Credit to: Mr Nai / Shutterstock.com Introducing the issue Few will be unaware that the IMO 2020 Sulphur Cap will come into force on 1 January 2020. As of this date, the global sulphur limit under MARPOL Annex VI will be reduced from 3.5% to 0.5%. There are clear concerns that there will not be enough compliant bunkers available in some areas when the regulation goes live. Others are concerned about how Port State Control (PSC) and other authorities will verify the sulphur content in bunkers and how the limit will be enforced. In the meantime, many owners have already installed, or are contemplating installing, scrubbers or LNG fuel equipment. Scrubbers could arguably result in savings or increased time charter equivalent (TCE) earnings, given the likely significant price difference between low and high sulphur bunkers. Scrubbers will require a significant investment. One would also need to consider the type of scrubber to be installed, mainly whether to install with an open, closed or hybrid loop, and perhaps with an eye on other potential changes in this area. The sulphur regime application The new sulphur regime is set out in MARPOL Appendix VI and, more specifically, in regulations 14 and 18 therein. The 2020 IMO Sulphur Cap will apply worldwide, to all fuels, whether used in the main or ancillary engine, boilers or for lubrication. It applies to all ships, as well as many offshore installations. Certification will be arranged by or through Flag States, which may have delegated responsibility from Classification Societies to issue valid International Air Pollution Prevention Certificates (IAPPC) to ships being 400 GT or more. Importantly, the sulphur regulation in designated areas under the Sulphur Emission Control Areas (SECA), with mainly 0.1% limits, still applies. Even if you trade only between non-MARPOL Appendix VI countries, you may risk falling foul of the regulation if a ship has to divert and the right of a vessel's innocent passage comes into sharper