Business

IBIA: IMO sub-committee fails to improve clarity of 0.50% sulphur limit enforcement

Debunkering should only be required when it has been established, beyond reasonable doubt, that a ship is carrying fuel oil that exceeds the 0.50% sulphur limit.

Published

5 years ago

July 21, 2021

Admin

The International Bunker Industry Association on Monday (19 July) issued a statement encouraging clarity of the 0.50% sulphur limit enforcement:.

The seventh session of the IMO’s Sub-Committee on Implementation of IMO Instruments (III 7) has brought no further clarity regarding on what basis authorities can determine that a ship’s fuel is non-compliant with MARPOL Annex VI sulphur limits.

IBIA had put in a paper, III 7/5/8, co-sponsored by Jamaica to III 7, seeking primarily to protect ships from unreasonable debunkering demands by relevant authorities, as there is presently room for doubt about on which grounds that may happen. (Click here to see the document).

Our submission urged member states to implement the amended sulphur verification procedures in appendix VI of MARPOL Annex VI, adopted by MEPC 75, to ensure consistent implementation of the 0.50% sulphur limit which has been in force since the start of 2020.

Appendix VI of the adopted amendment, “Verification procedures for a MARPOL Annex VI fuel oil sample” states that “The following relevant verification procedure shall be used to determine whether the fuel oil delivered to, in use or carried for use on board a ship has met the applicable sulphur limit of regulation 14 of this Annex.”

Appendix VI goes on to provide two distinctly different procedures: Part 1 for the MARPOL delivered sample which it says “shall be used to verify the sulphur content of the fuel oil delivered to a ship” and Part 2 for in-use and onboard samples which it says “shall be used to verify the sulphur content of the fuel oil as represented by that sample of fuel oil at the point of sampling.”

Part 2 of the verification procedure for in-use and onboard sample takes into account the inherent uncertainty of the sulphur test method by recognising samples as having met the regulatory requirement as long as the test result does not exceed the limit +0.59R – also known as the 95% confidence interval.

If those procedures were always followed, we would have clarity. However, there have been cases where ships have been required to debunker after reporting to authorities that they have received a test result from their own fuel oil testing programme against ISO 8217 parameters, on the ship’s own sample, indicating a sulphur content marginally above 0.50%.

There have also been reports of authorities obtaining and testing in-use samples from ships and treating it as a non-compliant on the basis of a single test result above 0.50% sulphur, but within the 95% confidence interval, for example 0.51% or 0.52% sulphur.

For these reasons, our submission asked for assurance that port State control (PSC) authorities, if seeking to verify compliance with the 0.50% sulphur limit and the associated carriage ban, would follow the sulphur verification procedure in appendix VI adopted by MEPC 75.

Debunkering should only be required when it has been established, beyond reasonable doubt, that a ship is carrying fuel oil that exceeds the 0.50% sulphur limit. This is why we also sought recognition that the 95% confidence principle should apply to fuel oil used and carried for use if, for any reason, an authority seeks to assess the ship’s compliance on the basis of a MARPOL delivered sample only, without obtaining an in-use or onboard sample to verify the ship’s compliance. This would provide the ship with the benefit of doubt against what remains a fairly arbitrary outcome, because a fuel which does in fact meet the limit may test marginally above that limit (as per 0.59R or 95% confidence limits).

However, we stressed that if the MARPOL delivered sample is above 0.50% sulphur, the fuel oil supplier would still be considered as not having met the requirement for the fuel as delivered, and could face enforcement action. The supplier does not get this “benefit of doubt” and therefore needs to use the limit minus 0.59R as the blend target to be 95% certain that a single laboratory won’t return an analysis result that is fractionally above the limit. For a 0.50% sulphur limit, this means the suppliers blend target must be 0.47% sulphur or less.

Parties to MARPOL Annex VI have an obligation to “take action as appropriate against fuel oil suppliers that have been found to deliver fuel oil that does not comply with that stated on the bunker delivery note”.

When the document was discussed at III 7, some delegations were of the opinion that asking for the outcome of testing a MARPOL delivered sample – in the case of the ship only – to be viewed in the same way as if an in-use or onboard sample had been tested, would interfere with the decisions made by MEPC on this issue and would lead to the use of fuels with 0.53% sulphur.

When IBIA pressed for clarity on the legal question as to what basis PSC might take enforcement action against the ship, the view was that the issues we raised in document III 7/5/8 concerning discrepancies in the enforcement of the 0.50% sulphur limit were not under the purview of the III Sub-Committee and should be referred to an appropriate IMO body.

We are disappointed that we could not get the legal certainty we were seeking, in particular regarding the basis for demanding debunkering of fuel that may, if tested again at a different laboratory, prove to be compliant given the inherent uncertainty of the test method.

