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IBIA questions new claims about VLSFO and black carbon emissions

Understanding factors behind BC is a complex science as BC formation depends on multiple and variable factors and how they interact i.e. engine type, engine load etc.

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Unni Einemo of the International Bunker Industry Association (IBIA) on Wednesday (15 July) published an article explaining why comprehending factors behind black carbon emissions from VLSFO is a complex science that even experts struggle to grasp completely, and thus the shipping industry should have solid data backing their claims before drawing conclusions about its environmental impact: 

Fuel oil blends produced to meet the IMO 2020 sulphur limit, referred to as very low sulphur fuel oil (VLSFO), have had a lot of bad press. Most of it has been based on alarmist predictions about the quality and other characteristics of these fuels, which have later proven to be unjustified or only partially accurate.

Earlier this year, IBIA addressed claims that the shift from high sulphur fuel oil (HSFO) with up to 3.50% sulphur to VLSO blends meeting the new 0.50% sulphur limit for marine fuels would increase black carbon (BC) emissions. The claims, which proliferated in the press and on social media, were based on a study submitted to the IMO indicating that the new VLSFO blends could potentially be highly aromatic, and therefore increase black carbon (BC) emissions.

IBIA and others explained to an IMO meeting (PPR 7) in February 2020 that the fuel specimens used in the BC measurement study were not representative of most VLSFOs that were actually in the market. IBIA made a statement at PPR 7, and interventions by ISO and IMarEST are on record in an annex to the IMO’s report from PPR 7. VLSFOs delivered to ships have so far generally been more paraffinic and less aromatic than the HSFOs they have replaced.

Now, a new theory has been circulated in the press based on an article published on LinkedIn by Francisco Malta of VM Industrials, a distributor for additive maker Aderco. The article, originally* published with the headline “Why new VLSFO 0.5% Sulphur fuels emit higher Black Carbon Emissions” claimed that it isn’t a high aromatics content, but rather paraffinic hydrocarbons in VLSFO that are to blame for BC emissions.

IBIA finds claims made in the article questionable. Without getting into too much detail, let’s explain some of the issues.

First of all, the article gave the impression that the introduction of VLSFO has led to an increase in black carbon (BC) emissions.* However, the article did not present or reference any independently validated data from actual measurements of actual VLSFOs in use so far to support this observation.

It is important to note that the discussion at IMO in February was about a theoretical increase in BC emissions based on the BC measurement study, not an actual observed increase since ships began to use VLSFOs. The BC measurement study, which had been submitted to the IMO in November 2019, showed that an increase in aromatic content was associated with increased BC emissions. This was well understood by industry, which welcomed the study as an important contribution to build better knowledge about factors contributing to BC emissions. It was the assumption that VLSFOs would be more aromatic than the HSFOs they were replacing that was disputed.

Understanding all the factors behind black carbon emissions is a complex science and many people struggle to get a good understanding of it, including experts on chemistry and combustion processes. Formation of BC depends on multiple and variable factors and how they interact, including the engine type, engine load, engine condition, the makeup of the fuel and the pre-conditioning of the fuel prior to injection.

While the article claimed that it was an increased level of paraffinic hydrocarbons in VLSFO that were causing an increase in BC emissions, we should not forget that a large portion of marine distillates are mainly paraffinic in nature. Yet there have not been any reports of an increase in BC emissions in emission control areas (ECAs), where most ships have been using marine gasoil to meet the 0.10% sulphur limit since 2015. We do note, however, that even clear and bright distillates can cause very visible black smoke when the engine is not in an optimum condition/and or setting.

The article stated that the asphaltenes in HFO 3.5% S “drop from suspension and end up as sludge in tanks” hence “they rarely ever make their way to combustion” whereas in the new VLSFO scenario, they “do make their way to the combustion chamber.” This isn’t what we have seen in practice. Conventional high sulphur fuel oils (HSFOs) are typically less prone to forming asphaltenic sludge prior to combustion than we have seen with VLSFOs so far. HSFO is typically more aromatic than VLSFO, and this helps keep the asphaltenes in suspension and stable. Hence, there would be more asphaltenes reaching the combustion chamber when using HSFO than VLSFOs. Also, VLSFOs typically contain less asphaltenes than HSFOs so it seems counterintuitive to suggest that more asphaltenes reach the combustion chamber when using VLSFO compared to HSFO.

Simply put, black carbon, or soot, is a result of incomplete combustion. From what we have heard, fuels with higher paraffinic content are associated with improved combustion compared to highly aromatic fuels. So far, we have not heard about VLSFOs being particularly prone to poor and/or incomplete combustion compared to HSFOs (which are typically more aromatic). Hence the claims in the article appear to run counter to real world experience.

