China: Emission Control Areas *Update*

Update 13 December 2018

China has established a coastal emission control area (ECA) and inland emission control areas that will cap sulphur content of marine fuels from 1 January 2019.

China Classification Society (CCS) reports that a coastal ECA that extends 12 nautical miles from the baseline of Chinese territorial waters will take effect from 1 January 2019. The new regulation will require vessels to burn marine fuels with a maximum sulphur content of 0.5%.

It is important to note that this coastal ECA excludes the waters under the jurisdiction of Hong Kong, Macao and Taiwan.

A more stringent sulphur cap will apply in designated ‘inland control areas’. These include the  navigable waters of the Yangtze River main lines (from Shuifu in Yunnan Province to Liuhe Estuary in Jiangsu Province) and the Xijiang River main lines (from Nanning in Guangxi Province to Zhaoqing in Guangdong Province).

Marine fuels used by seagoing vessels entering the inland emission control areas should not exceed 0.10% from 1 January 2020. However, this requirement applies to inland and “river-sea” ships entering inland emission control areas as of 1 January 2019.

Looking further ahead, a sulphur cap of 0.1% will apply to seagoing vessels entering Hainan Waters within the coastal ECA from 1 January 2022.

It is understood that alternative measures, such as LNG or scrubbers, will be accepted subject to approval.

Shore power requirements

CCS also advises on the requirements to use shore power when at berth in Chinese ports. From 1 July 2019, vessels engaged on international voyages that have the ability to receive shore power (except tankers or vessels using ‘equivalent measures’) should use shore power if berthed for more than 3 hours. This reduces to a minimum of 2 hours if berthed within an inland control area.

From 1 January 2021, cruise ships should use shore power when berthing for more than 3 hours in a berth with onshore power supply capacity.

The CCS technical notice can be read here.

Update 12 September 2018 

Early Implementation of Fuel Sulphur Regulations in Yangtze River Delta ECA

Local correspondents Huatai have provided an update on the early implementation of the next stage of fuel sulphur regulations in the Yangtze River Delta region. This follows the Jiangsu MSA issuing notification of the requirement for vessels to use fuel with sulphur content not exceeding 0.5%m/m when entering into the Suzhou and Nantong ECA.

Huatai have provided a helpful summary of the status of the regulation in the Yangtze River Delta as follows:

From 1 October 2018, ships are required to use low sulphur content fuel not exceeding 0.5%m/m when:

• entering Shanghai port area
• when entering Yangtze River Delta ECA if vessel’s destination is Ningbo or Zhoushan port
• when entering Suzhou and Nantong ECA area

Huatai circular PNI 1815 can be read here. 

Image credit: China MSA, translated by Huatai
Click here for high resolution

Update 31 August 2018

The Maritime Safety Administrations (MSA) of Shanghai and Zhejiang have issued notices on the requirements to use fuel with 0.5% maximum sulphur content at all times within the Yangtze River Delta emission control area.

Local correspondents Huatai – who have issued circular PNI 1814 – advise that from 1st October 2018 vessels are to use fuel with sulphur content of no more than 0.5% m/m when they enter into the emission control area (ECA) and when at any berth or anchorage. This means that vessels must change over onto compliant fuel in sufficient time prior to entering the Yangtze River Delta ECA.

Currently, vessels at berth in any port within this ECA should use fuel with a maximum sulphur content of 0.5% – except one hour after arrival and one hour before departure. The changes in requirements where complaint fuel must be used at all times within the ECA had not been expected to enter into force until 1 January 2019.

It is understood that vessels connecting to shore power receiving facilities are exempted from this requirement. Vessels may also use exhaust gas cleaning systems (scrubbers) to satisfy the new emission control requirements.

Vessels will need to apply in advance to the appropriate regional MSA for any exemptions on using non-compliant fuel.

We understand the situation in the Bohai Bay ECA and Pearl River Delta ECA remains unchanged and the requirement to use compliant fuel at all times within these ECAs will take effect on 1 January 2019.

Preparing for the Switch – Have a Plan

There are notable risks when changing over from ‘high sulphur’ heavy fuels to ‘low sulphur’ distillates and vice versa when at sea. It is strongly recommended that Members review and update their vessels’ procedures for this task.

Think about:

• Heavy fuel oil requires heating whereas distillates such as marine gas oil generally do not. It is important to control the rate of temperature change when changing between these fuels. 
• Ensure fuel oil spill returns from engines and other equipment are properly routed to avoid contamination of tanks.
• Changeover procedures must be workable and practical.
• Crew are trained and practice fuel changeovers – they fully understand the process and consequences of getting it wrong.
• When there are two fuels mixing in the supply line, there may be compatibility issues which can lead to the formation of sludge and block the pipework. It is advisable to carry out compatibility tests between the different fuels on board before use.
• There may be a need to undertake modifications to the vessels and its systems, such as fuel treatment arrangements. There will be a need for adequate storage capacity for the various grades of fuel and the suitability of the tanks must be assessed, such as protection from heat sources.
• Consider sending distillate bunker samples for laboratory testing and if operating in cold climates, know the cold flow characteristics of the fuel. Distillates can be adversely affected by the formation of wax in cold weather conditions and the fuel specification should be checked for cloud point and cold filter plugging point.
• If possible, carry out the changeover operations away from busy traffic areas and coastal areas.

