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 GLOBAL SULPHUR CAP 2020

Global Sulphur Cap

2020
Overview 

FAQ - General

What are the sulphur limits for fuel 

in use under MARPOL?

ANSWER:
With the adoption in 2008, 1 January
2020 was given as the effective date for
the 0.50% global sulphur cap, with an
option to later defer the date until 1
January 2025, taking into account the
global market supply and demand. In
2016, the IMO decided, based on
information provided, to stick with the 1
January 2020 date. Hence, from 1
January 2020, the global sulphur limit
will be reduced from 3.50% to 0.50%.
For vessels operating in Sulphur
Emission Control Areas (SECA) under
MARPOL, the limit, which will remain
unchanged, has been 0.10% since 1
January 2015.

FAQ - Operational

What will be the implication of

having fuel exceeding 0.50% 
sulphur remaining on board after 1
January 2020?

ANSWER:
Unless the vessel is fitted with a
scrubber (Exhaust Gas Cleaning System
[EGCS]), fuel oil exceeding 0.50%
sulphur can’t be used after 1 January
2020. All remaining HSFO must be de-
bunkered before 1 March 2020 when
the carriage ban for HSFO enters into
force. To avoid having non-compliant
fuel on board on 1 January 2020, it is
important to work out a bunkering
strategy ahead of the 2020 deadline.

For a vessel fitted with an EGCS +

and using HSFO instead of
compliant fuel, will there be any
restrictions on incineration of
sludge generated from HSFO after
2020?

Is the carriage ban for non- +

compliant fuel also applicable to
emergency equipment?

What about excessive non +

compliant fuel after a FONAR
situation?

Will there be a grace period in +

early 2020 where there will be no
Sulphur content controls of fuel in
use?

What if the sulphur analysis +

resulting from a commercial
analysis does not match the
bunker delivery note?

Is the >0.5% sulphur carriage ban +

as of 1 March 2020 making
exceptions for scrubbers and if
where is this regulated?

What is the risk of bunkering +

incompatible fuel?

Are Incinerators subject to the +

MARPOL Sulphur requirements?

In case of any excess HSFO after 1 +

January 2020 can that be diluted
onboard with sufficient low
sulphur fuel to achieve
compliance?

FAQ - Enforcement

What control measures will be in


place to enforce the 0.50% global
sulphur requirements from 2020?

ANSWER:
PSC will typically check the IAPP
certificate, together with the Bunker
Delivery Notes (BDNs), filed on board.
If there are “clear grounds” to do so,
PSC may conduct a more detailed
inspection, including on-board
sampling or analysing of the MARPOL
sample following the BDN. “Clear
grounds” may be indications from
remote sniffing devices or portable
sulphur content measuring devices that
the fuel used on board may be non-
compliant.

What may be the consequence of +

failing to comply?

When can the MARPOL delivered +

sample be claimed by PSC for
analysis.

What will be role of PSC +

inspectors post 2020 January 01 in
respect of compliance with fuels
and emissions?

FAQ - EGCS

Can fuel exceeding 0.50% sulphur

be used for testing of scrubbers 
e.g. during sea trail and
commissioning after 2020?

ANSWER:
For EGCS approved according to
Scheme B of MEPC.259(68) there is no
requirement for commission testing
with fuel oils exceeding 0.50% sulphur.
In principle the system can be tested
and commissioned with low sulphur
fuels and the IAPP including the EGCS
can be issued. In case the EGCS is to be
approved according to Scheme A of
MEPC.259(68) or the ship operator
requires testing and commissioning
with fuel oils exceeding 0.50%, flag
state and port state needs to be
contacted on a case-by-case basis
asking for exemption.

Are there any limitations on the +

fuel Sulphur content when using a
scrubber?

How to deal with EGCS failure at +

sea?

What to do in case of EGCS sensor +

failure?

What operational hick-ups have +

DNV experienced from use of
scrubbers?

For a ship using a scrubber, what is +

the time allowed being out of
compliance if the scrubbers fails,
before it is being brought up to
service or switch to compliant
fuel?

Are vessels with EGCS installed +

required to have a compliant fuel
onboard in case of EGCS failure?

What is the procedure for the +

issuance of IAPP certificate
including the exhaust gas cleaning
(EGC) system?

Are there any special requirements +

from the US Coast Guard?

Can fuel used for Inert Gas (IG) +

systems, which use a flue gas
scrubber, on tankers exceed
0.50% sulphur?

FAQ - FONAR

What happens if compliant fuel


cannot be obtained in the port of
bunkering?

ANSWER:
A Fuel Oil Non-Availability Report
(FONAR) shall be submitted to the flag
state, with a copy to the port of
destination, as soon as it is determined
that compliant fuel oil will not be
available. The standard FONAR form
can be found in Appendix 1 of
MEPC.320(74).

FAQ - Sampling

When are we required to install 

the “in use“ sampling points?

ANSWER:
The amendments to MARPOL requiring
sampling points for the purpose of
taking representative samples of the
fuel oil in use,will enter into force 1
April 2022. This implies that for vessels
keel laid before the entry into force
date sampling points shall be fitted or
designated no later than the first IAPP
renewal survey one year after the entry
into force date, i.e. the first IAPP
renewal survey after 1 April 2023

Will fitting of sampling point be +

subject to approval?

What are the allowable margins +

for the sulphur content for 2020
LSFO?

How should the “on bord” sample +

be taken?

GUIDANCE PACKAGE: Global

Sulphur Cap 2020
 Download our guidance documents
including scrubbers, fuel switch
options, checklists and more

Overview 

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