THE 2020 GLOBAL SULPHUR CAP－Allocating Risk and Responsibility <Some Key Charterparty Issues> Introduction As Members are likely aware new IMO sulphur regulations will come into force on 1 January 2020. On that date the MARPOL permitted limit for sulphur content in ship’s bunker fuel oil will be reduced from 3.5% m/m to 0.5% m/m. From 1 January 2020 vessels will only be permitted to burn fuel with a sulphur content below 0.5% m/m (hereinafter referred to as “Compliant fuel”) and the burning of fuel with a higher sulphur content than that (hereinafter referred to as “Non-compliant fuel”) will be prohibited. In addition, the IMO has also approved a prohibition on the carriage of Non-compliant fuel which will come into force on 1 March 2020.   Members, whether Charterers or Owners need to make sure they are ready for the introduction of the new regulations and that the risk and responsibility for complying with them is clearly allocated between the parties under their Charters. If there is no charterparty wording dealing with the issues raised by the new regulations, then the allocation of responsibility for compliance may be unclear. This means that disputes between the parties and potentially expensive legal proceedings are far more likely. This is of course highly undesirable for all parties involved.   In this article we will consider some of the issues that will arise under time charters as a result of the new regulations and how they might be addressed.     Some Key Charterparty Issues As a starting point the charterparty should include clear wording which provides Owners are responsible for ensuring that the vessel is able to consume fuel that will comply with the sulphur content requirements of MARPOL Annex VI. To avoid any ambiguity, the charter should also include wording that provides fuel supplied to the vessel (usually the responsibility of Charterers) is compliant with the new regulations in terms of its sulphur content.   A