The IMO’s bunker delivery note amendments relating to the supply of marine fuel to ships fitted with alternative mechanisms to address sulphur emission requirements entered into force on January 1, 2019.
The amendment enters into force a year before the global 0.5 per cent sulphur cap. The amendments to the bunker delivery note are intended to address situations where the fuel supplied does not meet low sulphur requirements, but has been supplied to a ship which is using an alternative compliance method, such as a scrubber, permitted under regulation 4 of MARPOL Annex to meet the sulphur cap.
The IMO reports that the bunker delivery note shall include a declaration signed and certified by the fuel oil supplier’s representative that the fuel oil supplied is in conformity with regulation 18.3 of MARPOL Annex VI and that the sulphur content of the fuel oil supplied does not exceed:
- The limit outside ECAS (currently 3.5 per cent, falling to 0.5 per cent from January 1, 2020)
- The limit in Emission Control Areas (ECAs) (0.1 per cent)
- The purchaser’s specified limit value, on the basis of the purchaser’s notification that the fuel oil is intended to be used:
- in combination with an equivalent means of compliance; or
- is subject to a relevant exemption for a ship to conduct trials for sulphur oxides emission reduction and control technology research.
On March 1, 2020, the IMO’s Marine Environment Protection Committee (MEPC) ban on carriage of non-compliant fuel, unless the ship is fitted with and using an abatement system, will enter into force. This amendment will amend the form of the International Air Pollution Prevention Certificate (IAPP Certificate), so that it specifies that, for a ship without an approved equivalent arrangement, the sulphur content of fuel oil carried for use on board the ship shall not exceed 0.5 per cent documented by bunker delivery note.
In addition to the bunker delivery note amendments, IMO notes the following have been implemented from January 1, 2019:
- Amendments to MARPOL Annex VI to designate the North Sea and the Baltic Sea as ECAs for nitrogen oxides (NOX). Both ECAs will take effect on January 1, 2021 and will result in considerably lower emissions of NOx from international shipping in those sea areas.
- Ships 5,000 gross tonnage and above will have to start collecting data on their fuel-oil consumption, under the mandatory data collection reporting requirements which entered into force in March 2018.
- The 2017 set of amendments (04-17) to the International Maritime Solid Bulk Cargoes Code (IMSBC Code) cargoes entered into force on January 1, 2019.The amendments include requirements for the shipper to declare whether or not a solid bulk cargo, other than grain, is harmful to the marine environment.
- Other amendments include updated carriage requirements for a number of specific cargoes and amendments to highlighting the responsibility of the shipper for ensuring that a test to determine the transportable moisture limit (TML) of a solid bulk cargo is conducted.