We learnt from the discussions about VLSFO and BC emissions prior to the IMO meeting in February that misunderstandings can take hold when theories are taken as evidence of fact, when the reality may be quite different.

IBIA believes it is important to have proper data and empirical evidence to back up theories. When pointing to a certain fuel characteristic as the cause of an increase in BC emissions, it needs to be backed by independently validated data and specifics on the measurement methodology used to define black carbon.

VLSFO is currently the most widely adopted solution to meeting the 0.50% sulphur limit and for the most part it has performed better than predicted in the run-up to IMO 2020. As such, VLSFO blends have confounded much of the bad press. As VLSFOs are still quite new, we are still learning. We should, however, ensure that any conclusions drawn about the performance and environmental impact of VLSFOs are based on solid evidence.

Unni Einemo
[email protected]

*Following communications with IBIA, the author of the article has edited the LinkedIn post to insert “may” in the headline so it reads “Why new VLSFO 0.5% Sulphur fuels may emit higher Black Carbon Emissions”, and has moderated some of the language that suggested that VLSFOs have caused an increase in black carbon emissions.

Related: Aderco: Why new VLSFO 0.5% Sulphur fuels may emit higher Black Carbon Emissions


Source:
IBIA
Published: 16 July, 2020

 

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Legal

Singapore police arrest eight over alleged illegal MGO transaction off Tuas

SPF says preliminary investigations found that crew members of a Singapore-registered tugboat misappropriated MGO worth about SGD 10,570 without their company’s knowledge and sold it illegally.

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Singapore police arrest eight over alleged illegal MGO transaction off Tuas

The Singapore Police Force (SPF) on Thursday (13 August) said it has arrested eight men, aged between 25 and 54, for their suspected involvement in an illegal transaction of Marine Gas Oil (MGO).

On 13 August 2026 at about 1.05am, officers from the Police Coast Guard (PCG) conducted a check on a Singapore-registered tugboat in the waters off Tuas and discovered that eight crew members were possibly involved in the illegal transaction of MGO. 

“Preliminary investigations revealed that the crew members of the tugboats misappropriated MGO valued at about SGD 10,570 (USD 8,258), without their company’s knowledge,” SPF said in a statement.

“The MGO was sold illegally for their personal financial gain.”

The eight crew members will be charged in court on 14 August 2026 with the offence of theft by servant of property in possession of master under Section 381 of the Penal Code 1871 If convicted, they shall be punished with an imprisonment term that may extend to seven years and shall also be liable to fine.

“The Police take a serious view of illegal transaction of MGO in Singapore Territorial Waters and will continue to conduct enforcement and security checks to prevent, deter and detect such illicit activities in Singapore waters,” SPF added. 

 

Photo credit: Singapore Police Force
Published: 14 August, 2026

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Port & Regulatory

Gard: Sulphur-related bunker claims rise amid tighter China MSA enforcement

Claims involving excessive sulphur content in marine fuels have been rising, while stricter inspections by the China MSA have heightened the focus on sulphur compliance, particularly in the Bohai Sea.

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shraga kopstein on Unsplash

Maritime protection and indemnity (P&I) club Gard on Wednesday (12 August) highlighted that claims involving excessive sulphur content in marine fuels have been rising, while stricter inspections by the China MSA have heightened the focus on sulphur compliance, particularly in the Bohai Sea:

Rise in off-spec sulphur claims

Recent claims experience indicates that bunker quality continues to pose a significant operational risk for shipowners. In our earlier review of bunker-related claims during the first five months of 2026, we highlighted a rise in off-specification bunker incidents amid increased pressure on global fuel supply chains following the escalation of the conflict in the Middle East. 

Specifically for Sulphur compliance, between January and June 2026, the number of sulphur-related cases increased by more than threefold compared with the same period in 2025. Notably, the number of cases recorded in the first six months of this year has already exceeded the total number reported during the whole of last year by approximately 40%. 

While each case is fact-specific, the increase is notable because excessive sulphur content constitutes a MARPOL compliance issue. Unlike many other bunker quality problems, sulphur non-compliance identified through port state inspections can result in vessel delays, enforcement action, and substantial costs associated with debunkering and fuel disposal. 

The map below illustrates the geographical distribution of sulphur-related claims recorded during the first six months of 2026, based on the location where the bunkers were stemmed.

