It has only been three weeks since the new ultra low sulphur regulations have come in to force in North America and Northern Europe, and already it is becoming clear that these rules will have teeth and that enforcement will be rigorous. Both the EPA in America and in Europe statements are being made to this very effect. The EPA penalty guidelines The Environmental Protection Agency (EPA) of the United States has now issued a detailed set of guidelines for setting of penalties, should a vessel fail to comply with the new regulations that mandate a maximum of 0.10% sulphur content in fuel for designated Emission Control Areas (ECAs). These guidelines are republished alongside this advisory for members' reference. The Association is grateful to Messrs. ECM for permission to republish alongside this advisory their Client Alert 03-2015 which explains the key points of the EPA's guidelines. Important points to note are: civil penalties may amount to USD25,000 per violation, per day penalties are not limited to sulphur content violations penalties are designed to deter future violations, that means they are likely to be larger the more aggravated the offence was found to be The Association would again remind members of the very stringent approach to environmental violations taken by both the EPA and the USCG - and it could be possible to be subjected to both criminal and civil sanction for an offence. Warning:   an additional, and very serious offence, is the giving of false information to a federal officer. A felony offence punishable by up to five years in prison. The Association has previously advised on the enforcement doctrine in North America: North American ECA compliance. European enforcement doctrine According to the Danish Ministry of the Environment, new EU rules will see member states be required to check on 10% of vessels calling in relevant member state ports per year, specifically reviewing logs and bunker delivery notes. The new rules would then