BIMCO's position on "air pollution" has been approved by the BIMCO Board of Directors.
The revised MARPOL Annex VI on Prevention of Air Pollution from ships was adopted by IMO in 2008. 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 0.5% on the sulphur content in marine fuel oil from 2020 in areas outside special designated emission control areas. A scientific study on the availability of fuel for ships to comply with this provision shall guide IMO in deciding on whether to keep 1 January 2020 as the implementation date or to postpone until 1 January 2025.
A global shift from residual fuels with maximum 3.5% sulphur to primarily distillate fuel with maximum 0.5% sulphur will not only severely affect the bunker industry, but also the refiners and their ability to ensure availability of compliant fuel from day one.
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 supports the revised MARPOL Annex VI, including 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.
Regional or national regulations for emission control should thus be aligned with existing international provisions.
The IMO decision on the feasibility of implementing the global 0.5% sulphur limit on fuel oil should take into account the need for uniform compliance and effective enforcement to ensure a sustainable way forward for both the shipping industry and society in general.
To ensure a level playing field, it is important that the global sulphur cap does not result in a shortage of fuel.
A robust enforcement of applicable sulphur limits is critical to ensure a level playing field for owners.
- Considering shipping’s share of total black carbon deposition in the Arctic area, a proportionate response does not justify regulating international shipping’s black carbon emissions in that region.