The NorthStandard P&I Club, in collaboration with the Clean Shipping Alliance, has compiled this overview summarizing the current restrictions and conditions on open-loop scrubber discharge across global ports.
Argentina
Open loop EGCS discharge allowed? Currently allowed, though the prohibition is suspended.
Regulation No. 15/2020 from the Environment Protection Bureau, effective from 10 August 2020, initially prohibited the discharge of washwater from exhaust gas cleaning systems (EGCS) in Argentine waters. However, on 24 September 2020, Prefectura Naval Argentina issued Resolution DISFC-2020-22-APN-DPAM#PNA, suspending enforcement of Regulation 15/2020. This suspension took effect on 3 October 2020, but it is provisional, and the restrictions have not been permanently overturned.
Australia
Open loop EGCS discharge allowed? Allowed conditionally and with exceptions.
AMSA issued Marine Notice 12/2022, stating that the use of an EGCS is permitted in Australian waters to comply with low sulphur fuel requirements of MARPOL Annex VI. AMSA is currently investigating the potential impacts of EGCS wash water discharges and has commissioned a study on the cumulative effects of such discharges over time. The EGCS must be approved by the vessel’s flag State Administration, or a recognized organization appointed by the flag State, and operated in accordance with IMO requirements. Prior to discharge, EGCS wash water must comply with the quality criteria set in the 2021 EGCS Guidelines. While there are no prohibitions on discharge in Australian waters, some port authorities may encourage vessels to avoid discharging wash water within port limits. Specific port regulations include: in Sydney, cruise ships must use low sulphur fuel or an equivalent measure; in Hastings, EGCS discharges into Westernport waters are prohibited.
Bahrain
Open loop EGCS discharge allowed? Not permitted in port or at anchorage.
However, it is allowed in Bahraini territorial waters and exclusive economic zone (EEZ), provided the discharge complies with MEPC.259(68) and does not negatively impact marine ecosystems. Vessels must obtain a permit from the Marine Safety & Environment Protection Directorate before discharging washwater anywhere in Bahraini waters.
Belgium
Open loop EGCS discharge allowed? Not permitted within 3 nautical miles of the coast.
Belgian federal law allows discharge only in coastal and open seawaters at least 3 nautical miles offshore, without endangering EU Water Framework Directive objectives. Flemish regional law confirms that discharge is also prohibited in ports and inland waters.
Brazil
Open loop EGCS discharge allowed? Current legislation allows discharge but its application is inconsistent.
There is no discharge at Vale terminals or the Port of Santos. Prior to 23 July 2020, local advice indicated that discharge was not allowed, based on national legislation (Law 9.966/00). However, the Directorate of Ports and Coasts (DPC) / Navy changed their position, allowing discharge until a competent environmental authority assesses the situation. This allowance is not consistently applied nationwide. Vale instructs vessels not to discharge EGCS washwater while in Brazilian ports, recommending a change to compliant fuel before entering coastal waters. The Santos Port Authority has expressly prohibited open-loop scrubbers and washwater discharges.
Canada
Open loop EGCS discharge allowed? Not permitted in Vancouver.
The Vancouver Fraser Port Authority (VFPA) prohibits wash water discharge from EGCS when vessels are anchored in the port or moored at a berth, effective from 1 March 2022. The VFPA’s Harbour Patrol crew is responsible for enforcement through random checks on vessels.
China (P.R.)
Open loop EGCS discharge allowed? Not permitted in inland river Emission Control Areas (ECAs), port areas within coastal ECAs, and the Bohai Sea.
The China MSA guidance prohibits discharge from open-loop scrubbers in these areas and also bans incineration of washing water residues from any type of exhaust gas scrubber. Ships must maintain accurate records of washing water disposal and, if unable to store it, must switch to low sulphur fuel before entering these restricted areas.
Croatia
Open loop EGCS discharge allowed? Not permitted in port.
According to the Clean Shipping Alliance, the Ministry of the Sea, Transport and Infrastructure Notice from 27/10/2017 states that only closed loop operation is allowed.
Denmark
Open loop EGCS discharge allowed? Will be banned after 1 July 2025.
An agreement reached in April 2024 prohibits the discharge of scrubber water into Danish territorial waters up to 12 nautical miles from the coast. Ships must switch to compliant fuel or closed-loop scrubbers. This ban is expected to extend to closed scrubbers by 1 July 2029.
Egypt
Open loop EGCS discharge allowed? Not permitted in the Suez Canal.
The Suez Canal Authority has issued Circular 08/2019 clarifying that wash water from open-loop scrubbers cannot be discharged during transit. Currently, there are no restrictions on marine fuels until Egypt ratifies MARPOL Annex VI.
Estonia
Open loop EGCS discharge allowed? Permitted conditionally.
Circular Number 4 (21.10.19) refers to MEPC 184(59) and outlines restrictions on discharging chemical EGCS wash water in enclosed ports and estuaries. Exceptions can be made if the operator demonstrates compliance with international requirements and necessary pH levels. Prior authorization is required for discharges into the port area. The Water Act effective 01.10.2019 does not treat washing water discharges as violations if compliant with MARPOL. Closed-loop EGCS use is permitted in Estonia’s territorial waters, but discharging wastewater is not allowed.
