IMO 2020

MEPC 74: IMO issues additional guidance on 2020 implementation

Meeting has approved various guidance and guidelines to support the implementation of IMO 2020.

Published

7 years ago

May 22, 2019

Admin

The International Maritime Organization on Monday (20 May) issued an industry update on IMO 2020 after the 74th session of the Marine Environment Protection Committee (MEPC 74) meeting ended on Friday:

The International Maritime Organization (IMO) has approved and adopted a comprehensive set of guidance and guidelines to support the consistent implementation of the lower 0.50% limit on sulphur in ships’ fuel oil, which will enter into effect from 1 January 2020. Related draft MARPOL amendments were also approved.

The 2020 rule will bring in considerable benefits for the environment and human health. The stricter limit will be applicable globally under IMO’s MARPOL treaty. (In designated emission control areas (ECAs), the sulphur limit will remain at 0.10%.).

The 1 January 2020 implementation date was adopted in 2008 and confirmed in 2016. IMO has been working with Member States and the industry to support implementation of the new limit, including the preparation of amendments to MARPOL Annex VI and development of guidance and guidelines.

Enforcement, compliance with and monitoring of the 2020 sulphur limit is the remit and responsibility of States Party to MARPOL Annex VI. Most ships are expected to utilize new blends of fuel oil which will be produced to meet the 0.50% limit on sulphur in fuel oil or compliant marine gas/diesel oil.

Guidance on 2020 sulphur limit

The IMO Marine Environment Protection Committee (MEPC), meeting for its 74th session (13-17 May):

Adopted 2019 Guidelines for consistent implementation of the 0.50% sulphur limit under MARPOL Annex VI – with sections on the impact on fuel and machinery systems resulting from new fuel blends or fuel types; verification issues and control mechanism and actions, including port State control and samples of fuel oil used on board; a standard reporting format for fuel oil non-availability (fuel oil non-availability report (FONAR); and possible safety implications relating to fuel oils meeting the 0.50% sulphur limit.

The 2019 Guidelines on consistent implementation of 0.50% sulphur limit under MARPOL Annex VI adopted by resolution MEPC.320(74) are available here.

Adopted 2019 Guidelines for port State control under MARPOL Annex VI Chapter 3, providing updated enforcement guidance for provisions including regulation 13 “nitrogen oxides” and regulation 14 “sulphur oxides and particulate matter”.
Approved Guidance on indication of ongoing compliance in the case of the failure of a single monitoring instrument, and recommended actions to take if the exhaust gas cleaning system (EGCS) fails to meet the provision of the Guidelines.
Approved Guidance for port State control on contingency measures for addressing non-compliant fuel oil. The guidance covers possible actions to be taken, following discussions between ship, flag State and port State, when a ship is found to have on board non-compliant fuel oil either as a consequence of compliant fuel oil being not available when the ship bunkered fuel oil or the ship identifying through post bunkering testing that the fuel oil on board is non-compliant.
Approved the 2019 Guidelines for on board sampling for the verification of the sulphur content of the fuel oil used on board ships.
Approved an MSC-MEPC circular on Delivery of compliant fuel oil by suppliers, subject to approval by the Maritime Safety Committee (MSC 101) in June. The draft circular says that Members States should urge fuel oil suppliers to take into account, as relevant: MEPC.1/Circ.875 Guidance on best practice for fuel oil purchasers/users for assuring the quality of fuel oil used on board ships; and MEPC.1/Circ.875/Add.1 Guidance on best practice for fuel oil suppliers for assuring the quality of fuel oil delivered to ships.
Approved Guidance for best practice for Member State/coastal States. This includes best practices intended to assist Member States in carrying out their responsibilities under MARPOL Annex VI, to ensure effective implementation and enforcement of statutory requirements of that Annex. The guidance says that Member States/coastal States should consider actions deemed appropriate, under domestic legal arrangements, with respect to promoting the availability of compliant fuel oils, consistent with regulation 18.1 of MARPOL Annex VI; and Member States or other relevant authorities desiring to do so may decide to establish or promote a licensing scheme for bunker suppliers.

The MEPC 73 in October 2018 had already approved Guidance on the development of a ship implementation plan for the consistent implementation of the 0.50% sulphur limit under MARPOL Annex VI (MEPC.1/Circ. 878).

The 2019 Guidelines on consistent implementation of 0.50% sulphur limit under MARPOL Annex VI adopted by resolution MEPC.320(74) are available here. These comprehensive guidelines include a template for a "Fuel Oil Non-Availability Report (FONAR)" set out in Appendix 1 and a "Technical review of identified possible potential safety implications associated with the use of 2020 compliant fuels" set out in appendix 2.

Carriage ban

A related MARPOL Annex VI amendment to prohibit the carriage of non-compliant fuel oil used by ships, which was adopted last year, is expected to enter into force on 1 March 2020.

