Following the introduction of the new 0.5% limit of sulphur in fuel oil on 1st January 2020, the International Maritime Organisation’s (“IMO”) so called ‘carriage ban’ on non-compliant fuel came into force on the 1st March 2020. In terms of this ban, it will become an offence for ships to carry fuel oils that contain sulphur content higher than 0.5%, unless the ship has a scrubber, or the non-compliant fuel is carried as cargo. Effectively the carriage ban is an additional mechanism aimed at giving teeth to the new global sulphur limit.

If any ship is found to be in breach of the new sulphur limit or the carriage ban, it may be subject to sanctions varying from administrative fines or criminal penalties such as detention, refusal or delay to enter port and prosecution. Sanctions are to be determined by the flag and port states.

Furthermore in order to support the safe and consistent sampling of fuel oil being carried for the purpose of combustion (not carriage), and the enforcement of the carriage ban, the IMO’s sub-committee on Pollution Prevention and Response (PPR) is currently finalising draft guidelines for the verification of the sulphur content of the fuel oil carried for use on board a ship. This will ensure that flag and port states adopt a streamlined approach when conducting such tests.