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Tanker Shipping & Trade

Tanker Shipping & Trade

IMO brings in bunker note, NOx and fuel consumption amendments

Tue 08 Jan 2019 by Jamey Bergman

IMO brings in bunker note, NOx and fuel consumption amendments
Many IMO amendments entering into force involve environmental regulations (Photo courtesy IMO)

Several agreed amendments to IMO regulatory schemes have entered into force as of the first day of 2019.

Bunker delivery note amendments

The bunker delivery note amendments that came in on 1 January this year require shipowners and operators to carry a certified declaration, signed by a representative of their fuel oil supplier to confirm the sulphur content of the fuel oil supplied meets relevant sulphur limits.

The changes are intended to address the use of 'alternative compliance methods' – essentially exhaust gas cleaning systems (EGCSs or ‘scrubbers’) – which allow shipowners and operators to carry and use non-compliant fuel after IMO global limits on sulphur in marine fuels come into force on 1 January, 2020.

According to the IMO regulation, fuel oil supplied to shipowners and operators using non-compliant fuel must not exceed “the purchaser's specified [sulphur] limit value, on the basis of the purchaser's notification that the fuel oil is intended to be used”:

  1. In combination with an equivalent means of compliance [i.e. scrubbers]; or
  2. Is subject to a relevant exemption for a ship to conduct trials for sulphur oxides emission reduction and control technology research.”

North Sea and Baltic Sea NOx ECAs

Amendments designating the North and Baltic Seas as emissions control areas (ECAs) for nitrogen oxides (NOx) entered into force on 1 January.

The new ECA rules in the regions will come into effect on 1 January 2021, subjecting vessels to IMO’s Tier III NOx emission limits.

Mandatory fuel oil data collection and reporting requirements come into effect

From 1 January 2019, IMO requires ships of 5,000 gt and above to begin collecting data on their fuel-oil consumption.

The Marpol Annex VI regulation on collection and reporting of ship fuel oil consumption data that came into force in March 2018 requires the vessels to collect consumption data for each type of fuel oil they use among other data points.  

Vessels report the aggregated data each calendar year and the flag state checks the data collection is compliant and issues a Statement of Compliance to be held on board the vessel and presented during inspection. 

Flag states also transfer the data into the IMO Ship Fuel Oil Consumption Database from which IMO will produce an annual report to the MEPC, summarising the data collected. 

The data collection system is one of the measures designed to support IMO implementing its Initial Strategy on Reduction of GHG Emissions from Ships, adopted in 2018.


SOx compliance and enforcement is on the menu for discussion at the Americas 2020 Sulphur Cap Conference in Houston this March. Book your place now.

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