Air pollution

Overview

BIMCO's position on "air pollution" has been approved by the BIMCO Board of Directors.

Background

MARPOL Annex VI on Prevention of Air Pollution from ships entered into force in 2006. It covers sulphur and particulate matter, nitrogen oxides, ozone depleting substances and the energy efficiency of ships.

MARPOL Annex VI introduces a global cap of 0.50% on the sulphur content in marine fuel oil from 2020 in areas outside designated emission control areas. This will result in a global shift from residual fuels with maximum 3.50% sulphur to primarily distillate fuel with maximum 0.50% sulphur.

Some studies  show that the refineries will not be able to produce sufficient low sulphur fuels for the bunker industry to meet demand from day one. Based on BIMCO’s initiative, IMO has tasked a working group to consider how a smooth and effective implementation of the new sulphur limit may be facilitated, as an urgent matter.

Uniform compliance with the sulphur emission limits and effective enforcement is of critical importance to ensure a level playing field.  It will not be sustainable for compliant ships to compete with non-compliant ships.

BIMCO’s position

  • The prospect of a shortfall of compliant fuel is of great concern to BIMCO because it may lead to non-compliance and serious market disruption and distortion.
  • The quality of fuel and its fitness for use on board ships may have a negative effect on safety and deteriorate the fuel stability when the sulphur content is reduced in residual-like fuel oils.
  • A ban of carriage of non-compliant fuel onboard ships not equipped with alternative compliance means will facilitate enforcement by allowing port state control to take proactive steps.
  • Regional or national regulations for emission control must be aligned with Annex VI.
  • A robust enforcement of applicable sulphur limits is critical to ensure a level playing field for owners. A clear distinction should be made between cases, where the shipowner has bought compliant fuel which leads to minor non-compliance (just above 0.50 % sulphur) and deliberate non-compliance by using of HFO with a high sulphur content.
  • BIMCO does not support name and shame initiatives by authorities for cases of minor non-compliance.
  • BIMCO supports the requirements for Emission Control Areas (ECAs) as the authoritative framework for implementing regional or national air emission control measures for sulphur and nitrogen oxides.

 

Rasmus Nord Jorgensen
in Copenhagen, DK

ELSEWHERE ON BIMCO

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