering and sent for external testing. A challenge may arise if the test result shows the bunkered fuel is above the 0.50% sulphur limit. By the time this result is obtained, the vessel could be mid-sea, creating a very difficult situation.

It will now be up to the Port State Control of the country of arrival as to which approach is taken for such cases. A great deal will depend on how the case is presented to it, so proper records must be maintained onboard the ships to convince the authorities that sufficient due diligence had been carried out while procuring the fuel.

During the transition into the 1 January 2020 sulphur regulation, we are hoping that Port State Controls will be pragmatic when deciding whether a non-compliance case has taken place because of factors outside the control of the ship or the company.”

Souravlas:
“The transition has to take place before 1 January 2020, during which time you must prepare the tanks of each ship and consume or remove all high-sulphur products. This is to make sure that the new low-sulphur fuel is not in any way mixed with parts of the old fuel.

After this, we suggest that an idependent surveyor is engaged to confirm the tanks are clean. If you are found to be consuming products with a sulphur content higher than 0.50%, there will be a very heavy fine. Then, you will have to prove that this was not your fault. To help you prove this, you need to have a confirmation that the tanks were clean and free of high-sulphur fuel before the new fuel came on board. If retesting at the next port shows the bunkers are non-compliant, you will be able to demonstate that this is because of the bunkers that were delivered to you. The retesting compliance level is at 0.53% sulphur content.

This is how we, as owners, can prepare ourselves. Certifying the cleanliness of our tanks by independent and reputable surveyors before receiving the new bunkers, will be the most important way of getting prepared.”

Can you prepare for – or avoid – having to debunker non-compliant fuel, even if you have done what you could to be compliant?

Berry:
“This will depend entirely on the merits of the case presented to the Port State Control, and how strictly or pragmatically the Port State Control enforces this regulation. If the Port State Control insists on debunkering such non-compliant fuel, one has to comply.

If we are talking about a Very Large Crude Carrier (VLCC), which has perhaps taken 3,000 tonnes of fuel on board, debunkering such a large quantity of fuel using shipboard pumps will be a challenge and may take several days. Arranging for barges for this job – especially in remote locations – will not be easy. Debunkering will bring many challenges that will be difficult to plan for.”

Souravlas:
“No. After 1 March, when the carriage ban comes into effect, non-compliant fuel must not be consumed under any circumstances and must be taken off the ship.

Debunkering is costly and, in some parts of the world, such as Singapore, is only allowed if your vessel has been bunkered there. If a test establishes that the fuel you have bunkered is not compliant, it must not be consumed. It must be removed from the vessel as soon as you have the chance, and definitely before 1 March. Even with a FONAR, you will have to debunker the non-compliant fuel. Once the analysis results show that the bunkers received are not compliant, you should consume whatever compliant fuel you have on board to proceed to a safe port where you can get the right quality of bunkers. You will still have to debunker the non-compliant fuel and never consume it.”

What is your view of the fuel oil non-availability report (FONAR)?

Berry:
“Using a FONAR will be a very complex affair and, in my view, should be avoided if at all possible.

If FONAR has been filled out, the flag state may grant permission to carry non-compliant fuel oil to the next bunkering port. However, the problem with using the FONAR is that high-sulphur fuel will have to be taken in the tanks that were cleaned for carrying compliant fuel and will have to be cleaned again once the vessel bunkers compliant fuel at the next suitable port.

Furthermore, extra reserve fuel will likely be taken as stated in a company’s safe practices to account for bad weather or sudden deviations. So, when the vessel arrives at the next bunkering port, it is likely to have some quantity of non-compliant fuel on board that will also have to be debunkered. In this case, it is likely that the value of the debunkered fuel will be lost.”

Souravlas:
“Using the FONAR is a very bad idea. It should only be employed in a total and absolute emergency.

If you bunker high-sulphur fuel because you have no other option, you will have to place this fuel in a tank that was originally clean. That tank will then become dirty. You might have to take, for example, 200 Metric Tonnes (MT) of non-compliant fuel to cover a distance, plus the extra fuel you usually take to cover for unforeseen weather, and so on; we usually allow a further 25%. If you do not consume the full amount, you might find yourself with, for example, 50 MT of excess fuel upon arrival at the next port – fuel that cannot be consumed. You are stuck with that, and will then have to go through the very expensive exercise of debunkering and tank cleaning. I would advise always carrying extra compliant fuel on board to avoid using the FONAR.”

Published: 23 September, 2019
 

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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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6 months ago

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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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7 months ago

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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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