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The reduction of the MARPOL Annex VI global fuel sulphur cap to 0.50% came into force on 1 January 2020. If you’re a shipowner or operator, important decisions were needed to ensure compliance with the requirements.
The impact of this new legislation is still being felt as vessel owners, operators, charterers and national authorities come to terms with its implementation. Learn more about the legislation and compliance options available to shipowners, as well as contractual and charterparty issues.
Want to know more?
Contact our 2020 sulphur cap specialists Mark Smith or Helen Barden on +44 191 232 5221 to see how we can support Members in making informed decisions.
2020 Sulphur Cap FAQ's
What is the Sulphur Cap 2020?
The reduction of the MARPOL Annex VI global fuel sulphur cap from 3.5% to 0.5% came into force on 1 January 2020. As expected, the introduction of a global sulphur cap has brought about radical change to the maritime industry and has posed challenges for shipowners and charterers alike. Many challenges relate to fuel availability, safety and compatibility as well as contractual and charter party disputes. If a ship is trading outside of the existing Sulphur Emission Control Areas (ECAs) they now need to burn compliant low sulphur fuels, or face potential fines, detentions or penalties.
What is the IMO 2020 regulation?
IMO 2020, is the regulation (MARPOL Annex VI) that mandates a maximum sulphur content of 0.5% in marine fuels globally. This is a reduction from the previous limit of 3.5%. The push for this change is the need to reduce the air pollution that is produced by the sulphur content of the fuels that ships use.
What are the main compliance options?
If you’re a shipowner or operator, difficult decisions are needed on which method of compliance to use. The best option for you may depend on several factors such as vessel type, vessel age and trading area. The five main compliance options are: burn distillates, burn hybrids or blends, install Exhaust Gas Cleaning Systems (EGCS), burn LNG, and use other alternative sources. Visit our compliance options area for more on the advantages and disadvantages of all options.
What are the contractual and charter party considerations for the MARPOL global sulphur cap?
Whether you’re an owner or a charterer, you will need to consider the technical and commercial issues to ensure your time charterparties and bunker supply contracts adequately deal with the new sulphur requirements. Some example clauses to be included are: bunker clauses and scrubber clauses. More information can be found in our contractual and charterparty area.
What legislation is in place for the MARPOL global sulphur cap?
The last decade has seen more stringent international and regional environmental regulations that aim to tackle shipborne air emissions. International legislation comes in the form of MARPOL, which is the very important IMO convention tackling pollution from shipping. Annex VI of MARPOL was created to prevent air pollution from ships, including sulphur oxides (SOx), nitrogen oxides (NOx), particulate matter (PM) and greenhouse gases (GHG) such as carbon dioxide (CO2) and ozone depleting substances. In addition to international legislation, some countries have created special emission control areas, which all have different rules. You will need to make sure that you always achieve the strictest sulphur requirement if there is a conflict between the local rules and the MARPOL global sulphur cap. For a full breakdown, visit our dedicated legislation area.
2020 Sulphur Cap Issues

Your 2020 Sulphur Cap Experts
Tiejha Smyth
FD&D Claims Director

Your 2020 Sulphur Cap Experts
Mark Smith
Loss Prevention Senior Executive - Nordics & Northern Europe

Your 2020 Sulphur Cap Experts
Tiejha Smyth
FD&D Claims Director

Your 2020 Sulphur Cap Experts
Mark Smith
Loss Prevention Senior Executive - Nordics & Northern Europe