Related MARPOL Annex VI amendments approved for future adoption

To support consistent implementation of regulation 14 of MARPOL Annex VI, MEPC approved draft amendments to MARPOL Annex VI to regulations 1, 2, 14 and 18, appendix I and appendix VI of MARPOL Annex VI, with a view to adoption at MEPC 75, with an expected entry force date of September 2021.

The MEPC also approved a circular to encourage early application of the approved amendments to the verification procedures for a MARPOL Annex VI fuel oil sample.

The draft amendments cover:

Draft amendments to Regulation 2 Definitions, to include new definitions for “Sulphur content of fuel oil” – meaning the concentration of sulphur in any fuel oil, measured in % m/m as tested in accordance with standard acceptable to the Organization; “Low-flashpoint fuel”, to mean gaseous or liquid fuel having a flashpoint lower than otherwise permitted under paragraph 2.1.1 of SOLAS regulation II-2/4; “MARPOL delivered sample”, to mean the sample of fuel oil delivered in accordance with regulation 18.8.1 of MARPOL Annex VI; “In-use sample”, to mean the sample of fuel oil in use on a ship; and “On board sample”, to mean the sample of fuel oil intended to be used or carried for use on board that ship.
Fuel oil sampling and testing – Draft amendments to Regulation 14 Sulphur oxides (SOX) and particulate matter, to add new paragraphs related to in-use and on board fuel oil sampling and testing, to add new paragraphs to require one or more sampling points to be fitted or designated for the purpose of taking representative samples of the fuel oil being used or carried for use on board the ship. The representative samples of the fuel oil being used on board are to be taken in order to verify the fuel oil complies with the regulation.
Appendix I amendments to the International Air Pollution Prevention (IAPP) certificate – Draft consequential amendments to update the IAPP certificate to add a reference to sampling points and also to note where there is an exemption to the provision for low-flashpoint fuel.
Appendix VI Fuel verification procedure for MARPOL Annex VI fuel oil sample Draft consequential amendments to verification procedures, to cover verification of the representative samples of in-use fuel oil and on board fuel oil.

Reporting on fuel oil quality and availability

The MEPC discussed how to enhance the reporting of data, as required by MARPOL Annex VI regulation 18 on fuel oil quality and availability.

The MEPC approved a draft MEPC circular on reporting of data related to fuel oil availability and safety in GISIS to promote greater understanding of the 0.50 % m/m sulphur limit under MARPOL Annex VI.

The MEPC instructed the IMO Secretariat to review the current MARPOL Annex VI module in IMO's global shipping information system GISIS (including: Regulation 18.1: fuel oil availability; Regulation 18.2.5: evidence of non-availability of compliant fuel oil; Regulation 18.9.6: failure of fuel oil suppliers to meet the requirements specified in regulation 14 or 18 of Annex VI.

The MEPC instructed the Secretariat to update the existing tabs in GISIS for better functionality, including: updating the types of fuels and sulphur contents that are listed; allowing for multiple ports to be entered in a single entry; allowing searching by port or compliant fuel (adding a port list could assist with this); aligning with the Fuel Oil Non-availability Reports (FONAR); adding check-boxes on fuel oil quality; and improving the selection of regulations.

The MEPC established a Correspondence Group, to be coordinated by the Secretariat, to report back to MEPC 75, to investigate the reporting of additional items on GISIS; and further usability improvements, if feasible and as appropriate.

The Secretariat was also instructed to report to MEPC 75 a preliminary overview of data on fuel oil quality and availability currently available in GISIS as well as an overview of the current use of GISIS with reference to obligations under regulation 14 and 18.

The Committee invited the Secretariat to advise MSC 101 on the progress made on the new GISIS module for fuel oil safety matters.

Exhaust gas cleaning systems (EGCS)

Some ships use exhaust gas cleaning systems (EGCS) (“scrubbers”), accepted by their flag States as an alternative equivalent means to meet the sulphur limit requirement.

The Sub-Committee on Pollution Prevention and Response (PPR) is undertaking a review of the 2015 Guidelines on Exhaust Gas Cleaning Systems (EGCS). The guidelines include, among other things, washwater discharge standards.

The MEPC approved a new output on "Evaluation and harmonization of rules and guidance on the discharge of liquid effluents from EGCS into waters, including conditions and areas", in the 2020-2021 biennial agenda of the PPR Sub-Committee and the provisional agenda for PPR 7 (meeting in February 2020), with a target completion year of 2021. PPR 7 is expected to further review the documents that were submitted to MEPC 74 in relation to the newly approved output, with a view to refining the title and scope of the output and will report the outcome of its consideration to MEPC.

The MEPC also instructed the Secretariat to liaise with the Joint Group of Experts on the Scientific Aspects of Marine Environmental Protection (GESAMP), an advisory body that advises the United Nations (UN) system on the scientific aspects of marine environmental protection.