Update 27 December 2017

Members are reminded that as of 1 January 2018 the requirement to use low sulphur fuel whilst visiting all ports within the emissions control areas will be in force.

The fuel requirements and the ECA areas are shown here.

Update – 22 September 2017

Further to the requirement for vessels to use low sulphur fuels in all ports within the Zhejiang ECA, it has been announced that the same obligation will apply to all ports within the neighbouring Jiangsu ECA.

Correspondents Huatai have advised in their circular PNI1711 that the Jiangsu MSA have issued a formal notice on the updated requirements. It states that as of 1 September 2017 vessels calling at any port within the Jiangsu ECA must use fuel with a sulphur content of 0.5% or less when at berth (excluding one hour after and before departure).

Huatai advises this now means that the 0.5% sulphur restriction when at berth applies to all ports with the Yangtze River Delta ECA.

Update 5 September 2017

Low sulphur requirements in all ports within Zhejiang ECA come into force 1 September 2017

China correspondent Huatai Insurance Agency and Consultant Service Ltd have advised of changes to the fuel sulphur regulations in the Zhejiang emission control area. The new lower limits will take effect on 1 September 2017.

The reduction of fuel sulphur limits applies to all ports within the Zhejiang ECA area which itself forms part of the Yangtze River Delta ECA area. All vessels calling at any port within the Zhejiang area must use fuel with a sulphur content not exceeding 0.5%m/m when berthing, excluding one hour after and before departure. Ports in this area include Ningbo, Zhoushan, Jiaxing and Taizhou.

Huatai’s Circular PNI1710 can be read here.

New Emission Control Areas in China

Three new emission control areas will be established in China. They have been created to reduce the levels of ship-generated air pollution and mainly focus on the sulphur content of fuels. These areas are the Pearl River Delta, the Yangtze River Delta and Bohai Bay. It should be noted that these emission control areas arise as a matter of Chinese domestic law and are not MARPOL Annex VI designated emission control areas.

Details of these areas were first announced in when the “Ship and Port Pollution Prevention Special Action Plan (2015-2020)” was issued by the Chinese Ministry of Transport. This was followed by the implementation plan which was released in December 2015.

The new regulations apply to all vessels entering or operating within the emission control areas, with the exception of military, pleasure craft and fishing vessels.

Boundaries and Core Ports

As part of the implementation process a number of ‘core ports’ have been identified. The boundaries and core ports for each emission control area are as follows:

Pearl River Delta ECA

Sea boundaries: the sea area within the lines connecting the points of A, B, C, D, E and F (excluding the waters of Hong Kong and Macau) as sketched above.
Point A: The Shoreline junction point of Huizhou and Shanwei
Point B: 12 nautical miles away from Zhentouyan
Point C: 12 nautical miles away from Jiapeng Archipelago
Point D: 12 nautical miles away from Weijia Island
Point E: 12 nautical miles away from Dafanshi Island
Point F: The Shoreline junction point of Jiangmen and Yangjiang
 
Inland water areas: navigable inland waters under administrative jurisdiction of 9 cities including Guangzhou, Dongguan, Huizhou, Shenzhen, Zhuhai, Zhongshan, Foshan, Jiangmen and Zhaoqing.
 
Key ports: Shenzhen, Guangzhou and Zhuhai.

Yangtze River Delta ECA

Sea boundaries: the sea area within the lines connecting the points of A, B, C, D, E, F, G, H, I and J.
Point A: The Shoreline junction point of Nantong and Yancheng
Point B: 12 nautical miles away from Wai Ke Jiao Island
Point C: 12 nautical miles away from Sheshan Island
Point D: 12 nautical miles away from HaiJiao
Point E: 12nautical miles away from Southeast Reef
Point F: 12nautical miles away from Two Brothers Reef
Point G: 12 nautical miles away from Yushan Archipelago
Point H: 12 nautical miles away from Taizhou Islands (2)
Point I: 12 nautical miles away from junction point of shoreline of Taizhou and shoreline of Wenzhou
Point J: Junction point of shoreline of Taizhou and shoreline of Wenzhou
 
Inland water areas: navigable waters under the administrative jurisdiction of 15 cities including Nanjing, Zhenjiang, Yangzhou, Taizhou, Nantong, Changzhou, Wuxi, Suzhou, Shanghai, Jiaxing, Huzhou, Hangzhou, Shaoxing, Ningbo, Zhoushan and Taizhou.
 
Key ports: Shanghai, Ningbo-Zhoushan, Suzhou, Nantong.

