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Thursday, January 10, 2019 

The International Maritime Organization has reminded ship operators about a number of changes - to bunker delivery note requirements, North Sea and Baltic ECAs and fuel consumption data collection - that entered into force on 1 January 2019.

The amendment to the bunker delivery note relating to the supply of marine fuel oil to ships which have fitted alternative mechanisms to address sulphur emission requirements enters into force as the shipping industry counts down to 1 January 2020, when the limit for sulphur in fuel oil will be reduced to 0.50% m/m outside emission control areas (ECAs), from 3.5% currently. In ECAs, the limit will remain at 0.10% m/m.

The amendments to Appendix V of MARPOL Annex VI are intended to address situations where the fuel oil supplied does not meet low sulphur requirements, but has been supplied to a ship which is using an alternative compliance method permitted under regulation 4 of MARPOL Annex VI (“Equivalents”) to reduce the sulphur oxide emissions of the ship in order to comply with MARPOL requirements. An equivalent means may be abatement technology such as an exhaust gas cleaning system (scrubber), if accepted by the flag State of a ship as an alternative means to meet the sulphur limit requirement.

Also on 1 January 2019, amendments to MARPOL Annex VI to designate the North Sea and the Baltic Sea as emission control areas (ECAs) for nitrogen oxides (NOx) entered into force. Both ECAs will take effect on 1 January 2021, and will result in considerably lower emissions of NOx from international shipping in those sea areas. In NOx emission control areas, ships are subject to so-called 'Tier III' controls to limit NOx emissions.

And from 1 January 2019, ships of 5,000gt and above need to start collecting data on their fuel-oil consumption, under the mandatory data collection reporting requirements which entered into force in March 2018. The MARPOL Annex VI regulation on Collection and reporting of ship fuel oil consumption data requires ships of 5,000 gross tonnage and above to collect consumption data for each type of fuel oil they use, as well as other, additional, specified data including proxies for transport work. 

The aggregated data is reported to the flag State for each calendar year and the flag State, having determined that the data has been reported in accordance with the requirements, issues a Statement of Compliance to the ship.  Flag States are required to subsequently transfer this data to an IMO Ship Fuel Oil Consumption Database. IMO is required to produce an annual report to the MEPC, summarising the data collected.

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