Ideally, there should be legal certainty that PSC must verify the ship’s non-compliance on the basis of obtaining and testing and in-use or onboard sample. However, we do not have that certainty. While this uncertainty is not helpful for the industry, there are some positives. When speaking to member states about the issue prior to III 7, we found that many were supportive of the principle that debunkering should only be required when it has been established, beyond reasonable doubt, that a ship is carrying fuel oil that exceeds the 0.50% sulphur limit. Moreover, while some ships have faced debunkering demands that seem poorly justified, it does not appear to be widespread. Nevertheless, even a few such cases have caused considerable anxiety in the market.

On a final note, best practice for the bunker producer/supplier is to ensure that the product meets the specification limit with 95% confidence by using the limit minus 0.59R as the blend target, rather than the limit value. This should minimise the number of cases where a ship’s own initial test result indicates potential non-compliance with the mandatory sulphur limits, and the subsequent concerns about what kind of enforcement actions the ship may face.

Photo credit and source: International Bunker Industry Association
Published: 21 July, 2021

Winding up

Singapore: Liquidators of East Marine Pte Ltd issues notice of annual meeting

Annual meeting of the company and its creditors will be held at 8 Wilkie Road, #03-08 Wilkie Edge, Singapore 228095 via audio-visual conference on 20 August at 11am.

Published

23 hours ago

August 12, 2026

Admin

A notice of annual meeting was issued by liquidators of East Marine Pte Ltd, which is in creditor’s voluntary liquidation, on the Government Gazette on Friday (7 August).

According to the notice, the annual meeting of the company and its creditors will be held at 8 Wilkie Road, #03-08 Wilkie Edge, Singapore 228095 via audio-visual conference on 20 August at 11am.

The purpose of the meeting is to have an account laid before the meeting showing the acts and dealings of the liquidators and the conduct of the winding up in the preceding year.

The following are the details of the liquidators:

Ng Kian Kiat
Yap Hui Li
Liquidators
c/o 8 Wilkie Road
#03-08 Wilkie Edge
Singapore 228095

Photo credit: steve pb from Pixabay
Published: 12 August, 2026

Winding up

Singapore: Annual and final meetings to be held for Asia-Pacific Shipyard Pte Ltd

Annual meeting and the final meeting of the company and its creditors will be held at 8 Wilkie Road, #03-08 Wilkie Edge, Singapore 228095 via audio-visual conference on 9 September.

Published

23 hours ago

August 12, 2026

Admin

A notice of annual meeting and final meeting was issued by liquidators of Asia-Pacific Shipyard Pte Ltd, which is in creditor’s voluntary liquidation, on the Government Gazette on Friday (7 August).

According to the notice, the annual meeting and the final meeting of the company and its creditors will be held at 8 Wilkie Road, #03-08 Wilkie Edge, Singapore 228095 via audio-visual conference on 9 September.

The annual meeting will be held at 2pm while the final meeting will be held at 3pm.

The purpose of the meeting is to have an account laid before the meeting showing the acts and dealings of the liquidators and the conduct of the winding up in the preceding year and the manner in which the winding up has been conducted and the property of the company has been disposed of and hearing any explanation that may be given by the liquidators.

The following are the details of the liquidators:

Ng Kian Kiat
Yap Hui Li
Liquidators
c/o 8 Wilkie Road
#03-08 Wilkie Edge
Singapore 228095

Photo credit: Drew Beamer
Published: 12 August, 2026

Bunker Fuel

JLC China Bunker Fuel Market Monthly Report (July 2026)

China’s bonded bunker fuel sales dropped in July, as typhoons hindered port operation in East and South China and bonded bunker fuel supply tightened in northern ports.

Published

23 hours ago

August 12, 2026

Admin

JLC China Bunker Fuel Market Monthly Report (July 2026)

Beijing-based commodity market information provider JLC Network Technology Co. recently shared its JLC China Bunker monthly report for July 2026 with Manifold Times through an exclusive arrangement:

China’s bonded bunker fuel sales drop in July

China’s bonded bunker fuel sales dropped in July, as typhoons hindered port operation in East and South China and bonded bunker fuel supply tightened in northern ports. Meanwhile, some shipowners became more cautious about bunkering when geopolitical tensions persisted.

China sold about 1.78 million mt of bonded bunker fuel in the month, with the daily sales at 57,503 mt, down by 10.12% month on month, JLC’s data shows.

