Open letter to Dr Prior, Clean Arctic Alliance

Dear Dr Prior

Thank you for your letter dated 23 January.

First, please be assured that the co-authors listed below fully support IMO’s emissions reduction and de-carbonisation programmes and have been working extremely hard with their members and colleagues at IMO and elsewhere to ensure the environmental footprint of shipping and its associated services continues to reduce.

Please note that our Joint Industry Guidance: The supply and use of 0.50% – sulphur marine fuel (JIG) (JIG) was produced in August 2019 to address the safe handling and use of the new fuels that ship operators were expected to use post 1 January 2020 to comply with IMO’s 0.50% sulphur requirement. It was limited to operational aspects only and was developed to support suppliers, ship managers and seafarers prepare and implement the use of 0.50% sulphur fuels as safely as possible. Our document was wholly safety related and did not investigate or comment on any other issue.

Among the key points we identified in the JIG were that these 0.50% sulphur fuels were expected to be much more variable in terms of composition and characteristics than had been experienced previously.  In your letter, you refer to fuels with a high aromatic content that show a potential link with black carbon emissions. We expected there to be a greater tendency for 0.50% sulphur fuels to be more paraffinic – not aromatic – in nature. The information available since the introduction of the 0.50% sulphur limit on 1 January 2020, suggests our expectations have been generally correct.

To conclude, we fully agree that all black carbon related submissions (including the joint submission from Finland and Germany to IMO dated before the introduction of the 0.50% sulphur limit) should be reviewed thoroughly and seriously by the international fuel oil supply and shipping community. The upcoming IMO Pollution Prevention and Response Sub-Committee is the most effective forum to progress that debate. It would not be appropriate for us to pre-empt the conclusions from that discussion.

Thank you for getting in touch.

The African Refiners & Distributors Association (ARA)

International Association of Classification Societies (IACS)

International Bunker Industry Association (IBIA)

International Council on Combustion Engines (CIMAC)

Institute of Marine Engineering, Science and Technology (IMarEST)


Japan Petroleum Energy Center (JPEC)

Oil Companies International Marine Forum (OCIMF)

The Royal Institution of Naval Architects (RINA)

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