China: Fuel Sulphur Cap and Emission Control Areas

Emission Control Areas

China established coastal emission control areas (ECA) that capped the sulphur content of marine fuels.

The three ECAs are the Pearl River Delta, the Yangtze River Delta and Bohai Bay. These arise as a matter of Chinese domestic law and are not MARPOL Annex VI designated emission control areas.

Timeline of implementation

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 was stricter enforcement of the existing international and domestic requirements. Ports within the emission control areas had the option to introduce a 0.50% sulphur limit and/or other control measures.

From 1 April 2016: the Yangtze River Delta core ports – Shanghai, Ningbo, Zhoushan, Suzhou and Nantong – require that vessels use fuel of less than 0.50% sulphur content whilst at berth.

This excludes one hour before departure and arrival. Authorities encourage vessels to burn fuels with a sulphur content less than 0.10% whilst at berth and to use 0.50% maximum sulphur fuel when operating within the emission control area. See Huatai Circular here.

From 1 October 2016: Vessels berthed at Shenzhen port required to use fuel with a maximum sulphur content of 0.50%. Other core ports within the Pearl River Delta ECA will introduce the 0.50% sulphur limit on 1 January 2017. See Huatai Circular here.

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 0.50% – except one hour after arrival and one hour before departure.

From 1 September 2017: All vessels calling at any port within the Yangtze River Delta area must use fuel with a sulphur content not exceeding 0.50% when berthing, excluding one hour after and before departure. See Huatai Circular here.

From 1 January 2018: Vessels at berth in any port within an emission control area should use fuel with a maximum sulphur content of 0.50% – except one hour after arrival and one hour before departure. See Huatai Circular here.

From 1 October 2018: Vessels to use fuel with sulphur content of no more than 0.50% m/m when entering:

• the Yangtze River Delta ECA
• the Shanghai port area
• Suzhou and Nantong ECA

See Huatai Circular here.

From 1 January 2019: Vessels operating within a coastal emission control area should use fuel with a maximum sulphur content of 0.50%. This excludes the waters under the jurisdiction of Hong Kong, Macao and Taiwan.

From 1 January 2020: The IMO global sulphur cap of 0.50% enters into force. China MSA issue ‘Implementation Scheme of 2020 Global Marine Fuel Oil Sulphur Cap’. See Huatai Circular here.

From 1 January 2022: A sulphur cap of 0.10% will apply to seagoing vessels entering Hainan Waters within the coastal ECA from 1 January 2022.

Inland Emission Control Areas

A more stringent sulphur cap applies 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.

Exhaust gas cleaning systems (scrubbers)

The discharge of wash water from open-loop scrubbers is prohibited in:

• Inland river ECAs
• Port waters within Coastal ECAs
• Bohai Sea – the sea area within lines connecting the junction point of shorelines of Dandong, Dalian and shorelines of Yantai, Weihai.

Also prohibited is the incineration of the water washing residues from any type of exhaust gas scrubber.

Ships are required to keep accurate records of the stowage and disposal of the washing washings. If a vessel is not able to store the washing water it is required to switch to low sulphur fuel (not exceeding 0.50%) prior to entering the above areas.

Under certain circumstances a vessel may apply for an exemption if it uses fuel that does not meet the MSA’s requirements.

A copy of the MSA’s guidelines for ships operating within the ECAs, including enforcement details can be found here.

Shore power requirements

CCS 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.

Guidance on checking compliance and enforcement

The China MSA has issued guidelines on how compliance with the fuel sulphur regulations will be checked and enforced.

Guidelines for Supervision and Management of Air Pollutant Emissions aims to standardise inspection procedures and actions related to Chinese sulphur limiting regulations. This includes guidance on the penalties that can be expected in the event of a violation.

See Huatai Circular here.

Boundaries and core ports for each emission control area

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.