britanniapandi.com The global low sulphur requirements of 0.50% by mass (m/m) came into force on 1 January 2020 under the MARPOL convention. However, some areas/regions have implemented separate local legislation with stricter requirements. Experience has shown that new changes to existing legislation in some places can happen with very little notice. Therefore, it is very important that shipowners always show due diligence and liaise closely with their local representative to obtain latest advice and before their ship enters a port state’s territorial waters. MARPOL EMISSION CONTROL AREAS There are currently five Emission Control Areas (ECAs) controlling the emissions of Sulphur Oxides (SOX). Control is achieved by capping the sulphur limit of the fuels in use in these areas at 0.10% m/m. These ECAs are the ‘Baltic Sea’, the ‘North Sea’, the ‘North American’, the ‘United States Caribbean Sea’ and the ‘Mediterranean Sea’. For the Mediterranean Sea, the requirement to use fuel with a 0.10% m/m sulphur content limit will come into force on 1 May 2025, following the 12-month exemption period as per MARPOL Annex VI, Regulation 14.7. Similarly, the new ‘Canadian Arctic Waters’ and the ‘Norwegian Sea’ ECAs will come into force on 1 March 2026, with the fuel sulphur limit becoming enforceable 12 months later. It is highly recommended to verify the current status with the latest IMO updates or official communications. REGIONAL AND NATIONAL REQUIREMENTS AUSTRALIA As per the Australian Maritime Safety Authority (AMSA) 02/2024, all cruise ships berthing in Sydney Harbour with a capacity to accommodate more than 100 passengers are required to limit sulphur emissions. This can be achieved by using low-sulphur fuel (sulphur content <0.10% m/m) or implementing an alternative measure, such as an Exhaust Gas Cleaning System (EGCS) or shore power etc. The limitation on sulphur emissions applies from one hour after the ship’s arrival at berth until one hour before its departure. CHINA • From 1 January 2020, ships must use low sulphur content fuel not exceeding 0.10% m/m when entering parts of the Yangtze and Xi Jiang Rivers - Inland Water ECAs LOSS PREVENTION UPDATE LOW SULPHUR REGULATIONS – EMISSION CONTROL AREAS 1 // APRIL 2025 britanniapandi.com 2 // APRIL 2025 • From 1 January 2022, ships must use low sulphur content fuel not exceeding 0.10% m/m when entering the territorial sea including the province of Hainan - Hainan Coastal ECA. So far alternative means such as ECGS have been accepted. However, the use of open scrubbers has been banned in certain parts of the Coastal ECAs. Ships equipped with onboard shore power systems must connect to and utilise them when berthing at ports with operational shore power facilities. Non-compliance may lead to penalties under local regulations. EUROPEAN UNION (EU) EU sulphur emissions from ships are regulated by Directive (EU) 2016/802 ‘Sulphur Directive’. Since 1 January 2010, ships of all flags berthed in EU ports are required to use fuels with a maximum sulphur content of 0.10% by mass. The transition to low-sulphur fuel must begin as soon as possible after berthing and revert as close to departure as possible. Ships scheduled to berth for less than two hours, according to a published timetable, are exempt from this requirement, as are ships fully switching to a shoreside electricity supply. For the purposes of this regulation, a ship is considered “berthed” when securely moored or anchored in an EU port while lo