Your 2020 Sulphur Cap Experts
Tiejha Smyth
FD&D Claims Director
Latest News & Articles
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Getting the Right Fit for the Cap: Assessing the Options
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North Publishes New Loss Prevention Guide on Marine Fuels
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EGCS: Do They Scrub Up Well?
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EMSA Publishes Guidance on Testing Fuels for Sulphur
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2020 Vision
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Danish EPA to use airborne sniffer technology to monitor passing ship emissions
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Danish Fines for Fuel Sulphur Violations
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China: Low Sulphur Fuel - Fines
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New Fuels and Heat Sensitive Cargoes
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New Year 2020 – New Regulations
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Dominican Republic Signing up to the IMO 2020 Sulphur Cap
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IMO 2020: Notifying Potential Non-compliance
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North Issues Guidance to Seafarers on Complying with the IMO 2020 Sulphur Cap
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Iceland Announce Stringent Sulphur Regulations
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China Issues Guidance on 2020 Sulphur Cap
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2020 Q&A: Bunker Suppliers Look Over the Horizon
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Free 2020 Training Video
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The Long-awaited Publicly Available Schedule (PAS) for Marine Fuels is Ready
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North Updates Guidance on 2020 Sulphur Cap
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Notifying Non-Compliant Bunkers in the US
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The 2020 Sulphur Cap
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2020: New Fuels on the Horizon
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Outcomes of MEPC 74 – Dealing with non-compliance
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2020: Outcomes of MEPC 74 – New Fuels and Bunkering
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2020: Outcomes of MEPC 74 – Fuel Sampling and Testing
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It's Time for Members to Prepare for the Big Switch
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South Africa Issues 2020 Fuel Oil Guidance
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2020:A View from the Refinery
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China’s Restrictions on Open Loop Scrubber Discharges
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BIMCO 2020 Bunker Clauses *Update*
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Taiwan – Low Sulphur Fuel Rules in 2019 *Update*
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Countdown to 2020: Updates on the IMO Fuel Sulphur Cap
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Getting the Right Fit for the Cap: Assessing the Options
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North Publishes New Loss Prevention Guide on Marine Fuels
-
EGCS: Do They Scrub Up Well?
-
EMSA Publishes Guidance on Testing Fuels for Sulphur
-
2020 Vision
-
Danish EPA to use airborne sniffer technology to monitor passing ship emissions
-
Danish Fines for Fuel Sulphur Violations
-
China: Low Sulphur Fuel - Fines
-
New Fuels and Heat Sensitive Cargoes
-
New Year 2020 – New Regulations
-
Dominican Republic Signing up to the IMO 2020 Sulphur Cap
-
IMO 2020: Notifying Potential Non-compliance
-
North Issues Guidance to Seafarers on Complying with the IMO 2020 Sulphur Cap
-
Iceland Announce Stringent Sulphur Regulations
-
China Issues Guidance on 2020 Sulphur Cap
-
2020 Q&A: Bunker Suppliers Look Over the Horizon
-
Free 2020 Training Video
-
The Long-awaited Publicly Available Schedule (PAS) for Marine Fuels is Ready
-
North Updates Guidance on 2020 Sulphur Cap
-
Notifying Non-Compliant Bunkers in the US
-
The 2020 Sulphur Cap
-
2020: New Fuels on the Horizon
-
Outcomes of MEPC 74 – Dealing with non-compliance
-
2020: Outcomes of MEPC 74 – New Fuels and Bunkering
-
2020: Outcomes of MEPC 74 – Fuel Sampling and Testing
-
It's Time for Members to Prepare for the Big Switch
-
South Africa Issues 2020 Fuel Oil Guidance
-
2020:A View from the Refinery
-
China’s Restrictions on Open Loop Scrubber Discharges
-
BIMCO 2020 Bunker Clauses *Update*
-
Taiwan – Low Sulphur Fuel Rules in 2019 *Update*
-
Countdown to 2020: Updates on the IMO Fuel Sulphur Cap
-
Getting the Right Fit for the Cap: Assessing the Options
-
North Publishes New Loss Prevention Guide on Marine Fuels
-
EGCS: Do They Scrub Up Well?
-
EMSA Publishes Guidance on Testing Fuels for Sulphur
-
2020 Vision
-
Danish EPA to use airborne sniffer technology to monitor passing ship emissions
-
Danish Fines for Fuel Sulphur Violations
-
China: Low Sulphur Fuel - Fines
2020 Shorts
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2020 Shorts (Know Your Fuel)
- Information Sheet
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2020 Shorts (Preparing for Port State)
- Information Sheet
An Overview for Members
Vision 2020 (Submitting FONAR)
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Submitting a Fuel Oil Non-Availability Report (FONAR)
- Information Sheet
Preparing for the Big Switch
Useful Resources
- ABS briefing on the global sulphur cap
- ABS issues guidance on exhaust gas scrubber systems – addressing the regulations, types, selection criteria and retrofitting
- BIMCO has published two new sulphur content related clauses to help deal with time charterparty issues which may arise from the 2020 sulphur cap
- Directive 2005/33/EC Of the European Parliament and of the Council
- EGCSA latest figures on scrubber orders (up to May 2018)
- EGCSA map showing information on SOx emission regulations and guidance on the use of exhaust gas cleaning systems
- EGCSA reference documents
- Free 2020 training video
- “Global Sulphur Cap 2020” guidance document published DNV-GL
- ICS factsheet on the global sulphur cap
- IMO FAQs on the global sulphur cap
- IMO guidance on the development of a ship implementation plan
- INTERTANKO’s Documentary Committee has completed its work on the INTERTANKO Bunker Compliance Clause for Time Charterparties and has published the text for this clause
- Platt’s special report on the global sulphur cap
- Report on MEPC – proposed ban on carrying high sulphur fuel oil
- Update on Intersessional working group meeting on developing draft guidance on 2020 compliance (9-13 July 2018)