Regarding the sales by supplier, the sales by Chimbusco, Sinopec (Zhoushan), SinoBunker, and China Changjiang Bunker (Sinopec) respectively settled at 380,000 mt, 600,000 mt, 60,000 mt, and 10,000 mt in the month, while those by suppliers with regional bunkering licenses settled at 732,600 mt.

China’s LSFO output retreats in July

China’s low-sulfur fuel oil (LSFO) output retreated in July , as refineries lacked production enthusiasm when their margins weakened.

Chinese refiners produced about 1.29 million mt of LSFO in the month, with the daily output at 41,613 mt, down by 4.48% month on month, JLC’s data shows.

Specifically, Sinopec witnessed an obvious decline in its output. ZhongKe (Guangdong) Refinery & Petrochemical lowered its output amid unit maintenance. Qingdao Petrochemical also cut its output, but it was still high. By contrast, Shengli Petrochemical boosted its production.

Meanwhile, CNOOC’s LSFO output slid in July , with T aizhou Petrochemical suspending production.

Zhoushan Petrochemical and Huizhou Refinery maintained stable production, while Zhongjie Petrochemical did not produce any LSFO in the month.

On the other hand, PetroChina recorded an increase in its LSFO output, with Dalian WEPEC, Jinzhou Petrochemical, Jinxi Petrochemical, Huabei (North China) Petrochemical, and Dagang Petrochemical raising output.

ZPC and Sinochem did not produce any LSFO in the month, but the latter produced and exported 10,000 mt of MGO.

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Domestic-trade bunker fuel demand shrinks in July

Domestic-trade heavy bunker fuel demand shrank in July when inland and coastal shipping was seasonally weak.

The demand settled at 300,000 mt in July, with the daily demand at 9,677 mt, slipping by 6.35% month on month, JLC’s data shows.

Shipowners just made deals for rigid demand, with a strong wait-and-see attitude and no intention of stockpiling.

Meanwhile, domestic-trade light bunker fuel demand settled at 140,000 mt in the month, with the daily volume at 4,516 mt, down by 9.68% month on month, the data shows. The decline was mainly due to the bad impact of continuous typhoons.

Bunker Fuel Supply

China’s bonded bunker fuel imports rebound in June

China’s bonded bunker fuel imports rebounded in June, after hitting a 16-month low in the previous month.

The country imported 515,300 mt of bonded bunker fuel in the month, soaring by 86.77% month on month, calculations show, based on data from the General Administration of Customs of PRC (GACC).

Bonded bunker suppliers boosted their purchases of imported high-sulfur fuel oil (HSFO) as premiums retreated amid easing conflicts between the U.S. and Iran. Meanwhile, downstream HSFO bunkering demand was relatively good, which also aroused suppliers’ import interest.

The arrivals of imported marine gas oil (MGO) also increased in June.

However, these bunker suppliers did not import any LSFO in the month, given sufficient domestic supply.

On a year-on-year comparison, China’s bonded bunker fuel imports declined by 5.50% in June.

Regarding the imports by source, Russia was still the largest supplier with 305,300 mt, accounting for 59.24% of China’s total imports. South Korea climbed to the second place with 120,700 mt, accounting for 23.43%, while Malaysia slipped to the third place with 89,300 mt, accounting for 17.33%.

China’s bonded bunker fuel imports totaled 3.38 million mt in the first half of this year, an increase of 5.54% from the same period of time in 2025, calculations also indicate.

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Domestic-trade bunker fuel supply tightens further in July

Chinese blenders supplied 270,000 mt of domestic-trade heavy bunker fuel in July , with the daily supply at 8,710 mt, a decline of 9.90% month on month, JLC’s data shows.

Low-sulfur residual oil supply continued to tighten despite restarts of some refineries, which forced blenders to cut their bunker fuel production. Meanwhile, supply of consumption-tax-included bunker fuel decreased with tax inspections becoming regular.

In the meantime, domestic-trade MGO supply settled at 170,000 mt, with the daily supply at 5,484 mt, down by 8.60% from a month earlier, the data shows.

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Bunker Prices, Profits

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JLC Network Technology Co., Ltd is recognised as the leading information provider in China. We specialise in providing the transparent, high-value, authoritative market intelligence and professional analysis in commodity market. Our expertise covers oil, gas, coal, chemical, plastic, rubber, fertilizer and metal industry, etc.

JLC China Bunker Fuel Market Monthly Report is published by JLC Network Technology Co., Ltd every month on China bunker market, demand, supply, margin, freight index, forecast and so on. The report provides full-scale & concise insight into China bunker oil market.

Note: China-based commodity market information provider JLC Technology has been providing Singapore bunkering publication Manifold Times China bunker volume data since 2020. Data from earlier periods are available here.

Photo credit: JLC Network Technology
Published: 12 August, 2026