Bohai-rim Waters ECA (Beijing, Tianjin and Hebei)

Sea boundaries: the sea area within lines connecting the junction point of shorelines of Dandong, Dalian and shorelines of Yantai, Weihai.
 
Inland water areas: navigable inland waters under the administrative jurisdiction of 13 cities including Dalian, Yingkou, Panjin, Jinzhou, Huludao, Qinghuangdao, Tangshan, Tianjin, Cangzhou, Binzhou, Dongying, Weifang, Yantai.
 
Key ports: Tianjin, Qinhuangdao, Tangshan and Huanghua.

Previous Updates

Update 2 December 2016 

Another Deadline Fast Approaching

The three emission control areas in China were created to reduce the levels of ship-generated air pollution and focus on the sulphur content of fuels.  The three areas are the Pearl River Delta, the Yangtze River Delta and Bohai Sea.  Below you will find a summary of the ECAs, ports, and the dates upon which the various requirements become mandatory:China’s Maritime Safety Administration (MSA) has issued a set of guidelines on the implementation and supervision of ECAs that detail how they will verify compliance with emission control measures.  Such verification measures may include:

• For ships using low sulphur fuel, inspection of bunker delivery notes, fuel change-over procedures, engine room logbook and fuel oil quality/samples.
• For ships using alternative measures, such as shore power, LNG or exhaust gas scrubbers, inspection of the International Air Pollution Prevention (IAPP) Certificate/Record and engine room log book.

2 September 2016

Local correspondents Huatai Insurance Agency and Consultant Service Ltd have issued a Circular that provides further details on the Shenzhen port fuel sulphur requirements that take effect on 1 October 2016. The Circular summarises the key points from the formal notice issued by the Shenzhen authorities.

The Circular can be read here: Huatai Circular PN1608

23 August 2016

Local correspondents Huatai have advised that reduced sulphur limits will take effect in the port of Shenzhen from 1 October 2016. From this date, vessels berthed at Shenzhen port will be required to use fuel with a maximum sulphur content of 0.5%.

It is understood that the other core ports within the Pearl River Delta ECA will introduce the 0.5% sulphur limit on 1 January 2017 as per the original schedule.

Huatai’s circular can be read here.

22 February 2016

Local correspondents Huatai Insurance Agency and Consultant Service Ltd have issued a circular that provides further details on the Yangtze River Delta emission control area. The circular summarises the requirements of the document “Notice on Enhancing Supervision and Administration of ECAs” issued by the Chinese MSA. The Huatai circular can be viewed here. 

25 January 2016

The Chinese Ministry of Transport have issued a notice advising that ports in the Yangtze River Delta have exercised their discretion to adopt more stringent sulphur limits in 2016.

From 1 April 2016, the Yangtze River Delta core ports – Shanghai, Ningbo, Zhoushan, Suzhou and Nantong – will require that vessels use fuel of less than 0.5% sulphur content whilst at berth. This excludes one hour before departure and arrival.

It is also understood that the authorities are encouraging vessels to go further than the new mandatory requirement. They wish to encourage vessels to burn fuels with a sulphur content less than 0.1% whilst at berth and to use 0.5% maximum sulphur fuel when operating within the emission control area.

11 December 2015

Huatai Insurance Agency & Consultant Service Ltd issued further information on the new regulations and can be read here.   

Timeline of New Sulphur Limits

The limiting of the sulphur content of the fuels used within the emission control areas will be a staged process. Also, there are provisions for vessels to take alternative measures to comply with the new rules, such as connecting to shore power – also known as cold ironing – or using clean energy fuels. Another alternative is to use an exhaust gas scrubber.

The details in the timeline for the regulations are not clear at present. But it is understood to be as follows:

From 1 January 2016: Strict enforcement of the existing international conventions and domestic laws and regulations on sulphur oxides, particulate matter and nitrogen oxides.  The notable change is the indication that there will be stricter enforcement of the existing international and domestic requirements.

In addition, the ports within the emission control areas have the option to introduce a 0.5% sulphur limit and/or other control measures. In view of this option, it will be necessary to monitor developments on a port-by port basis.

From 1 January 2017: Vessels at berth in a core port within an emission control area should use fuel with a maximum sulphur content of 0.5% – except one hour after arrival and one hour before departure.

From 1 January 2018: Vessels at berth in any port within an emission control area should use fuel with a maximum sulphur content of 0.5% – except one hour after arrival and one hour before departure.

From 1 January 2019: Vessels operating within an emission control area should use fuel with a maximum sulphur content of 0.5%.

At a date which has yet to be advised after 31 December 2019 there will be an assessment made by the Chinese authorities with a view to adopting one or more of the following:

• Reducing the maximum sulphur content to 0.1% for vessels operating in the emission control area
• Expand the geographical size of the emission control areas
• Consider any other further initiatives

Members are advised to keep up to date on how this new staged regulation process progresses. Where necessary have sufficient compliant low sulphur bunkers to comply with the Chinese domestic requirements.

Check the situation with local agents well in advance of calling at an affected port.