The company noted that the regulation entering into force in 2020 carries enforcement challenges and rising fuel costs, while the lack of viable methods for enforcement will create an uneven playing field, punishing compliant shipowners financially.

"It is unclear how non-compliance on the high seas will be detected, or how such instances will be pursued legally. At the same time, the OECD estimates that cleaner fuels will cost the container shipping industry up to USD 30 billion annually. The need for a cap on sulphur in fuels exists because it has been documented that emissions from fuels have serious impacts on human health, leading to premature deaths," said the company in its sustainability report for 2017.

Maersk is exploring viable solutions to the enforcement challenges, both alone and as a board member of the Trident Alliance, an association of shipowners committed to the strong enforcement of the global cap.

"Suggestions currently on the table include making it illegal to carry fuel with a sulphur content higher than the 0.5% limit if vessels are not fitted with a technology approved for exhaust gas cleaning such as scrubbers."

Further, the company informed it registered two non-compliance incidents in 2017, both driven from human error. In March 2017, a non-compliance was determined on a Maersk Line vessel calling at Long Beach in California, with the sulphur content at nearly 0.2% in an ECA where the sulphur cap is 0.1%. The internal investigation confirmed that the vessel carried compliant fuel, and that the contamination was due to a human error in the switchover procedure.

In July 2017, a Maersk Line vessel in the port of Antwerp, Belgium, was in breach of the area’s fuel sulphur limit of 0.1%.

"Our internal investigation found that the vessel’s low sulphur fuel tank had been contaminated due to human error in operating two butterfly valves between the ship’s high sulphur and low sulphur fuel tanks. The contamination raised the sulphur level in the low sulphur fuel tank to around 0.2 %. We carried out a complete cleaning of the low-sulphur tanks and the onboard systems, have implemented specific procedures to avoid this kind of contamination on all relevant vessels."

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