Sulphur limits for fuel used by ships in the Irish Sea

I have recently been raising the issue of pollutants from diesel engines and whilst the thrust of most concerns about such engines is associated with cars and lorries it has to be remembered that here on Merseyside we also have to consider the effects of pollutants from ships visiting the Mersey.

The Mersey - Looking from Bootle over the River to the Wirral

The Mersey – Looking from Bootle over the River to the Wirral

A local environmental campaigner of my acquaintance has been looking in detail at pollutants from ships and he took the matter up with the Government. Below is the text of a letter that details the present and future pollutant levels as they affect the Irish Sea. It makes for interesting reading and my thanks go to Peter Greener of Lydiate for digging into this sooty subject.


Pollutant emissions from ships are regulated by Annex VI to the International Convention for the Prevention of Pollution from Ships (commonly known as MARPOL), the latest, revised version of which was adopted by the International Maritime Organization (IMO) in October 2008. The Government supports the limits in MARPOL Annex VI, which are designed to improve air quality and result in consequential benefits for public health and for the environment.

The current 1.0 per cent limit for sulphur in marine fuel in waters designated as Emission Control Areas (ECAs), will be replaced with a 0.10 per cent sulphur limit, which will apply from 1 January 2015. Within Europe, the only ECAs are the Baltic Sea and the North Sea (including the English Channel). In order to comply with the 0.10 per cent sulphur limit, ship owners can use low-sulphur fuel or an alternative compliance method, such as using an exhaust gas cleaning system or using an alternative fuel like liquefied natural gas (LNG). Outside the ECAs, the current 3.5 per cent sulphur limit for fuel will be replaced by a 0.5 per cent sulphur limit in 2020 unless the IMO’s review of fuel availability (which must be completed by 2018) indicates that sufficient compliant fuel would not be available, in which case the requirement may be deferred to 2025.

The sulphur provisions contained in MARPOL Annex VI are substantially mirrored in the EU Directive on sulphur content of marine fuels (amending Directive 2012/33/EU) which was adopted in 2012. The main differences with the European rules are that:

• The 0.5 per cent sulphur limit will apply to all ships in European waters operating outside the ECAs, including the Irish Sea, from 1 January 2020 (i.e. this limit will not be deferred until 2025);
• Since 2010, all ships at berth at a port in European waters, for more than 2 hours, have been required to use 0.1 per cent sulphur fuel (or equivalent); and
• Until 31 December 2019, passenger ships on regular services, operating in European waters outside of the ECAs, must use fuel which does not exceed 1.5 per cent sulphur. From 1 January 2020, the sulphur limit will decrease to 0.5 per cent (as it will for all ships in European waters operating outside the ECAs).
Under both MARPOL Annex VI and the EU Directive, there is a provision concerning the non-availability of compliant fuel. If a ship is found to be using non-compliant fuel and can demonstrate that no compliant fuel was available, then a State has discretion to take into account all relevant circumstances and the evidence presented to determine the appropriate action to take, including not taking control measures. In practice however, it is very unlikely that a ship operating outside an ECA will have any difficulty obtaining compliant 3.5 per cent sulphur fuel.
There is nothing to prevent a group of States applying to the IMO to have the adjoining sea to their shoreline designated as a sulphur ECA. When the UK was considering its application (along with all the other adjoining States) to have the North Sea designated as an ECA, the available evidence supported the case for adopting stricter sulphur limits in these waters. Due to the much lower traffic density and lower population density in the Irish Sea and northern UK waters, the Government considers there is less justification for designating these waters as an ECA. Submitting an application for a new ECA, or extending the existing North Sea sulphur ECA so that it encompasses all the seas around the UK would also need the support of the Irish Government.

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