Preparing for the 2020 Sulphur Cap

The free ICS guidance has been prepared for the vast majority of ships that need to comply with the cap, which enters into force on January 1, 2020 and will cut allowable sulphur content from 3.5 percent to 0.5 percent.

ICS secretary general, Guy Platten, explained: “Shipping companies may need to start ordering compliant fuels from as early as the middle of 2019, and they are strongly recommended to commence developing implementation plans as soon as possible.”

Apart from the significant additional cost of compliant fuel, ICS says that implementation of the global cap will be far more complex than for the previous introduction of Emission Control Areas. This is because of the sheer magnitude of the switchover and the much larger quantities and different types of fuel involved, as well as continuing uncertainties about the availability, safety and compatibility of compliant fuels in every port worldwide.

ICS argues that if a ship has a suitably developed implementation plan, then the ship’s crew should be in a better position to demonstrate to Port State Control that they have acted in ‘good faith’ and done everything that could be reasonably expected to achieve full compliance.

“This need to demonstrate good faith could be particularly important in the event that safe and compliant fuels are unavailable in some ports during the initial weeks of implementation,” said Platten. “And IMO has provisionally agreed that Port State Control authorities may take into account the ship’s implementation plan when verifying compliance with the 0.5 percent sulphur limit.”

ICS adds, however, that the full implementation picture is far from complete, and the primary responsibility for ensuring that complaint and compatible fuels will be available rests with oil suppliers, as well as those IMO member states which have collectively agreed to implement this major regulatory change in 2020.

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