Stricter Sulfur Emission Regulations Transform Maritime Transport

Global Efforts to Reduce Ship Pollution Intensify with Expanding Emission Control Areas and Tighter Fuel Standards


In recent years, the regulation of sulfur emissions in maritime transport has intensified across various regions worldwide. This is part of a global effort to reduce atmospheric pollution generated by ships. Gard, a maritime insurance provider, has reported an increase in requests for guidance from clients and members who have faced sanctions for using fuels with sulfur content exceeding permitted levels in certain ports or maritime zones. According to Gard, this issue largely stems from ship operators and crews being unfamiliar with local regulations.

Implementation of Regulations

Numerous states and ports have enacted stringent limits on sulfur emissions, with the list of locations imposing such restrictions continually expanding. Gard warns that new local regulations or changes to existing ones can be implemented without prior notice. Therefore, ship captains are advised to consult with local agents about specific requirements before arriving at a port.

Gard’s recommendations for operators include:

  1. Awareness and Procedures: Ensuring that crews are informed about sulfur emission limits in the jurisdictions they operate in and that clear procedures are in place.
  2. Fuel Evaluation: Considering low-sulfur fuel options that comply with applicable regulations.
  3. Switching Procedures: If using multiple types of fuel, ensuring that the switching process is done well in advance to avoid contamination with non-compliant fuels.
  4. Use of Scrubbers: Checking with local authorities about the acceptance of exhaust gas cleaning systems (scrubbers) for sulfur emission reduction, and being mindful of local restrictions on the discharge of wash water from these systems.

MARPOL Emission Control Areas

The MARPOL Annex VI sets out specific Emission Control Areas (ECAs) where sulfur content limits in fuels are more stringent. Currently, these zones include North America, the U.S. Caribbean, the North Sea, and the Baltic Sea. Starting May 1, 2025, the Mediterranean Sea will also be designated as an ECA, with a sulfur limit of 0.10% applicable after a 12-month grace period.

In March 2024, the International Maritime Organization (IMO) approved proposals to designate the Canadian Arctic and the Norwegian Sea as new ECAs. The modified regulations are expected to be approved in October 2024, with the 0.10% sulfur limit coming into effect in early 2027.

Specific Regulations

Although the Panama Canal is not within the MARPOL-designated ECAs, it follows its own set of regulations to limit sulfur emissions, applying a global sulfur cap of 0.50%. Ships preparing to transit the Canal must switch to marine distillate fuels for their propulsion engines, boilers, and other auxiliary equipment upon entering its waters.

California, USA, presents a particularly strict and complex regulatory environment due to overlapping regulations. While Californian waters are part of the North American ECA under MARPOL Annex VI, which imposes a sulfur limit of 0.10%, the state has implemented additional regulations through the California Air Resource Board (CARB). CARB’s Ocean-Going Vessel (OGV) regulations not only require a 0.10% sulfur limit but also mandate that the fuel used meets specific distillate grade specifications. This regulation does not permit the use of scrubbers as an alternative for reducing sulfur emissions. Vessels operating within 24 miles of California’s coast must comply with both sets of regulations.

China has also taken proactive measures by establishing its own national Emission Control Areas. Since September 2015, China has implemented a coastal ECA covering all maritime zones and ports within its territorial seas, as well as a designated ECA in Hainan province, known as the Hainan Coastal ECA. Additionally, there are two inland ECAs covering significant parts of the Yangtze and Xi Jiang rivers. In these areas, a sulfur limit of 0.50% applies for the coastal ECA, and a stricter limit of 0.10% for the inland ECAs and Hainan province. Ships must complete any fuel switching operations before entering an ECA or initiate them after leaving to comply with the established sulfur limits.

Broader Context

These regional efforts to curb sulfur emissions align with global maritime strategies aimed at mitigating environmental impact. The enforcement of sulfur limits has been part of an ongoing evolution in maritime environmental regulation, reflecting increasing awareness and commitment to sustainability within the industry. The introduction of ECAs is a significant step in the IMO’s broader mandate to reduce air pollution from ships and protect human health and the environment.

Historically, sulfur emission regulations have evolved significantly. The International Convention for the Prevention of Pollution from Ships (MARPOL) initially addressed oil pollution, but later annexes expanded its scope to include various pollutants, including sulfur oxides (SOx) and nitrogen oxides (NOx). The establishment of ECAs and subsequent tightening of sulfur limits represent critical milestones in the global effort to reduce maritime pollution.

Looking ahead, the maritime industry must continuously adapt to evolving regulations, investing in cleaner technologies and ensuring compliance with regional and international standards. The ongoing expansion of ECAs and the implementation of stringent sulfur limits underscore the importance of vigilance and proactive measures in safeguarding both the maritime environment and public health.

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