sulphur, sulphur cap, bunkers, bunkering, contract, charterparty Home Publications Articles Sulphur 2020: Contractual Conundrums Sulphur 2020: Contractual Conundrums Publications Heloise Campbell Published: July 25, 2019 Contact author Download article pdf   March 2019 Video article   As Members will be aware, the Marpol Annex VI Regulation 14.1.3 (the “Regulations”) will come into force on 1 January 2020 requiring vessels to comply with the 0.5% SOX emissions limit worldwide, other than in Emission Control Areas [ECA] to which the existing 0.1% limit will continue to apply. The Club has already discussed the options available for compliance in its August 2018 article . However, with less than 10 months to go before implementation, more questions are being asked as to the contractual responsibilities and liabilities for compliance with this wide ranging Regulation. As of 1 January 2020, the Regulations will limit the sulphur content for ship’s fuel and as of 1 March vessels will be prohibited from carrying fuels with a sulphur content in excess of 0.5% (except as cargo or with a scrubber fitted). Therefore, from these dates vessels will either need to use low sulphur fuel oil or have a scrubber fitted. This article highlights contractual issues which are likely to arise from these Regulations and may give rise to disputes. In order to minimise the scope for disputes, these issues should be considered and negotiated between the parties, in order that contracts contain suitable clauses to address these. Charterparty Issues – the need for clauses to address these Obligation on Charterers of Non Scrubber Equipped Vessels to Supply LSFO Unless negotiated recently, and with an eye to the Regulations, existing Charterparties are unlikely to specify that compliant LSFO is to be supplied to the vessel. However, even if this is not expressly stated, a term may be implied requiring any fuel supplied to be lawful and compliant with the Regulations as in the absence of