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Updated: Sep 10, 2020

What is the Sulphur Cap 2020?

The responsibility with regards to the safety and security of the shipping industry, and the prevention of marine and atmospheric pollution by ships lies with the International Maritime Organization (IMO). In the Marine Environment Protection Committee (MEPC) London meeting of 2016, the IMO took a landmark decision to slash down sulphur emissions by 80%, even outside of the Emission Control Areas from 1st January 2020. The limit will fall from 3.5 wt. % to 0.5 wt. %. The IMO 2020 regulation will see the most significant reduction in the sulphur content of transportation fuel.

The four established Emission Control Areas that have had stricter regulations since 2015 are the Baltic Sea, the North Sea, the North American, and the United States Caribbean Sea. Here, the sulphur oxide emissions are limited to 0.10% m/m and hence, are not within the scope of the 2020 regulation.

Since 2005, the IMO’s regulation to reduce sulphur oxide emissions from ships, under Annex VI of the International Convention for the Prevention of Pollution from Ships (MARPOL Convention) has seen a progressive tightening, which will help reduce the environmental impact of the international shipping industry.

The shipping companies will need to make sure that their fleets comply with the sulphur limit in one of the three ways mentioned below:

· Use compliant fuels, such as Very low Sulphur fuel oil (0.5% VLSFO), ultra-low Sulphur fuel oil (0.1% ULSFO) or Marine Gas Oil (0.1% MGO). The problem that may occur is that ULSFO is a blend, so unless they are taking a regular route, calling in the same ports, they will face problems finding a consistent grade. MGO is consistent but is very expensive.

· Use of Exhaust Gas Scrubber Technology. Only MGO is compatible with this technology.

· Cylinder Lubrication, along with efficient control system, can neutralize the sulphur in the fuel and reduce sulphur dioxide emissions from the engine.

A blend of these methods is used by most companies to keep the sulphur oxide emission within the allowed limit.

Why it is needed and its impact

Heavy Fuel Oil (HFO) is the primary type of “bunker” oil for ships, which is a result of the residue from crude oil distillation. Crude oil contains sulphur which ends up in ship emissions following combustion in the engine. Sulphur dioxide is known to be harmful to human health, causing respiratory symptoms and lung disease. In the atmosphere, it can lead to acid rain, which can be detrimental to crops, forests and aquatic species, and adds to the acidification of the oceans.

Curbing sulphur dioxide emissions from ships will improve air quality and protect the environment. This reduction in the number of sulphur oxides emanating from ships will have considerable health and environmental benefits for the world, especially for populations living closer to ports and coasts.

The ships, before the regulation, used substandard fossil fuel today known as Heavy Fuel Oil along with other refined products. This fuel oil is a waste product of the simple refinery presses with a demand of 8 million barrels per day. A majority of the marine fuels which ships use have high sulphur of up to 3.5%. The shipping industry demands 50% of High-Sulphur Fuel Oil supply, and thus, the regulation will see a stark reduction in refining economics.

MARPOL aims at minimizing pollution from ships, whether accidental or from a routine operation. As said by an IMO air pollution and energy efficiency study, by the introduction of these lower sulphur oxide emission guidelines, about 570,000 deaths could be averted between 2020 and 2025. Very-low Sulphur fuel (VLSFO) generates less sooty air, which in turn lowers particulate matter in the air, resulting in fewer respiratory problems.

Following the 2020 regulation, reducing sulphur emissions by utilizing low sulphur fuel oils in shipping vessels will help reduce at least 50 % greenhouse gas emissions by 2050, translating to an annual reduction of 8.5 million metric tons.

Non-Compliance of the Regulation

Port states are responsible for inspecting the compliance of the ships with IMO 2020. In case of non-compliance, the port authority may put a brake on the sailing of ship vessels to any port unless compliance procedures are completed, together with eliminating all non-compliant fuel. The port state may find the information on where that fuel oil originated from, in respect to non-compliance and report to respective authorities.

According to Reuters, non-compliance with the regulation may result in vessel detainment, fines, and possibly imprisonment. The state party must consider all critical incidences and evidence while deciding what penalty to impose on the ships that fail to abide by the sulphur limit. On the other hand, the port and flag state control bodies may consider the ship’s execution plan when penalizing the vessels that do not comply with the 0.5% sulphur restriction requirement


Following IMO’s previous decisions, the first reduction was enforced in 2005 with a 4.5% Sulphur cap. In 2012, there was a further reduction to 3.5 wt. %. The decision to make it 0.5% in 2020 was taken way back in 2008, and it got ratified in 2016 in the 70th session of MEPC meeting. So, ship owners and leasers got ample time to prepare for this regulation since this was not a sudden change.

The IMO 2020 regulations reducing sulphur oxide emissions to less than 0.50% will significantly impact the current shipping industry. But we must remember that the 2020 regulation is not the first change of sulphur oxide emissions standards as this has been done in 2005 and 2012 as well. The prior sulphur caps did not cause a considerable fuel shortage or a permanent increase in prices.

It is also salient to keep in mind that sulphur dioxide is only one type of emission by the shipping vessels. Ships emit high amounts of nitrogen oxides and carbon oxides, which are very harmful in their own ways. In the quest to make shipping a greener industry, this is the first of many steps taken, for technological advancements and the environment.


Saloni Bhambi and Simantini Baraokar Author Details:

The authors are 4th year Law students currently studying at ILS Law College, Pune. They have a keen interest in Maritime Laws, Environment Laws, Business Laws and Gender Studies. We are also students committed to legal aid. When they are not keeping busy with Law school activities, one can find us putting our artistic flairs to use. 

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