The International Maritime Organization is an agency tasked with improving the security and safety of international shipping. One of its key duties is to devise strategies and measures to keep the waterways clean by preventing marine pollution from ships.

International Maritime Organization (IMO) is an agency of the United Nations which has been formed to promote maritime safety. … IMO ship pollution rules are contained in the “International Convention on the Prevention of Pollution from Ships”, known as MARPOL 73/78.

About International Maritime Organization (IMO)

♦ It was established by UN convention in Geneva on 17 March 1948 and met for the first time in January 1959.

♦ IMO is responsible for measures to improve the safety and security of international shipping and to prevent pollution from ships.

♦ It is also involved in legal matters, including liability and compensation issues and the facilitation of international maritime traffic

♦ It currently has 174 Member States. India joined in 1959.

International Maritime Organization (IMO) Number

The International Maritime Organization (IMO) number is a unique identifier for ships, registered ship owners and management companies. IMO numbers were introduced to improve maritime safety and security and to reduce maritime fraud. The International Maritime Organization (IMO) number is a unique identifier for ships and for registered ship management companies. For ships, it consists of the three letters “IMO” followed by the seven-digit number assigned to all ships by IHS Fairplay constructed.

3 key IMO conventions

Majority of conventions adopted by IMO usually fall into three main categories

1. Maritime Safety,

2. Prevention of Marine Pollution, and

3. Liability and Compensation, especially in Relation to Damage Caused by Pollution.

Global Marine Fuels Report 

The main type of “bunker” oil for ships is heavy fuel oil, derived as a residue from crude oil distillation. Crude oil contains sulphur which, following combustion in the engine, ends up in ship emissions. Sulphur oxides (SOx) are known to be harmful to human health, causing respiratory symptoms and lung disease. In the atmosphere, SOx can lead to acid rain, which can harm crops, forests and aquatic species, and contributes to the acidification of the oceans.

Limiting SOemissions from ships will improve air quality and protects the environment.

IMO regulations to reduce sulphur oxides (SOx) emissions from ships first came into force in 2005, under Annex VI of the International Convention for the Prevention of Pollution from Ships (known as the MARPOL Convention). Since then, the limits on sulphur oxides have been progressively tightened.

From 1 January 2020, the limit for sulphur in fuel oil used on board ships operating outside designated emission control areas is reduced to 0.50% m/m (mass by mass). This will significantly reduce the amount of sulphur oxides emanating from ships and should have major health and environmental benefits for the world, particularly for populations living close to ports and coasts.

The International Maritime Organisation (IMO) has ruled that from 1 January 2020, marine sector emissions in international waters be slashed. The marine sector will have to reduce sulphur emissions by over 80% by switching to lower sulphur fuels.

Cleaner Air in 2020: 0.5% sulphur cap for ships enters into force worldwide. From 1 January 2020, the maximum sulphur content of marine fuels is reduced to 0.5% (down from 3.5%) globally – reducing air pollution and protecting health and the environment.


How can vessel operators comply with the IMO 2020 regulation?

1. Use Scrubbers. They can use Scrubbers (emission cleaning technology) to remove pollutants from the ship’s exhaust, which allows them to continue using higher-sulphur fuels. …

2. Switch to non-petroleum-based fuels. …

3. Switch to a Very Low Sulphur Fuel (VLSF) or MGO.

The move to lower sulfur content allows for the application of advanced emissions control technologies that substantially lower the harmful emissions from diesel combustion.

MGO (Marine gas oil) – roughly equivalent to No. 2 fuel oil, made from distillate only. MDO (Marine diesel oil) – A blend of heavy gasoil that may contain very small amounts of black refinery feed stocks, but has a low viscosity up to 12 cSt so it need not be heated for use in internal combustion engines.

What does IMO 2020 go into effect?

The IMO 2020 regulations specifying 0.50% sulphur emissions will go into effect on January 1, 2020. Individual countries that are party to MARPOL Annex VI are responsible for monitoring, compliance, and enforcement of the new regulations.

March 1 was the second key date in IMO 2020 with carriage ban for non-compliant fuel unless the vessel is fitted with a scrubber coming into force.

The amendment to the International Convention for the Prevention of Pollution form ships (MARPOL) sits alongside the 0.5% global low sulphur cap and prohibits the carriage of non-compliant fuel oil fuel by ships for the purposes of propulsion. The only exception is for vessels fitted with scrubbers.

IMO 2020 came into force on 1 January with the majority of owners opting to use compliant very low sulphur fuel oils or marine gas oil and a much smaller percentage choosing to install scrubbers or run vessels on alternative fuels such as LNG.

The regulation will apply globally and throughout the industry to fuels used in the open sea. It will affect vessel operators, refineries, and global oil markets. In the Environmental Control Areas (ECA zones) an even stricter regulation remains, limiting the sulphur content to 0.1%.’

Does the sulphur limit apply only to ships on international voyages?

