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Skuld: Part of China ECAs has banned scrubber wash water discharge

New MSA Notice (2018) 555 issued on 29 December 2018 says ban took effect from 1 January 2019.

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Marine insurance provider Skuld on Thursday (17 January) issued a noticed regarding the Ban on discharging wash water from open loop scrubbers in part of China ECAs as of 1 January 2019. The notice begins below:

The new MSA Notice (2018) 555 issued on 29 December 2018 bans discharging washing water from open loop scrubbers in part of China ECAs as of 1 January 2019.

The crucial provision of MSA's Notice is set out in Article 7 which bans the discharge of wash water or wash water residue from open-loop Sulphur Oxide Exhaust Gas Cleaning Systems. A free translation was kindly provided by Hai Tong & Partners, Shanghai:

Article 7
The discharge and treatment of water pollutants generated by exhaust gas after-treatment device used by a ship shall conform to requirements of relevant regulations. It is prohibited to discharge into Inland River ECAs, waters of ports in Coastal ECAs and Bohai sea waters the washing water generated from open exhaust gas cleaning system. Requirements for prohibiting the discharge into waters within other coastal ECAs the washing water generated from open exhaust gas cleaning system will be promulgated in due time for implementation. It is also prohibited to discharge into water or burn onboard the washing water residuals generated from exhaust gas cleaning system, the ship shall truthfully record the situation regarding the storage and disposal of washing water residuals generated from exhaust gas cleaning system.

In respect of the storage and disposal of the wash water there is an obligation on the Owners to hold all relevant compliance certificates, technical and monitoring manuals and the record book of the exhaust gas cleaning system.

Wash water residues from Exhaust Gas Cleaning Systems should be handled as an operational waste.

For any discharge of the wash water or residues proper documentary trail should be kept for a period of no less than 18 months as good evidence.

Available for further reading (link):
Huatai's circular dated 15 January 2019 and an English translation of MSA's Notice (2018) 555 is kindly shared by Hai Tong & Partners, Shanghai.

Photo credit and source: Skuld
Published: 21 January, 2019

 

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ECA

NorthStandard issues operational guidance for vessels entering ECAs

Jordan Hatch, Loss Prevention Executive, issued guidance for vessels operating in Emission Control Areas (ECAs).

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Jordan Hatch, Loss Prevention Executive of global marine insurer NorthStandard, on Thursday (2 July) issued guidance for vessels operating in Emission Control Areas (ECAs):

The IMO addresses air pollution through MARPOL Annex VI, regulating the emissions of sulphur oxides (SOx), nitrogen oxides (NOx), and particulate matter from ships.

NOx requirements set limits on emissions from marine diesel engines through certification and tiered standards, whilst SOx regulations limit the sulphur content of fuel used onboard ships.

On 1 January 2020, the global sulphur limit for marine fuel was reduced from 3.50% to 0.50% by mass (m/m). However, some areas, known as SOx Emission Control Areas (ECAs), enforce stricter limits of 0.10% sulphur content. There are also dedicated NOx ECAs which impose tighter NOx emission standards for marine engines, particularly on newer vessels.

To meet the stricter SOx limits, ships must ensure they are burning compliant 0.10% sulphur fuel before entering an ECA. If a vessel is changing over from a 0.50% sulphur fuel, this requires a ship-specific calculation based on system volume, sulphur content, and current consumption to determine changeover time. Fuel changeover details, including quantities, date, time, and position, must be logged. Switching back to higher sulphur fuel should only begin after exiting the ECA.

To meet NOx requirements, vessels must demonstrate that their marine engines are certified to the applicable emission tier, and that they continue to operate within those limits through proper maintenance of combustion-related components.

Local Requirements

Some countries apply stricter local requirements in addition to MARPOL Annex VI. For example, Türkiye and Iceland have introduced a 0.10% sulphur limit in their territorial waters, while China has established its own dedicated ECAs.  

Members should check all applicable local requirements before entry and ensure that compliant fuel is available onboard, with sufficient time allowed for fuel changeover.

Scrubber Use

MARPOL allows for equivalent measures in the SOx regulations which means vessels can use exhaust gas cleaning systems (scrubbers) to meet both the global and ECA sulphur caps. Scrubbers remove sulphur from exhaust gases, with wash water as a byproduct, allowing the use of higher-sulphur fuels when operated and maintained according to IMO guidelines in MEPC.340(77).

Scrubbers are available as open-loop (discharging wash water directly into the sea), closed-loop (treating and recirculating the wash water) or hybrid systems. Local regulations vary by country, so members should consult specific guidelines on open or closed-loop usage; our resource here can be used as a guide.

New ECAs

The coverage of ECAs continues to expand, with MEPC 84 adopting the largest ECA to date in the North-East Atlantic.

Mediterranean Sea ECA

Entering into force on 1 May 2025, the Mediterranean Sea is now designated as an ECA, with the 0.10% sulphur limit in effect. Further details can be found here.

The Canadian Arctic and the Norwegian Sea ECA

The amendments to MARPOL Annex VI that designated the Canadian Arctic and the Norwegian Sea as new ECAs entered in to force on 1 March 2026. Both the Canadian Arctic and the Norwegian Sea ECAs for SOx will take effect on 1 March 2027, one year after these amendments came into force.

North-East Atlantic Ocean ECA

At MEPC 84 in 2026, the IMO adopted the North-East Atlantic Ocean as a new Emission Control Area, now the largest ECA designated to date.

This ECA covers a wide area including the waters of Greenland, Iceland, the Faroe Islands, and the western coasts of the United Kingdom and Ireland, extending south to Spain and Portugal, and effectively linking existing ECAs across Europe with the Canadian Arctic region.