The MEPC requested that, subject to sufficient external funding being provided by Member States and other stakeholders, a GESAMP task team be established to assess the available evidence relating to the environmental impact of discharges of exhaust gas cleaning system effluent, with a view to reporting its findings to PPR 7.

IMO sulphur monitoring programme

The MEPC note information provided by the Secretariat on the outcome of the monitoring of the worldwide average sulphur content of marine fuel oils supplied for use on board ships for 2018, based on three sampling and testing service providers. The worldwide average sulphur content (i.e. three-year rolling average) of residual fuel oil was 2.59% and for distillate fuel oil it was 0.08%.

The MEPC approved, in principle, draft amendments to the 2010 Guidelines, as amended for monitoring the worldwide average sulphur content of fuel oils supplied for use on board ships. The draft amendments update the IMO sulphur monitoring programme to take into account the entry into effect of the 0.50% sulphur limit from 1 January 2020 and the potential types of fuel oils which will be used to comply with this limit and will be required.

Roundtable meeting and 2020 seminar

The IMO Secretariat plans to hold a further roundtable meeting with representatives from across stakeholders in June 2019 to review progress and share information.

Additionally, to provide an opportunity for wider stakeholder engagement, IMO plans to hold an “IMO2020” seminar at IMO in autumn, as by then there should be a clearer understanding of the availability of compliant fuel oil and some experience of implementation that can be shared. Further details for this seminar will be issued in due course.

A series of earlier MEPC 74 coverage by Manifold Times, focusing on developments, have been organised below:

Photo credit: International Maritime Organization
Published: 22 May, 2019

Ammonia

AM Green plans to build green ammonia plant at Indian port

Initiative also includes development of green ammonia handling, storage and bunkering infrastructure, pilot bunkering operations, safety procedures and training programmes, says VOC Port Authority.

Published

1 day ago

June 3, 2026

Admin

VO Chidambaranar (VOC) Port Authority on Friday (29 May) said it has signed a Memorandum of Understanding (MoU) with India’s ammonia producer AM Green Ammonia to collaborate in the development of a green ammonia production plant.

The plant will have a capacity of one million tonnes per annum (MTPA) at Tuticorin.

The initiative also includes development of green ammonia handling, storage and bunkering infrastructure, pilot bunkering operations, safety procedures and training programmes.

The project is expected to support the development of green fuel corridors connecting VOC Port with major ports in Europe and Asia, thereby strengthening India’s position in the global green fuels value chain.

VOC Port also signed a Memorandum of Understanding (MoU) with Bureau Veritas (India) Pvt. Ltd., to collaborate on Green Port certification, emissions accounting, ESG reporting, safety validation, development of green bunkering practices, and establishment of a Centre of Excellence for green fuels and sustainability.

The port also plans for an upcoming 750 m³ green methanol bunkering facility.

Photo credit: Naveed Ahmed on Unsplash
Published: 3 June, 2026

Port & Regulatory

Study: Major drop in ship sulphur emissions confirmed following IMO regulations

National Centre for Atmospheric Science study found that the average sulphur content in ship fuel dropped nearly tenfold in open ocean areas following IMO’s 2020 regulation.

Published

6 months ago

December 8, 2025

Admin

Recent global regulations have significantly reduced sulphur emissions from ships, helping to improve air quality in coastal regions – confirmed by a recent international study led by researchers at the National Centre for Atmospheric Science.

The research, published in Environmental Science: Atmospheres, used aircraft and ground-based instruments to measure sulphur dioxide and nitrogen oxides emitted by ships in the North-East Atlantic and European coastal waters between 2019 and 2023.

The team found that the average sulphur content in ship fuel dropped nearly tenfold in open ocean areas following the International Maritime Organization’s 2020 regulation, which capped sulphur content in marine fuel at 0.5%.

Before the change, many ships exceeded the previous 3.5% limit. After 2020, only a small number of ships were found to breach the new standard.

In European sulphur Emission Control Areas (SECAs), such as the English Channel and the Port of Tyne, sulphur levels were even lower – well below the stricter 0.1% limit. Interestingly, ports outside these zones, like Valencia in Spain, also showed low sulphur levels, likely due to EU rules requiring cleaner fuel when ships are docked for extended periods.

This is the first study to use aircraft-based measurements and predictions from the Ship Traffic Emission Assessment Model (STEAM3) to assess ship emissions outside of sulphur control zones since the 2020 regulation came into effect. The findings support the widely held view that ships now emit around seven times less sulphur than before the rule change – an important step toward cleaner air and healthier coastal environments.

Note: The research, titled ‘SO2 and NOx emissions from ships in North-East Atlantic waters: in situ measurements and comparison with an emission model’ can be found here.