​The sulphur oxides regulation (MARPOL Annex VI, regulation 14) applies to all ships, whether they are on international voyages, between two or more countries;  or domestic voyages, solely within the waters of a Party to the MARPOL Annex.

What is the “carriage ban” and how does it work?

​The carriage ban refers to the MARPOL amendment adopted in 2018 to prohibit the carriage of non-compliant fuel oil for combustion purposes for propulsion or operation on board a ship – unless the ship has an exhaust gas cleaning system (“scrubber”) fitted.

The amendment is intended as an additional measure to support consistent implementation and compliance and provide a means for effective enforcement by States, particularly port State control.

The specific provision requires that fuel oil used on board ships shall not exceed 0.50% sulphur limit. The amended provision to prohibit the carriage of non-compliant fuel oil reads as follows: “The sulphur content of fuel oil used or carried for use on board a ship shall not exceed 0.50% m/m.”

So, carriage of fuel oil for use on board ships will be prohibited from 1 March 2020 if the sulphur content exceeds 0.50%.

Regulation 2.9 of MARPOL Annex VI provides the definition for ‘fuel oil’ – “Fuel oil means any fuel delivered to and intended for combustion purposes for propulsion or operation on board a ship, including gas, distillate and residual fuels.”

The provision does not apply to fuel oil being carried as cargo.

What must ships do to meet the new IMO regulations?

The IMO MARPOL regulations limit the sulphur content in fuel oil. So ships need to use fuel oil which is inherently low enough in sulphur, in order to meet IMO requirements.

Refineries may blend fuel oil with a high (non-compliant) sulphur content with fuel oil with a sulphur content lower than the required sulphur content to achieve a compliant fuel oil. Additives may be added to enhance other properties, such as lubricity.

Some ships limit the air pollutants by installing exhaust gas cleaning systems, also known as “scrubbers”. This is accepted by flag States as an alternative means to meet the sulphur limit requirement. These scrubbers are designed to remove sulphur oxides from the ship’s engine and boiler exhaust gases. So a ship fitted with a scrubber can use heavy fuel oil, since the sulphur oxides emissions will be reduced to a level equivalent to the required fuel oil sulphur limit.

Ships can have engines which can use different fuels, which may contain low or zero sulphur. For example, liquefied natural gas, or biofuels.

IMO is not Responsible for Enforcing their Policies

> The IMO is not responsible for enforcing its policies. There is no enforcement mechanism to implement the policies of the IMO.

> The IMO, like any other UN agency, is primarily a secretariat, which facilitates decision-making processes on all maritime matters through meetings of member states.

> The binding instruments are brought in through the conventions — to which member states sign on to for compliance

The Port State Control of the respective state is responsible. They will check logbooks, use sniffer devices and sniffer drones.

What will the Fine if a Carrier does not Comply with IMO 20202?

Depending on the jurisdiction, the penalties are high fines, ship arrest or even imprisonment of the captain.

Regulatory Impact of IMO 20202

IMO 2020 compliance requires a massive change that will demand rapid adjustments across the global fuel supply chain to comply with the 1 January 2020 deadline. The landmark decision by the International Maritime Organization already has begun to exact far-reaching consequences on shipping company operating costs, global freight rates, shipping economics, scrubber demand, accelerated ship scrappage and more

The prospect of IMO 2020 has resulted in a high level of uncertainty about availability of petroleum products and prices. It is currently not possible to indicate an accurate future price level for IMO 2020 compliant fuels, as prices are affected by several factors. In particular, geopolitical events such as sanctions and war, the actions of OPEC (Organisation of the Petroleum Exporting Countries) and the general demand of the world economy for oil influence the price of crude oil and ultimately the price of fuel products. The IMO 2020 regulation will have another significant effect in addition to the regular volatility of global oil prices.

Cost Impacts

According to current calculations, the expected increase in costs will have a significant impact on the overall prices of container transportation and on freight rates. Whilst the implementation date for IMO 2020 is January 1st 2020, freight rates increase is already seen. Long-term agreements for both full and part load containers will include a price adjustment method also known as Bunker Adjustment Factor (BAF). With each line having its own variation on a basic formula Bunker Adjustment Factor (BAF), covering a range of areas including fuel price, ship size and trade, Container lines are facing growing pressure to standardise surcharges, which have become ever more complicated with the introduction of IMO 2020.

The lack of transparency and standardisation of those variables is a constant irritant to shippers, freight forwarders, and non-vessel-operating common carriers (NVOCCs) and gives rise to the suspicion that some carriers are using the BAF as a revenue-raising tool as well as a cost-recovery and risk-sharing mechanism. Ultimately all these Cost are born by the Shippers (Exporters / Importers) there by increasing the Cost of Trading.

Disclaimer : The views and opinions; thoughts and assumptions; analysis and conclusions expressed in this article are those of the authors and do not necessarily reflect any legal standing.

(Author Can be reached at [email protected])

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May 2021