Technical Circular No: 041/2019

Subject: Guidelines for Consistent Implementation of the 0.50% Sulphur Limit Under MARPOL Annex VI

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  • Regulation 14 of MARPOL Annex VI sets out control measures to reduce emissions of Sulphur Oxides (SOx) and Particulate Matter (PM) from ships. From 1 January 2020, the limit of the sulphur content of any fuel oil used on board ships will be tightened from 3.50% m/m to 0.50% m/m outside emission control areas (ECAs).
  • It is required to plan for transition to compliant fuel oil on board ships in advance before 1st January 2020, unless the ship is fitted with an approved equivalent arrangement.
  • IMO Marine Environment Protection Committee vide Resolution MEPC.320(74) has provided guidelines to ensure consistent implementation of the 0.50% Sulphur Limit under MARPOL Annex VI.
  • The resolution addresses following issues with respect to implementation of 0.5% sulphur limit:
    • Planning for 2020, encouraging the development of ship implementation plans (SIP)
    • Impact on fuel and machinery, covering characteristics and challenges with different fuel oil types, technical considerations for ship owners, ISO standard for residual fuels and cylinder lubrication
    • Verification issues and control mechanisms, including survey and certification by administrations, control measures by port states, control of fuel oil suppliers, and information sharing
    • Fuel oil non-availability, including the FONAR (fuel oil non-availability report) standard reporting format
    • Possible safety implications related to fuel oils
  • In case that compliant fuel oil may not be received at the scheduled port of call, and no feasible alternative exists, the ship will be required to prepare and submit a Fuel Oil Non-Availability Report (FONAR) as indicated in Section 5 of IMO Resolution MEPC.320(74). The IMO FONAR template given in the MEPC.320(74) Appendix 1 and annexed to this circular should be used.
  • The Ship Implementation Plan (SIP) may include the contingency measures and FONAR procedures as described in above MEPC resolution.
  • To facilitate compliance, IMO has developed guidelines which include a template for a Ship-specific Implementation Plan (SIP) that may be used. The plan is not mandatory and is not subject to endorsement by the flag state or a recognized organization (RO). However, PSC may consider the preparatory actions described in the SIP when verifying compliance.
  • Ship owners, operators and Masters are advised to be guided by attached Resolution MEPC.320(74).



This Technical Circular and the material contained in it is provided only for the purpose of supplying current information to the reader and not as an advice to be relied upon by any person. While we have taken utmost care to be as factual as possible, readers/ users are advised to verify the exact text and content of the Regulation from the original source/ issuing Authority.

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