A PRACTICAL OVERVIEW OF THE IMO
2020 SULPHUR CAP Sulphur Cap Series: Part 1 - Scope of the Regulation and the Risks of Non-Compliance
With less than eighteen months before Regulation 14.1.3 of Annex VI of the MARPOL Convention comes into effect, there are still numerous challenges surrounding compliance and enforcement, which have cast uncertainty over the effect that the Regulation will have on the international maritime industry, and on individual shipping companies.
This three-part series aims to draw owners’ and charterers’ attentions to the practical issues that they should be aware of, ahead of the implementation of Regulation 14.1.3, and to highlight the various measures that they should now be considering, in order to safely absorb the significant costs and other commercial risks that are forecast to accompany the entry into force of the Regulation.
Part 1 provides a brief summary of the scope of Regulation 14.1.3, and an analysis of the different types of risks to which owners and charterers are likely to be exposed, if they do not take the necessary steps to comply with Regulation 14.1.3, by 1 January 2020.
SCOPE OF THE REGULATION
Regulation 14.1.3 of Annex VI of the MARPOL Convention (“Regulation 14.1.3”) was adopted by the IMO in 2016, in response to environmental concerns. The Regulation now provides that “the sulphur content of any fuel oil used on board ships shall not exceed ... 0.50% m/m on and after 1 January 2020.” The new limit will see a steep reduction in the permissible global sulphur limit, down from the 3.5% mass/mass (“m/m”) limit, currently in effect under Regulation 14.1.2. The limit will apply to all vessels registered with Flag States that have ratified Annex VI, and in all waters belonging to Port or Coastal States that have ratified Annex VI, at which, or through which, a vessel calls or passes.
The IMO has reconfirmed that Regulation 14.1.3 will take effect with immediacy, despite recent calls by leading Flag States and shipping associations for a period of “experience building” and “pragmatic enforcement”. The new limit will also not affect the ongoing obligation under Regulation 14.4.3 that vessels operating within Emission Control Areas (“ECAs”) use fuel with a sulphur content of only 0.1 m/m.
32 | ADMISI - The Ghost In The Machine | November/December 2018
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