New 0.50% sulfur limit for Philippine ships comes into force

The Maritime Industry Authority (MARINA) of Philippines has issued a circular to provide information regarding the mandatory 0.50% m/m sulfur limit on fuel oil for all Philippine-registered ships, effective January 1, 2025.

Coverage

The MARINA MC No. SR2020-06 specifically covers ships utilizing heavy sulfur fuel oil and are therefore mandated to shift to fuel oil with low sulfur content of 0.50% m/m or below, effective 01 January 2025. Ships already using Distillates (MGO, MDO, IDO) or blends may shift to fuel oil with 0.50% m/m sulfur content and are required to accomplish a Ship-Specific Implementation Plan (SIP) to be attached to the Ship’s SMS Manual.

Ship-specific implementation plan (SIP)

The SIP is mandatory for all ships transitioning from heavy sulfur fuel oil (HSFO) to fuel oil with low sulfur content of 0.50% m/m or below.
The SIP should include risk assessment and management and shall be integrated into the ship’s Safety Management Manual.
The SIP shall be annexed to the Safety Management Manual of the ship and shall form part of the documents audited by the Administration.

Monitoring and enforcement

Survey and certification shall be conducted by the Administration (for domestic ships) or by its Recognized Organization (ROs) for overseas ships.
Shipping companies shall always keep a record of fuel oil documentation issued by their supplier. For purposes of this Advisory, “supplier” means a DOE-accredited or recognized supplier or bunker trader directly supplying the ships or the shipping company’s fuel storage facility.
The sulfur content of the fuel oil delivered directly to the ship or through the fuel oil storage tank/facility of the shipping company shall be documented through a Bunker Delivery Note (BDN) compliant with Regulation 14.5 of MARPOL Annex VI.
The BDN shall be safekept for one (1) year from the date of issuance.
The BDN shall be accompanied by a representative sample of the fuel oil delivered, also known as MARPOL Delivered Sample, to be retained by the vessel/shipping company.
The MARPOL Delivered Sample is sealed and signed by the Supplier’s representative and the Master or Officer-in-Charge of the bunker operation.
Recognizing the inherent level of test variability for in-use and on-board samples, this Administration adopts the IMO’s maximum limit of 0.53% sulfur content for samples drawn on board.

Information sharing related to non-compliances

Non-compliance of domestic ships and/or fuel oil suppliers shall be reported to the Administration, with a copy furnished to the Oil Industry Management Bureau of the Department of Energy (DOE). For overseas ships, non-compliance shall be reported by the Administration or its Recognized Organizations (ROs) to the IMO’s GISIS Module (Regulation 11.4) of MARPOL Annex VI.

Non-availability of low sulphur fuel oil

In case of non-availability of LSFO, the shipping company shall submit a Fuel Oil Non-Availability Report (FONAR) using the template attached as “C,” duly certified by the Supplier.

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Fines and penalties

“No sail condition until compliance” means that the ship cannot proceed to its next port of destination until the non-compliant fuel oil has been removed from the ship.

Transitory provision

The Administration may extend the compliance deadline based on the SIP timelines as verified by MARINA, but not to exceed five (5) years. No extension of the deadline shall be allowed if there is no SIP submitted by 01 July 2024.

A Letter of Approval will be issued by MARINA, and the same shall be presented upon inspection.

This Advisory is effective immediately and remains in force until an amendatory Circular has been issued.