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Monday, January 21, 2019 

According to Gard, the Norwegian insurer, IMO considers exhaust gas scrubbers to be an acceptable means of reducing vesselsí sulphur emissions and ensuring compliance with MARPOL Annex VI. Resolution MEPC.259(68), sets out the criteria for discharging scrubber washwater into the sea.

However, some coastal states and ports have implemented local regulations with more stringent requirements that restrict or completely prohibit the discharge of washwater from open loop scrubbers or prohibit the use of scrubbers altogether. Gard is currently aware of the following regions/states/ports with local regulations that have an effect on the discharge of exhaust gas scrubber washwater. Full details of the applicable restrictions can be found on Gard's website, here.


  • China: China’s MOT issued its ‘Notice on Regulating the Implementation of Supervision and Management of Ship Air Pollutant Emission Control Areas’ which states that from 1 January 2019 discharge of washwater from scrubbers is prohibited in the county’s inland emission control areas (ECAs), port water areas of coastal domestic ECAs and Bohai Bay waters. The document also states that a ban in the entire coastal domestic ECA will be announced in due course.
  • Singapore: According to the Maritime and Port Authority of Singapore (MPA), discharge is prohibited in Singapore port waters from 1 January 2020.
  • India: In a Circular, India seems to indicate that scrubber washwater discharges are allowed if the criteria set out in MEPC.259(68) are met. However, this is qualified with a requirement that local regulations should also be followed.
  • Abu Dhabi, UAE: Guidelines state that scrubber washwater can be discharged in port waters if free form pollutants whilst scrubber sludge should be discharged from the vessel to a licensed waste disposal contractor.


  • Belgium: An EC note bans the discharge in ports and inland waters.
  • Germany: Discharge is not allowed in inland waterways and the Rhine.
  • Lithuania: The current position seems to be that discharge is not allowed in port waters.
  • Latvia: General position is that discharge is not allowed in territorial and port waters.
  • Dublin, Ireland: An Irish authorities’ Notice stipulates that discharge of washwater is prohibited in waters under Dublin port jurisdiction.
  • Norway: The Norwegian Maritime Directorate (NMD) has proposed a ban on the use of scrubbers in the country’s heritage fjords, which extends to all types of scrubbers including closed loop and hybrid systems. Implementation is expected during first half of 2019.


  • Hawaii, USA: VGP rules allow for discharge of washwhater subject to certain requirements being fulfilled.
  • Connecticut, USA: There are specific conditions as part of the VGP requirements, prohibitiing discharge of exhaust gas scrubber washwater into Connecticut waters.
  • California, USA: CARB regulations do not permit the use of scrubbers, unless the vessel has an experimental or temporary research permit.

Gard adds that various other coastal states and ports are discussing enforcing bans citing the adverse effects of scrubber washwater on the environment. Where the discharge of washwater is not permitted, Gard advises that vessel operators should either use compliant fuel instead of open loop scrubbers; or switch over to closed loop mode of operation, in which case it will be necessary to convert currently installed open loop systems to closed loop o

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