Distribution of sulphur related claims

China MSA steps up sulphur compliance enforcement

According to our correspondent, Huatai, on 5 June 2026, the maritime authorities of Tianjin, Hebei, Liaoning and Shandong jointly launched a special campaign on ship pollution prevention and control in the Bohai Sea region. The campaign involves coordinated supervision by local MSA branches across the region and is expected to last nearly five months. It covers major ports and surrounding port areas in the Bohai Sea region, including Tianjin, Tangshan, Qinhuangdao, Huanghua, Jinzhou, Yingkou and Longkou. 

While the initiative is broader than bunker sulphur compliance alone, its scope includes inspections relating to air pollution prevention, SOx emissions, fuel compliance and other high-pollution-risk operations. Enforcement measures are expected to comprise onboard inspections, cross-regional enforcement activities, unannounced spot checks and remote monitoring. These efforts will be supported by a combination of UAV patrols, maritime patrol vessels, shore-based monitoring systems and rapid on-site fuel testing. 

As a result, vessels trading in the Bohai Sea region may experience increased scrutiny of fuel compliance documentation, fuel sampling records, onboard fuel management procedures, and the handling or disposal of suspected non-compliant fuel.

Documents typically requested by China MSA

Based on our recent experience, including the case discussed above, and subject to the specific requirements of the local MSA office, owners and operators may be requested to provide supporting documentation such as: 

  • Bunker documentation – Bunker Delivery Notes (BDNs), MARPOL fuel sample records, fuel test reports, and relevant fuel quality certificates. 
  • Statutory certificates – including the International Air Pollution Prevention (IAPP) Certificate and International Oil Pollution Prevention (IOPP) Certificate. 
  • Operational records – engine logbooks, deck and navigation logbooks, Oil Record Book entries, and records relating to fuel transfers, storage and consumption. 
  • Sampling documentation – the Master’s statement and any records demonstrating how fuel samples were drawn, sealed, labelled, handled and retained. 
  • Correspondence records – communications with the authorities, bunker suppliers, charterers and other relevant stakeholders. 
  • Fuel disposal records – approved disposal plans, debunkering documentation, receipts and evidence of final disposal, where applicable. 

The exact documentation required will depend on the nature of the investigation, the findings of the inspection, and the requirements of the local enforcement authority. 

Possible regulatory consequences in China

Under the Air Pollution Prevention and Control Law of the People’s Republic of China, ocean-going vessels are required to use fuel oil meeting atmospheric pollutant control requirements after berthing. Vessels operating within designated emission control areas must also comply with applicable emission standards. Article 106 provides that where vessel fuel oil fails to meet applicable standards or requirements, the competent maritime authorities may impose fines ranging from RMB 10,000 to RMB 100,000. Liability may extend to shipowners, ship operators and ship managers depending upon the circumstances of the case. 

Recommendation

Sulphur compliance should be treated as both a fuel quality and regulatory risk. Owners and operators are encouraged to take preventive steps before bunkering, act promptly if non-compliant fuel is suspected, and preserve evidence carefully if an inspection or claim arises. Under amended 

Resolution A.1206(34), Appendix 18, 2.1.5, if the BDN shows compliant fuel, but the master has independent test results of the fuel oil sample taken by the ship during the bunkering which indicates non-compliance, the master may document this by notifying the ship’s flag Administration, with copies to: 

  • the competent authority of the relevant port of destination, 
  • the Administration under whose jurisdiction the bunker deliverer is located, 
  • and to the bunker deliverer.

 

Photo credit: shraga kopstein on Unsplash / Gard
Published: 14 August, 2026

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LNG Bunkering

Shell expands LNG bunkering footprint in Spain with Valencia

As one of the region’s key maritime hubs, the company said Valencia expands the options available to shipowners seeking LNG supply along major shipping routes.

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Shell expands LNG bunkering footprint in Spain with Valencia

British oil giant Shell on Thursday (13 August) said Valencia has joined its growing network of bunkering locations, making LNG available as a marine fuel.

The successful completion of the first LNG bunkering operation in Valencia marked an important milestone for Spain and further strengthened Shell’s LNG supply capabilities across the Mediterranean. 

In a video shared by the company, bunkering vessel Alice Consulich was shown supplying an undisclosed volume of LNG to the container ship MSC Sabrina.

“As one of the region’s key maritime hubs, Valencia expands the options available to shipowners seeking LNG supply along major shipping routes,” Shell said in a social media post. 

Shell said the achievement reflected the strong collaboration across the maritime value chain, including MSC Mediterranean Shipping Company, the Port of Valencia and Fratelli Cosulich Group.

“We look forward to making more LNG bunker deliveries in Valencia and across the Mediterranean as LNG infrastructure and capabilities continue to expand,” the company said. 

 

Photo credit: Shell
Published: 14 August, 2026

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