Key changes to MARPOL Annex VI on sulphur verification

The adoption of amendments to MARPOL Annex VI introduces three different types of fuel samples which authorities may obtain to check for compliance with sulphur limits, and two different verification procedures.

Key amendments include new definitions to identify the three types of samples and clarify what ‘sulphur content’ means, details on in-use and onboard fuel oil sampling and testing, introducing a requirement for ships to have designated sampling point(s) for taking representative samples of the fuel oil in use, and the new sulphur verification procedure in appendix VI of MARPOL Annex VI.

Amendments have also been made to Regulation 20, Attained Energy Efficiency Design Index (EEDI) and Regulation 21, Required EEDI.

IBIA was an active participant in developing amendments to MAPROL Annex VI relating to sulphur verification through submissions to IMO and discussions at IMO meetings, and achieved many, though not all, of our goals.

When the amendments were adopted at the 75th session of the IMO’s Marine Environment Protection Committee (MEPC 75) in November 2020, IBIA urged members states to forge ahead with early implementation of the amendments, as we believe it should greatly improve fair and consistent implementation of the 0.50% sulphur limit that took effect at the start of 2020.

The amendments are expected to enter into force 1 April 2022, however early implementation has been encouraged.

The preamble to Resolution MEPC.324(75), adopting the amendments, contains a reminder that already at MEPC 74 in 2019, MEPC.1/Circ.882 had requested the Parties to apply the amendments to appendix VI of MARPOL Annex VI related to the verification procedure for a MARPOL Annex VI fuel oil sample, in advance of their entry into force.

Resolution MEPC.324(75), which contains the full details of the amendments, invites the Parties to consider the early application of all the newly adopted amendments to MARPOL Annex VI.