As the implementation of the ban on the non-compliant fuel oil carriage is taking effect in March, the Indian Ocean MoU has been issuing a “letter of information” to vessels since September 2019, to make awareness in advance about the issue.
These new requirements prohibit the use of non-compliant fuel from 1st January 2020 and further the carriage of non-compliant fuel, for use on the ship, from 1st March 2020, unless the ship has a scrubber installed.
The importance is, therefore, placed on the requirements entering into force on 1st March 2020 prohibiting the carriage of non-compliant fuel, for use on ships not equipped with EGCSs.
As indicated in the letter, there are three options for ship owners and operators to comply:
- Use of compliant fuel oil with sulphur content not more than 0.50% m/m;
- Use an alternative fuel, such as LNG, with a sulphur content of 0.50 % m/m or less; or
- Fit an alternative means of compliance, such as an EGCS approved under regulation 4 of MARPOL Annex VI.
From 1 March 2020 onwards, non-compliant fuel can only be carried on board, for use on the ship, where the vessel is fitted with an EGCS and where compliant fuel cannot be obtained, a Fuel Oil Non-Availability Report (FONAR) must be submitted to the flag State and the Competent Authority in the next port of call.
Last month, the Tokyo and Paris MoUs also emphasized on the fuel carriage ban requirements entering into force on 1st March 2020, noting that the requirements will be applied without exception.