IMO 2020 Sulphur Cap

As of 1st January, 2020, amendments to MARPOL have brought in a global sulphur cap of 0.50%. This regulatory change, although undoubtedly a positive one for the marine environment, nevertheless brings with it significant commercial, financial, legal and practical implications for owners and charterers alike.  

In the lead-up to 2020, we have guided our Members as to how best to prepare for the transition, in both contractual and practical terms.  Now that the new regulations are in force and the sulphur cap has become a reality, we are closely monitoring the emerging issues and will continue to provide guidance to Members to ensure a smooth transition into 2020. 

In this dedicated section of our website, we offer a series of focused bulletins as well as resources and external industry guidance for the benefit of our Members.  

Members are invited to sign up here to receive access to our regular updates.

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'A Guide For Singapore-Registered Ships' and 'A Guide For Ships Calling To Port Of Singapore'.

Despite the different solutions available for the industry to comply with the impending 2020 Sulphur Cap, there is still no consensus from the industry on which works best for the long-run. This is outlined by industry experts in a newly-launched Sea Asia industry insights report, ‘2020 Sulphur Cap: Is the industry ready for the long-run?’.

A panel of industry leaders offer perspectives from the energy, finance and legal standpoints on the IMO global sulphur cap 2020 regulation, with a focus on the risks and challenges the shipping industry faces in the run up to a multi-fuel future. The panel raised the issues of fuel availability, contaminants, new building vs retro-fitting, and regional attitudes to the regulation.

The following ICS Guidance was first issued in September 2018. This version has been updated to take account of decisions made by the IMO Marine Environment Protection Committee (MEPC) in October 2018. A further update is anticipated after the next IMO MEPC meeting in May 2019.

Guidance on the development of a ship implementation plan for the consistent implementation of the 0.50% sulphur limit under MARPOL Annex VI.

MARPOL amendments entered into force on 1 January 2019. Data collection on fuel oil consumption by larger ships begins. Also, IMSBC Code amendments entered into force.

Taiwan's Ministry of Transportation and Communications (MOTC) has announced that Taiwan will start implementing this limit a year early.

In this edition of our “Sulphur Series”, we look in more detail at the practical steps that will need to be taken in order to prepare ships without scrubbers for the switchover to low sulphur fuel on 1st January, 2020. We also consider how the allocation of responsibilities and costs related to such steps might be dealt with contractually.

As an alternative to switching to cleaner, yet more expensive, low sulphur fuel some ship operators have chosen to achieve compliance with the MARPOL sulphur emissions regime by means of the installation of exhaust gas cleaning systems, commonly known as scrubbers, which will enable them to filter non-compliant fuel at a lower cost.

BIMCO has this week published two new clauses designed to address the forthcoming low sulphur content regime which will come into force on 1st January, 2020.


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