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The Maritime Industry Authority is set to implement the International Maritime Organization’s 0.50% sulfur cap on marine fuel oil in domestic ships on January 1, 2025
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The agency will, however, grant an extension to shipping operators with a higher number of vessels, said MARINA administrator Sonia Malaluan
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The extension applies to shipping operators that submitted their ship-specific implementation plan to MARINA by July 1, 2024
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The extension will not exceed five years, or only until 2029
The Maritime Industry Authority (MARINA) is implementing the International Maritime Organization’s (IMO) 0.50% sulfur cap on marine fuel oil in domestic ships by January 1, 2025, according to MARINA administrator Sonia Malaluan in a recent briefing.
While compliance to the sulfur cap policy is high, Malaluan said some shipping operators with a higher number of vessels will be granted an extension in consideration for the high costs that compliance entails.
The extension may only be granted to shipping operators that have submitted their ship-specific implementation plan (SIP) to MARINA as of July 1, 2024, based on MARINA Advisory (MA) No. 2024-35. The advisory provides supplemental guidelines on the implementation monitoring and enforcement of MARINA Circular (MC) No. SR-2020-06, which mandates the implementation of the IMO sulfur cap policy.
READ: MARINA issues supplemental rules on adoption of sulfur cap
The SIP refers to the ship’s transition plan in preparation for compliance with the use of low-sulfur fuel oil (LSFO).
The extension will also not exceed five years, or only until 2029. Malaluan noted that MARINA has already issued extensions to some shipping lines based on their SIP.
IMO’s International Convention for the Prevention of Pollution from Ships (MARPOL Convention) Annex VI requires all ships in non-emission control area zones to limit the sulfur content of their fuels from 3.50% to 0.50% by January 1, 2020. The Philippines ratified MARPOL Annex VI in 2018.
The regulation applies to all ships, whether they are on international voyages between two or more countries, or on domestic voyages solely within the waters of a party to the MARPOL Annex.
The sulfur cap policy, also known as IMO 2020, aims to reduce the amount of sulfur oxides emanating from ships in order to gain health and environmental benefits for the world, particularly for populations living close to ports and coasts.
The policy is already being enforced on foreign-flagged ships and Philippine-flagged vessels plying international trade since January 1, 2020, in compliance with the global implementation schedule.
For domestic ships, MARINA decided to implement the rule in January 2025 to help ease the cost impact on domestic shipping companies and give oil suppliers time to acquire their supplies of compliant fuels.
On the supply of LSFO locally, Malaluan noted that “supply follows demand” and that once shipping operators continue to comply with the policy, then “the supply of this fuel will also increase.”
Under MC SR-2020-06, MARINA also allows alternative measures for compliance, such as the use of alternative fuel such as liquefied natural gas, installation of exhaust gas cleaning system, or compliant marine diesel oil that has sulfur content of 0.50% per m/m or less.
MA 2024-35, meanwhile, said ships that are already using distillates or blends may shift to fuel oil with 0.50% m/m sulfur content and are required to accomplish an SIP to be attached to the ship’s Safety Management System Manual.
Shipping companies will be required at all times to keep a record of fuel oil documentation issued by their Department of Energy-accredited supplier.
The sulfur content of the fuel oil delivered direct to the ship or through fuel oil storage tank/facility of the shipping company should be documented through a Bunker Delivery Note (BDN) compliant with Regulation 14.5 of MARPOL Annex VI as a standard document required by MARINA that contains information on fuel oil delivery.
The BDN should also be kept safe within one year from the date of issuance.
The BDN should be accompanied by a representative sample of the fuel oil delivered, also known as MARPOL Delivered Sample, to be retained by the vessel/shipping company. Recognizing the inherent level of test variability for in-use and on-board samples, MARINA adopts the IMO’s maximum limit of 0.53% sulfur content for samples drawn on-board.
In case of non-availability of LSFO, the shipping company should submit a Fuel Oil Non-Availability Report duly certified by their supplier.
To help monitor compliance, Malaluan said they will be implementing next year its Maritime Energy Demand Information and Analysis Software, which is a system that will collect necessary environmental parameters and quickly estimate the energy consumption and greenhouse gas emissions of the operating fleet based on transportation activity.
MARINA will also be partnering with the Philippine Coast Guard, which Malaluan noted has the manpower to help enforce the policy.
