A Look at the 2020 Fuels Quandary

Although it feels like an overnight change, it is important to remember that these are not new issues. These are items that have been debated for well over ten years, ever since MARPOL Annex VI underwent a comprehensive revision shortly after its entry into force.

Author: Nick Makar, Regulatory Affairs Advisor, International Registries, Inc.

“When the decision was taken to keep 1 January 2020 as the effective date, concerns were raised related both to enforcement and to the idea that, for this regulation to work, a level playing needed to be maintained in order to avoid commercial distortion due to the costs of compliance,” Makar explains. “The carriage prohibition was among a set of amendments to Regulation 14, which, as currently structured, controls the sulfur content of fuels in use; the amendment adds a provision that also prohibits the carriage of those fuels. It’s a simple, elegant proposal to simplify enforcement – if you are not supposed to use high-sulfur fuel, why have it onboard? That was the intention,” he says. “It was also intended to aid enforcement, principally at sea, when ships aren’t within port or local jurisdiction.”

Concerns about the safety of fuel blends post-2020 are being addressed by the PPR subcommittee, but for now it seems shipowners just have to look out for themselves, as guidance from their flag States and industry groups develop. Or, as the ISO representative is reported to have told the PPR subcommittee meeting: “Recognizing that some degree of mixing of different fuel oils onboard the ship cannot be avoided, many ships today have already procedures in place to minimize co-mingling of fuel oils with bunker segregation being always the first option. We would therefore encourage ship operators to evaluate further their segregation policy.”