Finland
Open loop EGCS discharge allowed? Not permitted in the Port of Porvoo.
While Finnish legislation allows wash water discharge in territorial waters, some ports have imposed their own restrictions.
France
Open loop EGCS discharge allowed? Not permitted within 3 nautical miles.
French authorities issued amendments in July 2021, leading to a prohibition on open loop scrubber discharge starting 1 January 2022. All vessels must cease using scrubbers and comply with sulfur content regulations in coastal areas and ports. Compliance will be monitored, with penalties for infringement ranging from €4,000 for the Master of the vessel to potential imprisonment and fines for severe violations.
Germany
Open loop EGCS discharge allowed? Not permitted in inland waterways, canals, and ports within inland waterways.
According to the CDNI Convention, restrictions apply to all inland waterways except for specific areas in Lake Constance and the Rhine.
Gibraltar
Open loop EGCS discharge allowed? Not permitted in port or territorial waters.
Closed loop scrubbers are allowed, and hybrid scrubbers operating in closed loop mode are also permitted. Open loop scrubbers are temporarily prohibited pending a definitive policy decision.
Hong Kong
Open loop EGCS discharge allowed? Permitted.
Regulations allow an exemption from using non-compliant fuel if authorities are satisfied with the abatement technology used.
India
Open loop EGCS discharge allowed? Permitted according to the Directorate General of Shipping, Mumbai.
Ports proposing to prohibit open loop operations must submit requests for assessment and approval. The Clean Shipping Alliance states that open loop use is permitted in all Adani ports, adhering to IMO requirements.
Panama
Open loop EGCS discharge allowed? Not permitted in the Panama Canal.
NT NOTICE TO SHIPPING No. N-1-2020 prohibits open-loop scrubbers or hybrid scrubbers in open-loop mode in Panama Canal waters. Closed-loop systems must submit documentation to the Panama Canal Authority, and wash-water residues cannot be discharged into water bodies.
Portugal
Open loop EGCS discharge allowed? Not permitted in the ports of Aveiro, Leixoes, Lisbon, and Sines.
Although Decree-Law No. 170/B/2014 allows the use of open-loop scrubbers, port administrations can impose additional restrictions, disallowing discharge from the entry into the port until the ship leaves.
Qatar
Open loop EGCS discharge allowed? Not permitted in ports or territorial waters.
Qatar Petroleum’s regulations state that wash water from open-loop scrubbers, containing chemicals and metals, is prohibited in Qatari waters.
Romania
Open loop EGCS discharge allowed? Not permitted within port limits.
Information from the Romanian Naval Authority states that the use of open-loop EGCS is forbidden within port limits, although there are no restrictions for their use in territorial waters.
Saudi Arabia
Open loop EGCS discharge allowed? Not permitted in ports or territorial waters.
Circular 55-2020 bans exhaust wash-water discharges from open-loop EGCS in Saudi ports until environmental standards are issued.
Singapore
Open loop EGCS discharge allowed? Not permitted.
The Maritime and Port Authority of Singapore issued a ban on open-loop scrubbers effective January 1, 2020. This ban does not apply to ships transiting the Traffic Separation Scheme without calling at the Port of Singapore.
Spain
Open loop EGCS discharge allowed? Not permitted in the ports of Algeciras, Valencia, Cartagena, and Huelva.
The use of open-loop scrubbers is restricted in the ports of Bilbao and Cadiz, where operators must check with the Harbour Master and submit documentation.
Sweden
Open loop EGCS discharge allowed? Not permitted in the ports of Gothenburg, Stockholm, Trelleborg, Petroport, and Stenungsund.
Although there is no nationwide ban, local restrictions exist, and the discharge of contaminated water from scrubbers is only permitted in closed-loop mode in several ports.
Turkey
Open loop EGCS discharge allowed? Not permitted in ports or territorial waters.
A circular from the Ministry of Environment and Urbanization prohibits the discharge of wash-water from open-loop scrubbers in Turkish waters, requiring vessels to use compliant fuels instead.
United Kingdom – England
Open loop EGCS discharge allowed? Not permitted at berth in the Port of Tilbury.
The PLA allows both open and closed-loop scrubbers in the tidal Thames, but specific berth operators may impose additional restrictions. At the Port of Southampton and Port of Felixstowe, scrubbers are permitted under certain conditions.
United Kingdom – Scotland
Open loop EGCS discharge allowed? Not permitted in Forth and Tay ports.
Forth Ports Circular No. 45 of 2019 prohibits the discharge of materials, including wash-water from open-loop scrubbers.
United Kingdom – Wales
Open loop EGCS discharge allowed? Not permitted in the Port of Milford Haven.
Notice to Mariners No. 127 of 2019 prohibits the discharge of exhaust gas scrubber wash-water within the jurisdiction of the Milford Haven Port Authority.
United States – California
Open loop EGCS discharge allowed? Not permitted in ports or territorial waters.
The Californian ARB OGV regulations require vessels to use compliant distillate fuels to comply with the 0.1% sulphur limit before entering Californian waters.
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