The new ICS guidance explains that the implementation process must address the possibility that some ships may need to carry and use more than one type of compliant fuel in order to operate globally. This could lead to more challenges, like compatibility between different available grades of fuel that could have significant implications for the safety of the ship as well as its commercial operation.


ICS also highlighted that the full implementation picture is far from complete, and that the main responsibility for making sure that compliant and compatible fuels will be available rests with oil suppliers, as well as those IMO Member States which have  agreed to implement this major regulatory change in 2020.

The free ICS guidance has been prepared for the vast majority of ships that will comply after 1 January 2020 using fuel oils with a sulphur content of 0.50% m/m or less.

As ICS Secretary General, Guy Platten explained, shipping companies may need to start ordering compliant fuels from as early as the middle of 2019, and are strongly recommended to begin developing implementation plans as soon as possible.

In addition, ICS said that the implementation of the global cap will be far more complex than for the previous introduction of Emission Control Areas. This is because of the big magnitude of the change and the much larger quantities and different types of fuel involved, as well as  uncertainties about the availability, safety and compatibility of compliant fuels.

Namely, ICS noted that if a ship has a suitably developed implementation plan, then the ship’s crew should be in a better position to showcas to Port State Control that they have acted in ‘good faith’ and done everything that could be reasonably expected to achieve full compliance.

This will be important, especially in case that safe and compliant fuels are unavailable in some ports during the initial weeks of implementation, Mr. Platten said. He also added that IMO has agreed that Port State Control authorities may consider the ship’s implementation plan when verifying compliance with the 0.5% sulphur limit.

Finally, the association called for more progress by governments to address outstanding safety issues, including serious concerns about the fuel quality of new blended fuel oils, at the next meeting of the Maritime Safety Committee in December 2018.

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