Photo credit: shraga kopstein on Unsplash
Published: 8 December, 2025

Interview

IBIA Annual Convention 2025: ‘Exciting times’ for post IMO 2020 bunker suppliers, states Equatorial

Choong Sheen Mao, Chief Operating Officer, Equatorial, describes to Manifold Times the pre/post IMO 2020 challenges and evolution of bunker suppliers.

Published

7 months ago

October 31, 2025

Admin

The International Bunkering Industry Association (IBIA) will be hosting its flagship Annual Convention in Hong Kong at the Hong Kong Convention Exhibition & Convention Centre between 18 to 20 November 2025, as part of Hong Kong Maritime Week.

Choong Sheen Mao, Chief Operating Officer, Equatorial Marine Fuel Management Services (Equatorial), speaks to bunkering publication Manifold Times about the challenges of a post IMO 2020 bunker supplier.

MT: How does Equatorial continue to offer customer assurance and maintenance of marine fuel quality to ISO8217 standards despite increasing complexity of bunker fuel blends?

We maintain our focus to provide compliant, quality and competitively priced products to our customers. There is no shortcut. We source our products from a wide range of cargo producers and suppliers. We continue to be strict and vigilant with our testing programme for our products before delivering them to our customers. Equatorial has deepened our engagement with the wider industry to have a better and up-to-date understanding of the existing and new marine fuels.

MT: Can you share the evolution of commercial marine fuel procurement, blending and trading strategies on the back of increasing fuel types (pre/post IMO 2020)?

Pre IMO 2020, the main types of marine fuel procured and consumed by vessels were high-sulphur fuel oil, marine diesel oil and marine gas oil. Trading strategies were therefore closely linked to that within the oil industry.

However, many of the new fuel types are from other industries. For example, biofuels, methanol and ammonia are mainly products from the chemical and agriculture industries. There are marked differences between these industries and the energy industry (in particular, the marine fuels industry). LNG is from the gas industry which is distinct from the oil industry.

Without an existing liquid paper market for many of these commodities (especially as a marine fuel), the price risk management is less straightforward. Furthermore, commodity prices are no longer the sole consideration for price itself. The price of compliance must be considered. This could range from guaranteeing the origin of the marine fuel, its sulphur properties as well as its carbon intensity. The list goes on.

MT: Operational wise, what are the changing role and responsibilities of a bunker supplier to date, compared to before IMO 2020?

The role and responsibility of a bunker supplier have evolved. Fundamentally, it has been about providing quality marine fuels at competitive prices. Quantity assurance has been a critical concern which led to the mandatory implementation of the mass flow meter system for bunkering in the Port of Singapore. Interestingly, due to the nature of credit terms in the bunker industry, bunker suppliers also performed the role of “bankers” by extending favourable credit terms to shipowners and charterers.

These days, post IMO 2020, things have become even more complicated. Today, a bunker supplier retains the abovementioned roles and responsibilities, and much more – it has to ensure compliance with a plethora of rules and regulations. Compliance not only with sulphur cap requirements, but with international and regional sanctions and restrictions unrelated to the quality of the marine fuel itself. In fact, especially with alternative low- and zero-carbon marine fuels, this means compliance with standards, rules and regulations on sustainability such as the European Renewable Energy Directive and/or International Sustainability and Carbon Certification. There is also the need to comply with increasingly stringent safety regulations on both conventional and alternative marine fuels.

In addition to the above, a post IMO 2020 bunker supplier is still expected to supply compliant and quality fuel at competitive prices.

MT: Equatorial is Singapore’s largest local-born supplier; what is the next big thing for the company?

Equatorial continues to adapt and improve with the times, while maintaining its core values – Integrity, Teamwork, Commitment, Proficiency and Quality, and Safety and Environment. The bunker industry is a highly competitive one, and it is our intention to keep our competitive edge and remain relevant. This means that we have had to step out of our comfort zone and embrace the two mega trends of our time – digitalisation and decarbonisation.

We have been early adopters and developers of the electronic bunkering note as part of our own digital bunkering efforts. We have diversified our product offering to include low carbon marine fuels and are proud to be one of the pioneers for bunkering B100 biofuels earlier this year. This was made possible by the arrival of our IMO Type II chemical and oil bunker tankers. These same bunker tankers are also capable for carrying and delivering methanol. Equatorial has invested in an LNG bunkering vessel (LBV) newbuilding that is set to be delivered in Q3 2027. We are also involved in a study to develop low- or zero-carbon ammonia bunkering in Singapore.

These are exciting times.

Note: Choong Sheen Mao is amongst panellists featured in ‘Session Three: Bunker Sellers Panel’ at the IBIA Annual Convention 2025.

Join the Conversation

With over 300 delegates expected, the IBIA Annual Convention 2025 is set to be a defining moment for the marine fuels industry. Registration is now open via the IBIA Annual Convention website.