The amendments enter into force on 1 September 2027, with SOx limits of 0.10% applying from 1 September 2028. NOx requirements will apply to new ships constructed on or after 1 January 2027 when operating within the area.

With most European and North American waters now designated as ECAs, ship operators should ensure that fuel procurement, changeover procedures, and crew awareness remain aligned with evolving MARPOL requirements when trading in these regions.

A useful infographic and further guidance on ECAs can be found here.

 

Photo credit: Venti Views on Unsplash
Published: 7 July, 2026

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FOBAS: Summary of marine fuel oil sulphur requirements

FOBAS publishes a bulletin to provide ship operators with an updated reminder of marine fuel oil sulphur regulations under various regulatory frameworks.

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Lloyd’s Register Fuel Oil Bunkering Analysis and Advisory Service (FOBAS) on Wednesday (24 June) published a bulletin to provide ship operators with an updated reminder of marine fuel oil sulphur regulations under various regulatory frameworks: 

MARPOL Annex VI

Ships operating inside or outside Emission Control Areas (ECA) for Sulphur Oxides (SOx) i.e., ECA-SOx, are

required to comply with specific sulphur limits in respect of the fuel oils as used unless the particular

combustion systems (engine, boiler, other) in use have in operation an approved exhaust gas cleaning system as per MARPOL Annex VI regulation 4. These fuel oil limits are as follows;

  • Inside ECA-SOx: Max sulphur content of 0.10% m/m
  • Outside ECA-SOx: Max sulphur content of 0.50% m/m

MARPOL Annex VI regulation 14.3 currently gives the following as ECA-SOx together with the respective geographic limits:

  • Baltic Sea;
  • North Sea;
  • North American (which includes an area around the Hawaiian Islands);
  • US Caribbean Sea;
  • Mediterranean Sea;
  • Canadian Arctic; and
  • Norwegian Sea

Additionally, MEPC 84 adopted the North-East Atlantic as an ECA-SOx which will come into effect from 1 September 2028.

European initiatives

For EU, UK, and Turkish ports situated outside ECA-SOx, ships must switchover to a fuel with a maximum sulphur content of 0.10% m/m when at berth. Similarly, Norway and Iceland have also 0.10% m/m requirements for ships at berth and operating in Fjords (territorial / internal waters).

Other initiatives

Due to increasing concerns around the environmental impact from shipping on local air quality, there are a number of national and local regulations which require the use of low sulphur fuel oils, typically maximum sulphur content 0.10% m/m, or other measures by all or certain ships within defined areas. Examples of these are China, California (CARB), South Korea and Sydney. Furthermore, there can be other related restrictions, for example, on the discharges to sea from exhaust gas cleaning systems.

However, whereas with the MARPOL Annex VI ECA-SOx, there is a single point of reference as to which areas are covered, there is no such central registry for these regional, national or local initiatives taken outside MARPOL Annex VI. Consequently, in all the cases, it is important for ships to check with the relevant authorities beforehand in order to confirm the current status as regards SOx and related emission requirements in order to avoid any penalties – which can be substantial.

 

Photo credit: Louis Reed from Unsplash
Published: 25 June, 2026

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ECA

DNV: North-east Atlantic joins expanding network of ECAs

DNV highlighted key information on the new North-East Atlantic ECA, which will enter into force on 1 September 2027, following recent amendments MARPOL Annex VI adopted at MEPC 84.

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Classification society DNV on Wednesday (17 June) highlighted key information on the new North-East Atlantic ECA, which will enter into force on 1 September 2027 following recent amendments MARPOL Annex VI adopted at MEPC 84, creating a continuous emissions control area across much of the North Atlantic: 

Need to Know

  • The new North-East Atlantic ECA will enter into force on 1 September 2027, creating a continuous emissions control area across much of the North Atlantic.
  • SOx limits (0.10% sulphur) will apply from 1 September 2028.
  • Ships meeting the MARPOL “three‑date” criteria (from 1 January 2027 onward) must comply with Tier III NOx limits for engines above 130 kW when operating in the ECA.

North-East Atlantic ECA

In general, the ECAs are designed to reduce air pollution from NOx, SOx and PM, and play a vital role in protecting sensitive marine environments as well as improving air quality for nearby communities.

The latest addition is the North-East Atlantic ECA, covering the Exclusive Economic Zones (EEZs) and territorial seas of Portugal, Spain, France, Ireland, Iceland, the Faroe Islands, Greenland and mainland UK that are not already included in existing ECAs. The EEZs surrounding Madeira, the Azores and the Canary Islands will be excluded. The precise ECA boundaries are defined by exact coordinates in Appendix VII of the revised MARPOL Annex VI.

Once in force, this designation will create a continuous ECA across the North-East Atlantic, linking the Canadian Arctic, Norwegian Sea, North Sea and Mediterranean Sea ECAs into a single, connected regulatory area.

eca map 2026 1

Application

The North-East Atlantic ECA, as part of the next amendments to Annex VI of MARPOL, will enter into force on 1 September 2027. The effective dates will be as follows:

SOx requirements

The sulphur limits for new North-East Atlantic ECA take effect 12 months after entry into force, in other words on 1 September 2028. From that date onwards, ships must use fuel with a sulphur content of no more than 0.10%.

Alternatively, compliance may be achieved using exhaust gas cleaning systems (EGCS) when operating on higher-sulphur fuels. However, it should be noted that restrictions on the use of open-loop EGCSs are becoming increasingly stringent, particularly in the coastal waters of northern Europe under OSPAR (please refer to our Technical and Regulatory News No. 26/2025), thereby limiting this as a practical compliance option in the region.

Note: The full article by DNV can be read here

 

Photo credit: william william on Unsplash and DNV
Published: 19 June, 2026

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