Specifically, although both Associations welcomed Iceland's decisions, they were critical on Minister's for the Environment and Natural Resources, Guðmundur Ingi Guðbrandsson "gap" which allows vessels to continue burning HFO and emit black carbon.

They both support that scrubbers in their majority are open loop, meaning that the waste produced , which can be high in sulphur and also other pollutants such as heavy metals and polyaromatic hydrocarbons, can be dumped straight into the sea.

Also, they expressed their concerns on the potential of a scrubber malfunctions when the vessel sails in cold temperatures or due to ice, given that in this case the possibilities that ships will continue to burn HFO and will emit high levels of Sulphur increase.

Árni Finnsson, of the Iceland Nature Conservation Association commented that

The only viable step forward is for Iceland to completely ban the use and carriage of heavy fuel oil from its territorial waters, ahead of an International Maritime Organization ban currently in development to ban its use and carriage in the Arctic.

Moreover, two more challenging threats are not yet solved; Continuous use of HFO along with a scrubber may reduce black carbon emissions somewhat, but it will not however prevent emissions of black carbon entirely. Under the possibility that black carbon is deposited into snow and ice in the Arctic, it accelerates sea and ice melt, increasing the area of exposed, dark ocean water which absorbs more heat, and promoting the self-reinforcing cycle of human-induced climate warming.

The second threat is the amount of HFO carried by vessels in the North Atlantic and into the Arctic will not be significantly reduced by Iceland’s new regulation, which means the risk of severe damage to the ocean ecosystem in case of an accidental HFO spill will remain. Cleaning HFO once it enters the marine environment, particularly colder Arctic waters, is virtually impossible.

Therefore, the two Associations urge the Government of Iceland to ban all vessels which burn or carry HFO, from entering Icelandic waters.